Spice & Seasoning Controls That Prevent Salmonella Recalls

A dry seasoning manufacturer in Milwaukee recently discovered the hard way that Salmonella does not need moisture to survive — it just needs a gap in your quality system. Jonco Industries' recall of certain consumer-sized White Cheddar Seasoning products, flagged by the FDA for potential Salmonella contamination, is a useful case study not because it is unusual, but because it is not. Dry spice and seasoning recalls tied to Salmonella happen with enough regularity that the FDA has issued specific guidance on the topic, and yet manufacturers keep landing in the same place.

What follows is a practical breakdown of where these failures tend to originate, what regulations govern them, and what a well-functioning quality system looks like before an FDA investigator shows up at the door.

Why Dry Seasonings Are a Higher-Risk Category Than Most People Assume

The intuition that dry products are inherently safe is one of the more persistent and dangerous assumptions in food manufacturing. Water activity (Aw) below 0.70 does inhibit microbial growth — but it does not kill Salmonella already present in a product. The pathogen can persist in low-moisture environments for months or even years, remain viable through distribution, and become dangerous the moment conditions change.

According to the FDA's own data, spices are among the most frequently recalled food categories for Salmonella contamination. A 2013 FDA import study found that approximately 7% of imported spice shipments were contaminated with Salmonella — roughly twice the contamination rate of other FDA-regulated food imports. That study is over a decade old now, but the structural vulnerabilities it described have not disappeared. They have simply migrated to different points in the supply chain as sourcing patterns have shifted.

The lesson from the Jonco recall is not that white cheddar seasoning is dangerous. It is that any seasoned powder — whether it contains dairy, nutritional yeast, dehydrated vegetables, spices, or some combination — carries real contamination risk that requires active management, not passive assumption.

The Regulatory Framework That Applies Here

FSMA Preventive Controls for Human Food (21 CFR Part 117)

The Food Safety Modernization Act's Preventive Controls rule, codified at 21 CFR Part 117, is the governing regulation for facilities like the one involved in the Jonco recall. This rule moved FDA's posture from reactive (investigate after something goes wrong) to proactive (require documented systems designed to prevent things from going wrong in the first place).

Under 21 CFR Part 117 Subpart C, manufacturers of ready-to-eat (RTE) products — which dry seasonings intended for direct consumer use generally are — must implement a written Food Safety Plan that includes:

• Hazard Analysis identifying known or reasonably foreseeable biological, chemical, and physical hazards (21 CFR §117.130)
• Preventive Controls for each hazard requiring one, including process controls, sanitation controls, supply chain controls, and allergen controls (21 CFR §117.135)
• Monitoring procedures with defined frequency (21 CFR §117.145)
• Corrective action procedures (21 CFR §117.150)
• Verification activities, including environmental monitoring if Salmonella or Listeria monocytogenes is a hazard of concern in the facility (21 CFR §117.165)
• Recall plan as part of a broader supply chain program (21 CFR §117.139)

A Salmonella hazard in a dry seasoning facility producing RTE products is not a borderline call. It is a required hazard identification under any reasonable hazard analysis. If your Food Safety Plan does not name it, the plan is incomplete — and that gap is a 483 observation waiting to happen.

FDA's Compliance Policy Guide and Draft Guidance on Environmental Monitoring

FDA's draft guidance on environmental monitoring programs (EMPs) for Listeria in RTE facilities has a direct analog for Salmonella in spice and seasoning environments. The agency has consistently signaled, through warning letters and 483 observations, that facilities producing RTE low-moisture products must operate a robust EMP that includes indicator organism testing and targeted pathogen testing. The specific expectation is that environmental monitoring be risk-based, meaning higher-risk zones (Zone 1 — food contact surfaces; Zone 2 — near food contact surfaces) receive more frequent sampling than lower-risk areas.

Current Good Manufacturing Practices (21 CFR Part 117 Subpart B)

The cGMP requirements covering personnel hygiene, plant and grounds maintenance, sanitary facilities, equipment design, and production and process controls all apply. Of particular relevance to dry seasoning facilities: equipment that is difficult to clean and dry completely creates harboring sites for Salmonella that can persist through routine sanitation cycles.

Where the Quality System Typically Breaks Down

In my experience working with food manufacturers on FDA compliance, the gap between "we have a Food Safety Plan" and "our Food Safety Plan actually prevents Salmonella" is often wider than it looks on paper. Here are the specific failure points I see most often.

Inadequate Supplier Verification

Dairy-based ingredients — including the cheese powder components typical in white cheddar seasonings — are often sourced from third-party suppliers. FSMA's supply chain program requirements under 21 CFR §117.410–§117.475 require that manufacturers verify their suppliers are controlling hazards that the receiving facility is relying on those suppliers to control. In practice, this means:

• Reviewing supplier food safety plans or audit results, not just certificates of analysis
• Conducting or reviewing incoming material testing for Salmonella at a risk-based frequency
• Requiring Certificates of Analysis (CoAs) that include actual lot-specific test results — not just a supplier's blanket assurance

A CoA that states "product meets specifications" is not supplier verification. It is paperwork. The distinction matters enormously when an FDA investigator is asking how you validated that your incoming cheese powder was free of Salmonella before you blended it into finished product.

Environmental Monitoring Programs That Exist on Paper Only

A written EMP that describes zone-based sampling but has never driven a corrective action is a program that has never been tested. Effective environmental monitoring should, over time, find positives. If your EMP has run for two or three years without a single positive for indicator organisms in Zones 1 or 2, you are probably not sampling the right locations, not sampling with sufficient frequency, or using swabs that are not detecting what is there.

The FDA expects EMPs to be dynamic — meaning the sampling sites, frequency, and corrective action triggers are reviewed and updated based on what the data is showing. A static grid of sites sampled on a fixed schedule, filed away without analysis, is not what the agency has in mind.

Process Validation Gaps for Kill Steps

Some dry seasoning manufacturers apply a heat treatment, roasting step, or other validated kill step to achieve a Salmonella reduction. Many do not, relying instead on supplier-controlled kill steps upstream. If your process relies on a supplier kill step, that reliance must be documented in your hazard analysis, the supplier must be on your approved supplier list with corresponding verification activities, and you need evidence that the kill step is actually being achieved at the claimed log reduction.

If your process does not include any kill step for Salmonella — meaning you are relying entirely on incoming ingredient quality and environmental controls — that risk profile needs to be honestly assessed in your hazard analysis, and your environmental and incoming testing programs need to be calibrated to that higher residual risk.

Allergen Controls That Inadvertently Introduce Cross-Contamination Routes

This one is less obvious but worth naming. White cheddar seasoning is a multi-ingredient product. Facilities that run multiple seasoning SKUs often have complex changeover and cleaning protocols. Equipment shared across products, inadequate line clearance, and co-mingling of ingredient streams can introduce contamination — microbial or allergen — in ways that are hard to trace back to a single root cause. Cleaning verification (swab testing post-cleaning, not just visual inspection) is a basic but frequently absent control.

What a Prevention-Focused Quality System Looks Like

The gap between the minimum column and the better practice column is not just a quality preference. It is often the gap between catching a contamination event internally and learning about it from an FDA recall notice.

The Environmental Monitoring Deep Dive

Because environmental monitoring is the most commonly underdeveloped element I see in dry product facilities, it is worth going deeper here.

An effective EMP for a Salmonella risk in a low-moisture RTE facility should include the following components:

Zone Definition and Risk Ranking. Zone 1 is food contact surfaces during production. Zone 2 is non-food contact surfaces immediately adjacent to food contact surfaces or open product. Zone 3 is more remote surfaces in the production environment (floors, drains, walls). Zone 4 is outside the production environment (hallways, locker rooms, receiving areas). Higher-zone sampling informs where Salmonella might be harboring; Zone 1 and 2 findings require the most aggressive corrective action.

Sampling Frequency. At minimum, Zone 1 and 2 sampling should occur weekly in facilities with a confirmed Salmonella hazard. Zone 3 and 4 sampling monthly is a reasonable starting point, with frequency adjusted based on findings.

Corrective Action Triggers. A presumptive positive on an indicator organism (like Enterobacteriaceae) should trigger an immediate investigation and increased sampling frequency. A confirmed Salmonella positive in Zone 1 or 2 triggers product hold, root cause investigation, enhanced cleaning, and typically product testing for any lots produced since the last negative result.

Trending and Analysis. Monthly trend reports showing positive rates by zone and site, seasonality patterns, and correlation with operations (e.g., post-maintenance, post-new-employee onboarding) turn raw sampling data into actionable intelligence.

Effective Dates and Current Compliance Expectations

The FSMA Preventive Controls rule for larger businesses has been in full effect since September 19, 2016. Small businesses (fewer than 500 full-time equivalent employees) had a compliance date of September 18, 2017. Very small businesses (under $1 million in total annual sales of human food) had until September 17, 2018. There are no grace periods remaining for any category.

This means that as of 2026, any food manufacturer subject to 21 CFR Part 117 who does not have a documented, implemented, and verified Food Safety Plan is not just taking a regulatory risk — they are operating in a posture that has been non-compliant for years. FDA inspections of food facilities routinely cite deficiencies in environmental monitoring, supplier verification, and hazard analysis. Warning letters from the past 18 months reflect continued enforcement focus on exactly these elements.

If you have a Food Safety Plan that was written in 2017 and has not been substantively reviewed since, it almost certainly does not reflect current FDA expectations for EMPs, supply chain verification, or recall plan robustness. That is not a hypothetical risk — it is a documented pattern in FDA 483 observations.

Practical Steps to Take Before the Next Inspection

You do not need to wait for a recall notice — or an FDA investigator — to identify whether your system has the gaps described above. Here is what I would prioritize:

1. Pull your hazard analysis and confirm Salmonella is addressed for every incoming ingredient that could plausibly carry it, and for your production environment. If it is not there, add it — and document the reasoning.

2. Review your EMP for the last 12 months. How many samples were collected? How many were positive for indicator organisms or pathogens? What corrective actions were taken? If the answers are "not many," "none," and "none," your EMP needs attention.

3. Audit your supplier verification records. For your highest-risk ingredients — dairy powders, spice blends, nutritional ingredients — do you have actual lot-level data or just supplier assurances? If it is the latter, that is a supply chain program gap under 21 CFR §117.410.

4. Run a mock recall. Trace a single lot of finished product through your distribution records. How long does it take? Can you identify all customers who received it? Do your records support a targeted recall versus a broad one? The answer to these questions tells you a lot about your recall plan's real-world readiness.

5. Review your corrective action records. A quality system that has no corrective actions is usually not a quality system that has no problems — it is a quality system that is not finding problems. Corrective actions are a sign of a functioning system, not a failing one.

A Note on Scale

One thing I want to be direct about: the Jonco recall is a reminder that small and mid-sized manufacturers are not exempt from these requirements or from these risks. FSMA applies regardless of company size (with the limited exception of very small businesses under specific thresholds). FDA inspects smaller facilities. And a Salmonella recall — with the associated costs of product destruction, customer notification, reputational damage, and potential regulatory action — is disproportionately damaging to a smaller operation.

The good news is that a well-designed Food Safety Plan, a functioning EMP, and a disciplined supplier verification program do not require a large quality team. They require clear procedures, consistent execution, and honest review of what the data is actually telling you.

Certify Consulting has helped 200+ food and dietary supplement manufacturers build and defend exactly these systems — including facilities that have gone through FDA inspections and maintained a 100% first-time audit pass rate. If you want to know where your current system stands, a gap assessment is a reasonable first step. Learn more about our FDA compliance and audit readiness services.

Source: FDA recall notice — Jonco Industries, Inc. recall of consumer-sized White Cheddar Seasoning products for potential Salmonella contamination

Last updated: 2026-05-24