Salmonella Controls That Prevent FDA Dry Seasoning Recalls

The Jonco Industries recall of certain consumer-sized White Cheddar Seasoning products — announced in June 2026 for possible Salmonella contamination — adds another entry to a troublingly long list of spice and seasoning recalls in recent years. If you manufacture, co-pack, or distribute dry seasonings, or if you source flavoring components from third parties, this event should prompt a hard look at your own program.

The recall itself isn't the lesson. The lesson is what these events reveal about where quality systems tend to break down in dry seasoning manufacturing, and what a well-designed preventive controls program looks like when it's actually doing its job.

Why Salmonella in Dry Products Is a Persistent Problem

Most food professionals understand Salmonella as a pathogen that thrives in moisture. That intuition is correct but incomplete — and the incompleteness is what gets companies into trouble.

Salmonella can survive for months, sometimes years, in low-moisture environments. Water activity (aw) below 0.60 stops Salmonella from growing, but it does not kill the organism. A contaminated dry seasoning that enters your facility will persist in your production environment until you take deliberate action to eliminate it. And because many dry seasonings are consumed without further cooking — on popcorn, crackers, ready-to-eat snacks — there's no kill step downstream to save you if your controls fail upstream.

A 2013 FDA import surveillance study found that approximately 7% of spice shipments entering the U.S. were contaminated with Salmonella or Salmonella-indicator organisms. That figure has improved since FSMA went into effect, but dry seasonings and spices still carry elevated contamination risk compared to most other processed food categories. The CDC estimates that Salmonella causes approximately 1.35 million infections in the United States each year, with 26,500 hospitalizations and 420 deaths — and low-moisture foods like spices and seasonings account for a meaningful portion of those numbers.

In my view, the industry has underestimated the complexity of dry-environment Salmonella control for a long time. The assumption that "it's dry, so it's safe" has driven real harm.

The Regulatory Framework: What 21 CFR Part 117 Actually Requires

If you produce seasoning products, your primary regulatory obligation is 21 CFR Part 117 — the FSMA Preventive Controls for Human Food rule. This rule replaced and significantly expanded the older CGMP framework under 21 CFR Part 110, and it specifically requires you to conduct a written hazard analysis and implement preventive controls for hazards that are reasonably foreseeable in your facility.

Salmonella in dry seasonings is a reasonably foreseeable biological hazard. That's not a gray area. FDA has cited spices and low-moisture foods in every major guidance document on biological hazards for processed foods, and your hazard analysis needs to address it explicitly.

Under 21 CFR § 117.135(c), your preventive controls must include, as appropriate to your facility and product:

• Process controls — including specific parameters and values for any step that controls the hazard
• Sanitation controls — specifically aimed at environmental pathogens if they're relevant to your production environment
• Supply-chain controls — when you're relying on a supplier, rather than your own process, to control a hazard

For dry seasoning manufacturers, all three of these typically apply. A gap in any one of them can produce exactly the kind of event that generates an FDA recall notice.

Compliance with 21 CFR Part 117 has been required for large manufacturers since September 2016 and for small businesses since September 2017. If your food safety plan doesn't address Salmonella through environmental monitoring and supply chain verification, you're already out of compliance — and you're operating at elevated recall risk.

Supplier Qualification: Where Most Dry Seasoning Risks Begin

Dry seasonings are almost universally multi-ingredient products. White cheddar seasoning typically contains dairy solids, salt, natural flavors, maltodextrin, and various spice components — each sourced from a different supplier, often with multiple countries of origin in the supply chain.

Every one of those ingredients is a potential contamination vector. If your supplier qualification program doesn't verify food safety controls upstream, you're essentially assuming that everyone else in your supply chain has their systems in order.

Under 21 CFR §§ 117.410–.430, FDA requires supply-chain controls for any hazard that is controlled before receipt — meaning you're depending on your supplier to control the risk rather than your own process. For Salmonella in dry ingredients, if you don't have a validated thermal or other kill step in your own production process, you are by definition relying on your supplier. And that dependency requires a documented verification program: supplier audits, certificates of conformance backed by actual laboratory data, or incoming sampling and testing of high-risk materials.

A functional supplier qualification program for dry seasonings includes:

• An approved supplier list with documented qualification criteria for each ingredient category
• At minimum, annual review of supplier food safety performance — audit reports, third-party certifications like SQF or BRC Level 2+, or recent COAs from accredited laboratories
• Incoming lot testing for high-risk ingredients, particularly dairy components and any ingredient with a documented Salmonella risk history in FDA's records
• A formal approval workflow for new ingredients and new suppliers before first use in production

What I see repeatedly in small and mid-sized seasoning companies is an informal vendor relationship that substitutes for a documented program. A long-standing supplier relationship feels like trust, and in some ways it is. It is not, however, the same thing as verification — and FDA doesn't treat it as equivalent during an inspection.

Environmental Monitoring Programs: Your Early Warning System

If supplier controls are your first line of defense, your Environmental Monitoring Program (EMP) is your early warning system. It answers a specific question: even if contamination entered my facility, would I know before it reached finished product?

For facilities producing ready-to-eat or no-further-cooking products — which includes most dry seasoning applications — FDA's guidance on environmental monitoring is clear. Under 21 CFR § 117.165(a)(3), environmental monitoring is explicitly listed as a required verification activity for sanitation controls when environmental pathogens are a relevant hazard. If your food safety plan identifies Salmonella as a biological hazard and lists sanitation controls to address it, you need an EMP. This is not optional.

A well-designed EMP for a dry seasoning facility divides sampling by zone:

The sampling cadence matters, but so does what you do when a positive comes back. An EMP that generates results with no defined corrective action protocol is documentation theater, not a control. Your program should specify what happens when Salmonella is detected at each zone: intensified sampling, a sanitation event, a production hold, a root cause investigation. The investigation trail is what FDA reviewers examine during FSMA inspections — and what a well-run facility can produce quickly when a contamination event occurs.

Process Controls and Validated Kill Steps

The most reliable solution to Salmonella risk in dry seasonings — if your process allows it — is a validated thermal kill step applied to finished blend or to high-risk components before blending. This could be steam treatment, dry heat, or another scientifically validated method.

A validated kill step means you have documented scientific evidence that your process achieves the intended log reduction of Salmonella under defined conditions. The validation study must cover worst-case scenarios: the highest contamination load you'd reasonably expect, the lowest treatment intensity your process might deliver, and the product formulation that presents the greatest challenge to heat penetration. FDA expects to see this validation data — and the monitoring records confirming that validated parameters are being achieved — in your food safety plan.

Not every dry seasoning facility has the infrastructure for thermal treatment. If yours doesn't, that's not automatically a compliance problem, but it does mean your supplier qualification program and your EMP are carrying more of the weight. You need to be honest with yourself about whether those programs are actually robust enough to compensate for the absence of an in-process kill step.

In my experience working with more than 200 clients on food safety compliance over the past eight-plus years, the facilities that end up in regulatory difficulty aren't usually cutting corners deliberately. They're operating on assumptions that were never verified — that the supplier handles it, that the dry environment makes it safe, that the testing program is comprehensive enough. What they needed was someone to ask those assumptions out loud.

Finished Product Testing: Its Role and Its Limits

Many dry seasoning manufacturers rely heavily on finished product testing — releasing lots after a certificate of analysis comes back negative. This approach has a legitimate role in a layered control system, but it has real limitations that are worth understanding clearly.

Salmonella is not uniformly distributed in a contaminated lot. A contaminated batch of seasoning blend might contain a small number of affected particles spread through 5,000 pounds of product. Standard sampling plans, even statistically rigorous ones, have meaningful probability of missing a low-level contamination event. FDA's compliance policy for environmental pathogens explicitly acknowledges that finished product testing alone is insufficient when the hazard is a pathogen that could be unevenly distributed.

Finished product testing works best as a final verification tool — confirming that upstream controls are performing — not as the primary control mechanism. If your food safety plan lists lot release testing as your primary or sole control for Salmonella, that's a gap FDA is likely to identify during a FSMA inspection.

What you want is a layered system: supplier qualification reduces the probability that contamination enters your facility, process controls and environmental monitoring detect it if it does enter, and finished product testing provides a final check before product ships. Each layer compensates for the inherent limitations of the others.

Recall Readiness: When Controls Fail Anyway

Even a well-designed quality system doesn't guarantee zero recalls. Contamination events happen. When they do, how quickly and thoroughly you respond determines the public health impact — and often, FDA's assessment of your overall food safety culture.

Under 21 CFR Part 7, FDA can request a voluntary recall and, under FSMA authority, mandate one if a company fails to act. In practice, most Salmonella recalls in dry foods are voluntarily initiated — but FDA is paying close attention to whether a company identified the issue proactively or reacted only after external signals. That distinction matters both to regulators and to the public record.

A functional recall readiness program includes:

• Traceability records sufficient to identify which lots contain potentially affected material and where that material has been distributed. Under 21 CFR § 117.310, records must support the traceability that a class I recall requires.
• Annual mock recall exercises with documented outcomes and corrective actions — not just a table-top walk-through, but a test of your actual records system
• A defined communication protocol for notifying distributors, retail customers, and consumers within the timeframes FDA expects
• A root cause investigation process that identifies and addresses the origin of contamination, not just the affected product

If your records system can't support a complete recall notification within 24 hours of a decision to recall, that's a gap worth closing before you need it.

What a Strong Quality System Looks Like: A Practical Summary

Bringing this together, a dry seasoning manufacturer with a genuinely functional quality system would have all of the following in place:

1. A current, written food safety plan (HARPC) that explicitly identifies Salmonella as a reasonably foreseeable biological hazard with documented preventive controls and monitoring records
2. A documented supplier qualification program with defined incoming material testing requirements for high-risk ingredients, including dairy components
3. A zone-based Environmental Monitoring Program with corrective action protocols and investigation documentation for any positive result
4. Either a validated kill step or a documented, defensible rationale for why supplier and environmental controls are adequate in its absence
5. Finished product testing positioned as a verification activity within a layered system, not as the primary control
6. Annual mock recall exercises with documented traceability verification
7. Training records demonstrating that production and quality personnel understand their role in each preventive control

None of this is exotic. All of it is required or clearly expected under 21 CFR Part 117. The challenge isn't usually knowing what the program should look like — it's building a system where these things happen consistently and leave the documentation trail that an FDA investigator expects to see.

Take Stock Before the FDA Does

Dry seasoning recalls like the one Jonco Industries is managing right now are not random events. They follow predictable patterns — patterns that show up in the hazard analysis, the supplier qualification records, and the environmental monitoring data before they show up in a recall notice. The question worth asking is whether your program would catch those signals in time.

At Certify Consulting, we've helped more than 200 food manufacturers build and strengthen the quality systems that prevent these events — with a 100% first-time audit pass rate across eight-plus years of practice. If you're in the seasoning, spice, or flavoring business and aren't fully confident your food safety plan covers Salmonella with the depth 21 CFR Part 117 requires, that's worth examining now. Learn more about our FSMA compliance consulting services and what a gap assessment looks like for facilities in your position.

Source: FDA Safety Alerts — Jonco Industries White Cheddar Seasoning Recall, June 2026. This article is provided for educational and informational purposes. It does not constitute legal or regulatory advice.

Last updated: 2026-06-07