Dry botanicals stop microbes from growing, yet Salmonella and spores survive in them
This course explains the USP tests behind a botanical's microbial specification, the organisms that slip past them, and the kill steps that lower the risk. It works through spores, acid tolerance, biofilms and cells that are alive but form no colonies, using published data and three calculators.
Each pathogen grows only inside its own window of water activity, pH and temperature, so lowering any one of them can stop it
You will learn
- How USP ⟨2021⟩, ⟨2022⟩ and ⟨2023⟩ set and test botanical microbial limits, and how they differ from ⟨61⟩, ⟨62⟩ and ⟨1111⟩.
- Why low water activity stops growth but does not sterilize, using FDA growth limits.
- Which cells a plate count misses: spores, injured cells, persisters, biofilm cells and viable but nonculturable cells.
- How to compute a kill step with D, z and F values, and why dry products need far more heat.
- What a plate count and an "absent in 10 g" result can and cannot prove.
- How steam, dry heat, irradiation and ethylene oxide compare, with their U.S. rules.
USP sets botanical limits by how processed the material is, from 10² to 10⁶ cfu/g
Text version of the chapter comparison
- ⟨2021⟩ TAMC on soybean–casein digest agar, 48–72 h; TYMC on Sabouraud dextrose agar at 20–25 °C for 5–7 days; plates expected to give 30–300 colonies; preparatory testing must show more than 70% recovery of spiked organisms. ⟨61⟩ TAMC at 30–35 °C for 3–5 days; TYMC at 20–25 °C for 5–7 days; counts from plates below 250 (TAMC) or 50 (TYMC); suitability requires recovery within a factor of 2.
- ⟨2022⟩ Absence of Salmonella, E. coli, S. aureus and Clostridium species, normally in 10 g, with a 25 g retest for doubtful results. For Clostridium, one portion is heated to 80 °C for 10 min. ⟨62⟩ Bile-tolerant Gram-negative bacteria, E. coli, Salmonella, P. aeruginosa, S. aureus, Clostridia and C. albicans.
- ⟨2023⟩ Recommended limits by material (next figure), used when the monograph does not specify limits. ⟨1111⟩ Acceptance criteria by route; for nonaqueous oral drugs TAMC 10³, TYMC 10², absence of E. coli in 1 g; a criterion of 10¹ means a maximum acceptable count of 20, 10² means 200, and so forth.
Data table: USP ⟨2023⟩ recommended limits (cfu/g or mL)
| Material | TAMC, NMT | TYMC, NMT | Other |
|---|---|---|---|
| Dried or powdered botanicals | 10⁵ | 10³ | BTGN NMT 10³; absence of Salmonella spp. and E. coli in 10 g |
| Powdered botanical extracts | 10⁴ | 10³ | Absence of Salmonella spp. and E. coli in 10 g |
| Tinctures | 10⁴ | 10³ | None listed |
| Fluidextracts | 10⁴ | 10³ | None listed |
| Infusions and decoctions | 10² | 10 | None listed |
| Nutritional supplements with botanicals | 10⁴ | 10³ | Absence of Salmonella spp. and E. coli in 10 g |
| Botanicals to be treated with boiling water before use | 10⁶ | 10⁴ | BTGN NMT 10²; absence of E. coli and Salmonella spp. in 10 g |
| Other raw materials and dietary supplement ingredients | 10³ | 10² | Absence of E. coli in 10 g |
| Nutritional supplements with synthetic or highly refined ingredients | 10³ | 10² | Absence of E. coli in 10 g |
Source: USP 38–NF 33, ⟨2023⟩ Tables 2 and 3. In USP 35–NF 30 (official May 1, 2012) the boiling-water category read TAMC 10⁵, TYMC 10³ and absence of E. coli in 10 g, so the chapter has changed before; the 2025 version could not be read without a subscription. AHPA's June 2022 comparison lists the same values as USP 38 for dried botanicals, powdered extracts and supplements with botanicals.
Explanation, details and sources
Two counts anchor a typical specification. TAMC is the total aerobic microbial count; TYMC is the total combined yeast and mold count. Both are reported in colony-forming units (cfu) per gram, where one cfu is any cell or clump that grows into a visible colony. Absence tests then look for named pathogens in a stated mass.
The category drives the decision. Reclassifying a raw powder as a powdered extract tightens the TAMC recommendation tenfold, from 10⁵ to 10⁴ cfu/g, while the yeast-and-mold and Salmonella and E. coli recommendations stay the same. A supplier specification that quotes only a count, with no category and no absence tests, is incomplete.
A plate count is meaningful once the method has shown it recovers organisms from that botanical
Text version of the workflow
- Suitability first. Inoculate 25–250 cfu of challenge strains; ⟨2021⟩ requires more than 70% recovery, ⟨61⟩ a count within a factor of 2 of the control. If the botanical inhibits growth, increase the diluent volume or add inactivators such as soy lecithin 0.5% and polysorbate 20 4.0%. FDA BAM states that "there are no known methods for neutralizing the toxicity" of allspice, cinnamon, cloves and oregano, and examines them at 1:100 (cloves 1:1000). Onion and garlic are pre-enriched with 0.5% K₂SO₃.
- Count. Suspend 10 g in diluent to 100 mL (1:10), make tenfold dilutions and plate in duplicate. Report the mean in cfu/g, or "less than 10 per g" when the 1:10 plates are blank.
- Absence. Pre-enrich in nonselective broth, transfer to selective broth (Rappaport Vassiliadis for Salmonella; MacConkey broth at 42–44 °C for E. coli), streak selective agar and confirm typical colonies.
- Clostridia. Heat one portion to 80 °C for 10 min, culture both portions anaerobically, and look for catalase-negative Gram-positive rods.
Method, assumptions and limits
- What it calculates
- The concentration of culturable organisms in the sample from colony counts on duplicate plates at two tenfold dilutions, by two published rules, and compares it with a specification.
- Equations
- FDA BAM maximum-likelihood estimate without too-numerous plates: cfu/g = ΣNi/ΣVi over plates with 15–300 colonies, reported to two significant figures (third digit 5 rounds to even). USP ⟨61⟩: the arithmetic mean of the plates at the dilution with the highest counts below 250 (TAMC) or 50 (TYMC), divided by the grams of sample per plate. The 95% interval uses exact Poisson limits on ΣNi.
- Variables and units
- Ni colonies on plate i; Vi grams of original sample on plate i; the first dilution 10⁻¹ is the 1:10 suspension of 10 g in 100 mL.
- Assumptions
- Colonies are Poisson-distributed around the true mean; the method has passed its recovery check; one colony arises from one cfu.
- Valid range
- 0–5,000 colonies per plate. When no plate falls in 15–300, the BAM result is flagged as estimated. When every plate is blank, the result is reported as less than one colony on the least diluted plate.
- What it does not establish
- It ignores sampling error between containers, which is usually larger than counting error. It counts only culturable cells. Applying the ⟨1111⟩ rule that 10ⁿ means at most 2 × 10ⁿ to a ⟨2023⟩ limit is shown for comparison; the ⟨2023⟩ text we read does not state that rule.
- References
- FDA BAM Chapter 3 (January 2026 edition); USP 38–NF 33 ⟨61⟩ and ⟨1111⟩.
- Verification
- An independent Python solution in
tests/numerics/ref/academy_microbiology.py(scipy chi-square limits) reproduces the readouts, including BAM Example 2.1a (14,000).
Explanation, details and sources
Some botanicals inhibit the very organisms a test looks for. FDA's method lists allspice, cinnamon, cloves and oregano as toxic to Salmonella in the broth, so the laboratory first spikes known organisms into the sample and proves it recovers them.
Salmonella sits in spices at low, patchy levels, so the mass tested decides what a test can find
Data table: Salmonella prevalence at import and at retail
| Spice | Import positive / tested | Import % (95% CI) | Retail positive / tested | Retail % (95% CI) |
|---|---|---|---|---|
| Coriander, ground | 17 / 92 | 18 (11–28) | 3 / 543 | 0.56 (0.11–1.6) |
| Red pepper, ground | 36 / 337 | 11 (7.6–14) | 4 / 633 | 0.64 (0.17–1.6) |
| Oregano | 8 / 78 | 10 (4.5–19) | 1 / 669 | 0.15 (0.0038–0.83) |
| Cumin | 11 / 130 | 8.5 (4.3–15) | 0 / 549 | 0 (0.00–0.67) |
| Sesame seed, whole | 12 / 155 | 7.7 (4.1–13) | 0 / 526 | 0 (0.00–0.70) |
| Black pepper | 15 / 223 | 6.7 (3.8–11) | 3 / 1,264 | 0.24 (0.049–0.69) |
| White pepper, ground | 3 / 50 | 6 (1.3–17) | 0 / 588 | 0 (0.00–0.63) |
| Basil | 1 / 20 | 5 (0.13–25) | 1 / 529 | 0.19 (0.0048–1.1) |
| Curry powder, ground | 7 / 177 | 4 (1.6–8.0) | 1 / 518 | 0.19 (0.0049–1.1) |
| Paprika, ground | 3 / 85 | 3.5 (0.73–10) | 2 / 816 | 0.25 (0.030–0.88) |
| Dehydrated garlic, ground | 1 / 59 | 1.7 (0.043–9.1) | 3 / 615 | 0.49 (0.10–1.4) |
FDA 2017 update, Table 1 (retail, 125 g) and Table 2 (import, 750 g). Imports and retail differ significantly for all spices except basil and dehydrated garlic. Spice risk profile 2013 draft: 14 outbreaks in Canada, Denmark, France, Germany, New Zealand, Norway, Serbia, the United Kingdom and the United States; Salmonella caused 10 (87% of illnesses) and Bacillus spp. 4 (13%).
p = 1 − (1 + c m/k)−k (clumped)
Plot = 1 − (1 − p)n
Method, assumptions and limits
- What it calculates
- The probability that a presence/absence test finds a contaminant at a given mean concentration, for one or several test portions.
- Equations
- Poisson: p = 1 − exp(−c m). Gamma-Poisson (negative binomial) with dispersion k: p = 1 − (1 + c m/k)−k, which tends to the Poisson result as k grows. For n independent portions with no positives allowed: P = 1 − (1 − p)n.
- Variables and units
- c mean cfu per g; m grams per portion; n portions; k dimensionless (smaller is more clumped).
- Assumptions
- The method detects one living, culturable cell in the portion (a perfect test); portions are independent; the lot mean is constant.
- Valid range
- 10⁻⁴ to 10 cfu/g; 1–60 portions.
- What it does not establish
- It does not model false negatives from inhibitory botanicals, injured or VBNC cells, or variation between lots. FDA found that a gamma-Poisson model fit its shipment data better than five other models, which is why clumping is offered; the k values here are illustrative, not FDA's fitted values.
- References
- FDA 2013 draft spice risk profile; EFSA BIOHAZ Panel, Guidance on microbiological criteria (2017); Gonzales-Barron, Zwietering and Butler (2013).
- Verification
- Checked against an independent Python implementation (scipy.stats.nbinom and poisson).
Explanation, details and sources
FDA tested imported spice shipments for fiscal years 2007–2009: 6.6% carried Salmonella (750 g tested; 95% CI 5.7–7.6%), against 3.4% for all other imported FDA-regulated foods. Fourteen spice-linked outbreaks from 1973 to 2010 caused 1,946 reported illnesses, 128 hospitalizations and two deaths. In contaminated capsicum shipments the mean concentration ranged from 6 × 10⁻⁴ to 0.09 MPN/g.
At the concentrations FDA measured, a single 10 g test is a weak screen. Confidence comes from testing more mass in more independent portions, and from a validated kill step that does not depend on finding the cells first. The calculator below shows the arithmetic.
Below water activity 0.83 none of FDA's listed pathogens grows, but dry storage does not sterilize
Data table: FDA Table A-1 growth limits
| Pathogen | Min. aw | Min. pH | Max. pH | Temperature range, °C |
|---|---|---|---|---|
| Bacillus cereus | 0.92 | 4.3 | 9.3 | 4–55 |
| Campylobacter jejuni | 0.987 | 4.9 | 9.5 | 30–45 |
| C. botulinum type A, proteolytic B and F | 0.935 | 4.6 | 9 | 10–48 |
| C. botulinum type E, nonproteolytic B and F | 0.97 | 5 | 9 | 3.3–45 |
| Clostridium perfringens | 0.93 | 5 | 9 | 10–52 |
| Pathogenic E. coli | 0.95 | 4 | 10 | 6.5–49.4 |
| Listeria monocytogenes | 0.92 | 4.4 | 9.4 | −0.4–45 |
| Salmonella spp. | 0.94 | 3.7 | 9.5 | 5.2–46.2 |
| Shigella spp. | 0.96 | 4.8 | 9.3 | 6.1–47.1 |
| Staphylococcus aureus, growth | 0.83 | 4 | 10 | 7–50 |
| S. aureus, toxin formation | 0.85 | 4 | 9.8 | 10–48 |
| Vibrio cholerae | 0.97 | 5 | 10 | 10–43 |
| Vibrio parahaemolyticus | 0.94 | 4.8 | 11 | 5–45.3 |
| Vibrio vulnificus | 0.96 | 5 | 10 | 8–43 |
| Yersinia enterocolitica | 0.945 | 4.2 | 10 | −1.3–42 |
FDA Fish and Fishery Products Hazards and Controls Guidance, Appendix 4, Table A-1 (downloaded October 23, 2026). Xerophilic fungi: some germinate at 0.650–0.605, and mycelial growth limits near 0.65 were lowered to 0.640 by adjusting solutes (Stevenson et al. 2015). Drying and particle engineering covers how to measure aw and choose packaging.
Explanation, details and sources
Water activity (aw) is the vapor pressure of a material divided by that of pure water at the same temperature. It measures available water, which is different from moisture content. FDA's 1984 inspection guide notes that foods controlled to aw 0.85 or less are exempt from 21 CFR Parts 108, 113 and 114. A dried botanical well below 0.6 supports no microbial growth, yet Salmonella and spores already present can survive.
For a product decision, water activity controls growth during shelf life and is set by drying and packaging. It is not a kill step, so a dry botanical still needs counts and absence tests at release.
Spore formers survive drying and mild heat, so dried botanicals drift toward them
Text version of the spore figure
A vegetative cell forms a forespore, the mother cell lyses, and the free spore can stay dormant for years. Nutrient germinants act on receptors in the inner membrane; the core releases its dipicolinic acid, the cortex is degraded, and the core takes up water. The core holds DNA saturated with small acid-soluble proteins (SASP), which protect it. A lower core water content gives more wet-heat-resistant spores. Tests exploit this: ⟨2022⟩ and ⟨62⟩ heat one portion to 80 °C for 10 min before anaerobic culture. In the spice risk profile, Bacillus spp. caused 4 of 14 spice-linked outbreaks and 13% of illnesses.
Data table: B. cereus spore D-values and spray-drying reductions
| Strain | D 90 °C, min | D 100 °C, min | D 110 °C, min | Log reduction, outlet 95 / 105 / 110 °C |
|---|---|---|---|---|
| 540 | 17.71 | 4.31 | 0.62 | 2.19 / 2.21 / 4.08 |
| B63 | 35.64 | 2.30 | 0.67 | 2.45 / 2.52 / 2.76 |
| 436 | 23.03 | 1.48 | 0.30 | 0.06 / 1.01 / 1.39 |
D-values in phosphate-buffered saline (Table 1); log reductions in skim milk at inlet 150, 170 and 190 °C (Table 2). Alvarenga et al. 2018.
Explanation, details and sources
Bacillus and Clostridium species can enclose a copy of their DNA in a dormant endospore. The spore's dry core helps it resist heat, radiation and many chemicals, and spores can stay dormant for years. USP ⟨2023⟩ notes that in dried botanicals the flora "will tend to change from Gram-negative bacteria to Gram-positive spore formers and fungi".
A mild acid exposure can make Salmonella far harder to kill with strong acid
Text version of the acid tolerance figure
Foster and Hall grew Salmonella Typhimurium at pH 7.6, shifted it to pH 5.8 for one doubling, then challenged it at pH 3.3. Adapted cells were 100 to 1,000 times more resistant than unadapted cells. The response needed protein synthesis (12 proteins induced and 6 repressed) and the proton-translocating ATPase. The authors reported: “No cross protection was noted for hydrogen peroxide, SOS, or heat shock.” In E. coli, the glutamate system (GadA and GadB decarboxylases with the GadC antiporter) and the arginine system (AdiA with AdiC) each consume an intracellular proton per decarboxylation and export the product in exchange for fresh substrate. Lin et al. found that once induced, these systems remain active through prolonged cold storage at 4 °C.
Explanation, details and sources
Acidic botanical extracts and the stomach (pH 1–3) are both acid stresses. Bacteria that first meet mild acid switch on defenses. Salmonella shifted to pH 5.8 for one doubling survived a pH 3.3 challenge 100 to 1,000 times better than cells moved straight from pH 7.6. Acid-adapted Salmonella also tolerated heat and salt better in a separate study (Leyer and Johnson 1993).
For acidic extracts and beverages, acidity alone is a poor kill step. Cells that survive a mild acid stage can resist a stronger one, and the same exposure can raise their tolerance of heat and salt.
Biofilms shelter cells on equipment and can need far higher antimicrobial doses to remove
Text version of the biofilm figure
Stages: (1) organic matter adsorbs to the surface; (2) cells attach loosely and can leave; (3) cells attach firmly and begin making EPS; (4) a microcolony grows inside the matrix; (5) a mature biofilm forms towers separated by water channels; (6) cells disperse to colonize new sites. The matrix is mainly polysaccharides, proteins, nucleic acids and lipids. With the Calgary Biofilm Device, eradicating biofilms of reference strains often needed 100 to 1,000 times the concentration that inhibits planktonic cells, for some antibiotics. Proposed mechanisms include slow growth, an rpoS-mediated stress response and exclusion of biocides by the matrix.
Data table: Salmonella biofilm density by surface (cfu/cm²)
| Surface | S. Weltevreden | Salmonella FCM 40 |
|---|---|---|
| Plastic | 3.4 × 10⁷ | 1.2 × 10⁷ |
| Cement | 1.57 × 10⁶ | 4.96 × 10⁶ |
| Stainless steel | 3 × 10⁵ | 2.23 × 10⁵ |
Joseph et al. 2001, abstract.
Explanation, details and sources
A biofilm is a community of cells attached to a surface inside a self-made matrix of extracellular polymeric substances (EPS). Biofilm cells are not usually removed by normal cleaning and can contaminate food that touches the surface. USP ⟨2023⟩ flags water systems and wet steps, such as wet granulation, liquid batching and film coating, as the problem areas.
Each method sees a different slice of the population, so laboratories combine them
Text version: why each method is rated as it is
- Plate count: counts only cells that form colonies; spores germinate on the medium; no identity.
- Enrichment culture: nonselective pre-enrichment lets injured cells repair; some VBNC cells resuscitate in rich media; confirmation names only the target organism.
- qPCR on DNA: detects DNA from living, VBNC and dead cells alike; species-specific by primer design.
- PMA–qPCR: PMA penetrates cells with compromised membranes and removes their DNA from analysis, so intact VBNC cells still score; injured cells with damaged membranes may drop out.
- Flow cytometry with live/dead stains: separates intact from damaged membranes, with intermediate states; no species identity without added probes.
- ATP bioluminescence: tracks metabolically active cells and is rapid, but extracellular ATP inflates results, dormant spores are not detected, and it has no specificity.
- MALDI-TOF MS: identifies colonies already grown, if the spectral database contains the species.
- 16S rRNA gene sequencing: identifies DNA from any cell state; resolution below genus varies.
USP–NF 2025, Issue 2, includes chapters on respiration-based ⟨72⟩ and ATP bioluminescence-based ⟨73⟩ methods for detecting contamination in short-life products, with ⟨1071⟩ as the risk-based companion (USP–NF 2025 Issue 2 commentary, February 3, 2025).
Explanation, details and sources
USP ⟨2021⟩ allows alternative methods "provided that they have been properly validated as giving equivalent or better results". DNA methods are fast and specific but also count dead cells. Propidium monoazide (PMA) enters only membrane-damaged cells and blocks their DNA, so PMA–qPCR reports cells with intact membranes. ATP methods miss dormant spores.
Kill steps are designed from D, z and F values measured in the real, dry matrix
Data table: D-values at 65 °C and time for a 5-log reduction
| Organism and matrix | D at 65 °C, min (95% CI) | 5-log time, min |
|---|---|---|
| Salmonella Montevideo, chili pepper, aw 0.97 | 0.72 (0.54–0.90) | 3.6 |
| Salmonella Montevideo, chili pepper, aw 0.50 | 6.78 (5.63–7.92) | 34 |
| Salmonella Montevideo, chili pepper, aw 0.33 | 30.24 (25.72–34.74) | 151 |
| L. monocytogenes, moist food (FDA) | 1.55 (from a 6D time of 9.3 min) | 7.8 |
Data table: measured and modeled D-values, Salmonella Montevideo on dried chili pepper
| aw | Temperature, °C | Measured D, min (95% CI) | Model D, min |
|---|---|---|---|
| 0.33 | 60 | 88.11 (67.86–108.36) | 66 |
| 0.33 | 65 | 36.24 (31.94–40.54) | 33 |
| 0.33 | 70 | 14.91 (13.29–16.52) | 16 |
| 0.50 | 60 | 13.57 (10.80–16.34) | 24 |
| 0.50 | 65 | 7.16 (6.24–8.08) | 12 |
| 0.50 | 70 | 3.78 (3.10–4.46) | 5.8 |
| 0.97 | 55 | 2.22 (1.76–2.67) | 2.8 |
| 0.97 | 60 | 1.05 (0.94–1.16) | 1.4 |
| 0.97 | 65 | 0.50 (0.40–0.59) | 0.68 |
Measured: Table 2 (dynamic conditions). Model parameters: Table 3, dynamic fit, D70 °C = 16.11 min at aw 0.33, zT = 16.25 °C, zaw = 0.38 (reference aw 0.33). The isothermal fit gives D70 °C = 17.61 min, zT = 24.03 °C and zaw = 0.44.
log reduction = F / Dref
Method, assumptions and limits
- What it calculates
- The lethality of a heat step with a linear come-up from 25 °C and an isothermal hold, the log reduction it delivers, the expected survivors and the hold time needed for a target log reduction.
- Equations
- Lethal rate L(T) = 10(T − Tref)/z; F = ∫L dt, with Simpson's rule over the come-up (400 intervals) and L·t over the hold; log reduction = F/Dref; required hold = (target × Dref − Fcome-up)/L(T). For the chili model, Dref is multiplied by 10(0.33 − aw)/0.38. For C. botulinum, z is 7.0 °C below 90 °C and 10 °C at or above it, as in FDA Table A-4.
- Variables and units
- T in °C; times in min; D in min; F in min at Tref (70 °C for Listeria and Salmonella, 90 °C for C. botulinum); counts in log10 cfu/g.
- Assumptions
- First-order (log-linear) inactivation; the product temperature equals the set profile everywhere; water activity stays constant during heating; cooling adds no lethality.
- Valid range
- Source data cover 63–85 °C (Listeria), 85–100 °C (C. botulinum) and 55–70 °C with aw 0.33–0.97 (Salmonella on chili). Outside these ranges the calculator warns that it is extrapolating.
- What it does not establish
- It is not a validated process. Real products have cold spots, tails and shoulders on survival curves, and changing water activity during heating; a kill step must be validated in the actual product and equipment.
- References
- FDA Fish and Fishery Products Hazards and Controls Guidance, Appendix 4, Tables A-3 and A-4; Faliarizao et al. 2025.
- Verification
- An independent Python solution (scipy.integrate.quad) reproduces the readouts and FDA's tabulated values: 6D at 70 °C in 2.0 min and at 63 °C in 17.0 min for Listeria; lethal rate 0.193 and 6D in 51.8 min at 85 °C for C. botulinum.
Explanation, details and sources
The D-value is the time at a set temperature that kills 90% of a population, one log. The z-value is the temperature rise that cuts D tenfold. The F-value adds up the lethality of a whole time–temperature profile as equivalent minutes at a reference temperature.
The design rule follows from the data. Validate a kill step at the water activity the product has while it is heated, and measure the come-up, because lethality that is not recorded cannot be credited.
Irradiation and ethylene oxide are limited by use, dose and residue rules; heat steps by validation
Text version of the treatment comparison
- Steam. Moist heat; the wet surface raises local water activity, which lowers D. Salmonella on chili at 65 °C: D 0.72 min at aw 0.97. Spores need far more heat.
- Dry heat. At aw 0.33 the same Salmonella had D 30 min at 65 °C. USP ⟨2023⟩ notes dry heat "may adversely affect stability and degradation of the raw material".
- Irradiation. 21 CFR 179.26 permits up to 30 kGy for microbial disinfection of dry or dehydrated aromatic vegetable substances "when used as ingredients in small amounts solely for flavoring or aroma" (culinary herbs, seeds, spices, vegetable seasonings and blends; turmeric and paprika also as color additives), and up to 10 kGy for dry enzyme preparations. Retail packages carry the radura logo and "Treated with radiation" or "Treated by irradiation". Gamma irradiation of S. Montevideo in black pepper and sesame gave 3–4 logs at 3 kGy and 5.5–6 logs at 5 kGy.
- Ethylene oxide. EPA tolerances (40 CFR 180.151): 7 ppm ethylene oxide and 940 ppm 2-chloroethanol in dried herbs and spices (except basil), licorice roots, dried peppermint and spearmint tops, sesame seed and dried vegetables. EPA's January 14, 2025 Interim Decision cancels use on specific dried herbs and spices where it is not critical, phases out others where alternatives exist, and notes use on about 30% of dried herbs and spices.
Whether a botanical used in a dietary supplement fits the 179.26 condition "in small amounts solely for flavoring or aroma" is a question for regulatory counsel.
Explanation, details and sources
Each treatment trades kill against product damage and regulatory limits. USP ⟨2023⟩ warns that irradiation and ethylene oxide "may cause unwanted changes" and that crude extracts with alkaloids have lost alkaloid content after ethylene oxide treatment. In the EU, sesame seeds must meet an ethylene oxide limit of 0.05 mg/kg, set at the limit of quantification; a 2020 Indian sesame incident led to withdrawals in member states.
Twelve terms carry most of microbial quality control
Show the 12 key terms
- cfu
- Colony-forming unit: a cell or clump that grows into one colony.
- TAMC and TYMC
- Total aerobic count; total yeast and mold count.
- Specified microorganism
- A named organism that must be absent in a stated mass.
- Method suitability
- Proof that the test recovers spiked organisms from the product.
- Water activity (aw)
- Vapor pressure of a material over that of pure water.
- D-value
- Minutes at one temperature for a tenfold reduction.
- z-value
- Temperature rise that cuts the D-value tenfold.
- F-value
- Lethality of a heat profile, in minutes at a reference temperature.
- Endospore
- Dormant, heat-resistant form of Bacillus and Clostridium.
- Sublethal injury
- Damage a cell survives but must repair before growing on selective media.
- VBNC
- Viable but nonculturable: alive, yet forming no colonies on routine media.
- Biofilm
- Surface-attached cells inside a self-made polymer matrix (EPS).
Six questions test the main ideas
A dried root powder has TAMC 6 × 10⁴ cfu/g and TYMC 5 × 10² cfu/g. Does it meet the USP ⟨2023⟩ recommendation for dried or powdered botanicals?
Yes for both counts: the recommendations are 10⁵ and 10³ cfu/g. It must also show no Salmonella or E. coli in 10 g and bile-tolerant Gram-negative bacteria of no more than 10³ cfu/g.
A lot carries Salmonella evenly at 0.01 cfu/g and tests "absent in 10 g". How likely was that result?
About 90%. The portion is expected to hold 0.1 cell, so the chance it holds one or more is 1 − e−0.1 ≈ 9.5%. Thirty such portions are needed for a 95% chance of detection.
Why does FDA's method test cloves at a 1:1000 dilution?
Cloves inhibit Salmonella in the broth, and FDA knows of no neutralizer for them. Dilution takes the spice below its inhibitory level so that any Salmonella present can grow.
Why is a heat step that works for a wet extract weak for a dry powder?
Low water activity raises the D-value. For Salmonella on chili at 65 °C, D rose from 0.72 min at aw 0.97 to 30 min at aw 0.33, so the same time gives about 40 times less kill.
A qPCR test is positive for Salmonella, but culture is negative. Name two explanations.
The DNA may come from dead cells, which PCR still detects, or from viable but nonculturable cells that culture misses. PMA–qPCR helps separate the two because it excludes cells with damaged membranes.
Does 21 CFR 179.26 allow 30 kGy for any dried botanical ingredient?
No. The 30 kGy use covers dry or dehydrated aromatic vegetable substances "used as ingredients in small amounts solely for flavoring or aroma", with turmeric and paprika also allowed as color additives. Other uses need their own authorization or counsel's review.
Next: how pH and solubility shape what the body absorbs
Course 8 follows a botanical compound from the stomach to the bloodstream.