Spices and herbs have become a key focus on FDA’s radar because of the high risk of contamination.
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DAVID ACHESON, Founder and CEO, The  Acheson  Group

What do basil, black pepper, coriander, cumin, curry powder, oregano, white pepper, red pepper, paprika and sesame seeds have in common?

The most general answer, of course, is that all are spices or herbs. Running a close second is that imports are the major source of the U.S. spice supply. But what you may not know is that these spices and herbs have become a key focus on FDA’s radar because of the high risk of contamination, particularly in those that are imported. These can be highly susceptible to pathogens because of the way they are harvested and dried, primarily in developing countries.

According to USDA, more than 95% of coffee/cocoa/spice products consumed in the U.S. are imported, with the dollar value of imported spices nearly doubling between 2009 and 2014 (the most recent year for which USDA has data) from $647 million to more than $1.34 billion. But, in its 2013 spice risk profile, FDA found imported spices  to have an estimated 6.6% Salmonella prevalence rate at port of entry into the U.S., with some countries being significantly higher, such as Mexico’s which hit 14%. Additionally, there was a 12% prevalence of filth adulteration in the spice shipments.

On a positive note, the agency’s follow-up 2017 spice risk profile found that this risk is greatest at import, with no spices having a Salmonella prevalence rate greater than 0.65% at retail, and many at or nearly reaching zero. In the report, FDA stated that it sees this as consistent with the assumption that most (bulk) shipments of spices undergo a pathogen reduction treatment in U.S. processing. It also is consistent with the most recent data from CDC’s Foodborne Outbreak Online Database (spanning the years 1998-2016) which show only 18 foodborne illness outbreaks linked to herbs or spices resulting in 859 illnesses, 19 hospitalizations, and no deaths.

But because there is so much risk associated with spices, even these numbers are of concern, enough so that FDA is increasing its oversight to ensure that the risk is significantly reduced from import to consumer.

In a separate but somewhat related undertaking, FDA has begun a Microbiological Surveillance Sampling of fresh cilantro, basil, and parsley (along with avocado products) that are retailed without a kill step. Because of their susceptibility to contamination and the number of outbreaks that have occurred, the agency is testing for Salmonella and E. coli  (STEC) in these foods. Although the agency is sampling only fresh, raw herbs, it is focused on those of both imported and domestic origin, so is collecting samples virtually throughout the supply chain — prior to consumer handling.

So, if you sell spices, fresh herbs, or avocado products at retail or produce an RTE product in which these are used without a further kill step, FDA’s increased oversight is of critical significance to you. And that significance increases when one considers FDA’s current use of whole genome sequencing (WGS) which enables the linkage of pathogens from food or environmental samples to those of ill persons. Thus, when sampling data is logged into the National Antimicrobial Resistance Monitoring System (NARMS), it could link you as a source in an outbreak — past, present, or future.

There are very few foods that do not use spices or herbs, and you can be sure that whether FDA is showing up at your door to take samples for its microbiological surveillance or is simply conducting a regular inspection, your spices and herbs will be on their radar. The agency also has made it clear that it will be conducting the surveillance sampling in the same manner as a regular inspection; that is: no notice. And if a positive is found, action likely will be taken, which could include placing the firm on import alert, pushing for a recall, or issuing public warnings.

Spices and herbs are high-risk foods. And with Salmonella and E. coli being found in product, primarily at import but also at retail, FDA is concerned. Which means that you need to be concerned and conduct an intensive assessment of the steps you take for detection, prevention, and reduction of pathogenic contamination. Does your food safety plan include a focus on the herbs and spices you use? Do you have a stringent supply chain program? Are you in compliance with all relevant Preventive Controls of FSMA?

If not, you could be risking regulatory action.