Dry food operations are difficult to manage. They are called dry operations not only because the finished product may indeed be dry, but also because the individual ingredients must be kept dry. From a regulatory standpoint, the FDA defines low-moisture foods as those with a water activity (aw) of 0.85 or below. Water activity, not moisture content alone, determines the microbial risk profile of a dry food. Salmonella and Cronobacter can survive in low-water-activity environments for extended periods, which is why even very dry environments still require a rigorous HACCP-based approach.
Moisture creates a greater risk for the pathogens Salmonella and Cronobacter in the environment and in the food. Both are identified by the FDA as the primary environmental pathogens of concern in low-moisture processing environments, and both must be considered in any HACCP or food safety plan hazard analysis for dry food operations. It may be more uncommon for salmonella contamination to occur in dry operations, but it can affect huge amounts of consumers. This is an important reason a HACCP plan for dry food operations is needed, so biological hazards do not contaminate your products. FoodReady has HACCP plan templates you can customize for your business, including chocolate HACCP templates and dry processing templates.
Dry Storage Is an Important Step in a HACCP Plan
Dry operations largely involve dry ingredients such as: powders, spices, gums, thickeners, vitamin and mineral blends, flour, salt, and sugar. All food companies need to have dry storage for their dry ingredients and is an important step in your HACCP plan. For every dry ingredient purchased by a food facility, there is a food company making that dry ingredient.
Cleaning and sanitizing in dry operations is necessary, difficult and part of every HACCP plan because most dry operation production does not stop. If the equipment can keep running, the company keeps it running! Most dry-ingredient manufacturers do business on a small profit margin, and so they cannot afford to shut down. If the processing equipment shuts down for cleaning, it can be a big deal and may take days or a week to make repairs, clean, clear the lines, sanitize, completely dry, and then start back up. On top of that usually a large percent of the first product out needs to be disposed of in case a pathogen in the lines was cleared at startup. The expense is huge.
In Some Operations, There Are Pieces of Equipment That Are Never Cleaned
In some operations, there are pieces of equipment that are never cleaned. What happens is, it is just impossible during a normal shutdown to take apart and open and clean some machinery. If a recall were to occur, that would mean there was never a clean break. FDA asks companies when the last clean break occurred. When a company has a clean break they also have evidence that will shorten the span of a recall back to when the clean break occurred. An example of machinery that is never cleaned are chocolate holding tanks. This is standard practice throughout industry.
It is also important to note that material flush techniques, which involve pushing product or hot oil through food-contact surfaces to clear them, are not effective at killing pathogens. The FDA’s guidance on low-moisture ready-to-eat foods makes clear that cleaning and sanitizing must be performed sequentially, and that flushing alone cannot be relied upon to eliminate a pathogen contamination event.
Struggling With Sanitation in Dry Operations?
Even if some equipment can’t be cleaned, we’ll show you how to document preventive controls and limit recall scope.
How do you handle a recall when some of your equipment is never cleaned? Must the company recall all products in the market with that specific chocolate?
Without a clean break in production, how do you determine how far back to go for a recall?
One method is to stop production, call in a consultant to investigate, and collect hundreds of swabs to determine the root cause and source of contamination. This takes a tremendous amount of time, and in the meantime you must inform the public of the recall to protect them.
Schedule an Annual Shutdown for Cleaning and Repairs
Scheduling a complete annual shutdown for deep cleaning, equipment disassembly, and thorough sanitizing is not only sound practice from a business continuity standpoint but is consistent with FDA guidance on low-moisture ready-to-eat food production. The FDA’s 2025 draft guidance for LMRTE foods recommends that facilities establish and document routine sanitation breaks as part of a formal sanitation program. Importantly, the timing and completeness of your last documented sanitation break can directly determine the scope of a recall if a contamination event occurs. This is enormously expensive, but if you compare the cost of a recall you will find it’s worth doing, and also you are protecting your brand reputation and your customers.
So, do you need a HACCP plan for dry food operations? Yes. The biological, chemical, and physical hazards present in dry food environments are real and documented. The sanitation challenges are significant. The recall consequences of getting it wrong are severe. A well-structured HACCP plan specific to your dry processing environment, supported by a formal sanitation program, documented clean breaks, and regular environmental monitoring for Salmonella and Cronobacter, is your strongest defense. FoodReady offers HACCP plan templates and consulting support tailored to dry food operations, including chocolate, spices, powders, and more.
The FDA’s 2025 LMRTE Draft Guidance: What Dry Food Manufacturers Need to Know
In January 2025, the FDA published a long-awaited draft guidance specifically targeting manufacturers and processors of low-moisture ready-to-eat (LMRTE) human foods: “Establishing Sanitation Programs for Low-Moisture Ready-to-Eat Human Foods and Taking Corrective Actions Following a Pathogen Contamination Event.” This guidance is directly relevant to any facility producing dry food products, including chocolate, peanut and nut butters, powdered spices, powdered drink mixes, granola, dry cereal, crackers, processed tree nuts, milk powders, and powdered infant formula.
The guidance formalizes FDA’s expectations in four key areas that align closely with the practical realities of dry food operations described in this article.
Controlling water in dry production environments. The guidance reinforces what experienced dry food operators already know: the introduction of moisture into a dry production environment dramatically increases pathogen risk. The FDA recommends strict controls on water activity throughout the facility, including segregation of wet and dry processing zones and robust maintenance of equipment to prevent condensation or moisture ingress.
Routine sanitation breaks. The guidance recommends that facilities establish and document scheduled sanitation breaks as part of a formal sanitation program. Critically, it connects the timing of documented sanitation breaks directly to the scope of any potential recall. If a contamination event occurs, the FDA considers the last fully documented sanitation break as a key reference point for identifying potentially affected products. This gives formal regulatory weight to the industry best practice of annual or periodic deep-cleaning shutdowns discussed earlier in this article.
Material flush techniques are not sufficient. The guidance specifically cautions that flushing equipment with product or oil rather than conducting a full clean and sanitize is not an effective pathogen control. Facilities that rely on flushing as their primary sanitation method for inaccessible equipment should review this approach in light of the guidance and document their rationale carefully.
Environmental monitoring for Salmonella and Cronobacter. The guidance recommends routine environmental monitoring programs targeting Salmonella and Cronobacter as the primary environmental pathogens of concern in LMRTE production environments. It also distinguishes between transient strains (pathogens found sporadically and removed through routine cleaning) and resident strains (pathogens that have established themselves in equipment or facility infrastructure). The presence of a resident strain is treated as a much more serious event requiring full remediation and root cause investigation.
As of mid-2025, this guidance was still in draft form following an extended public comment period. However, it represents FDA’s documented current thinking on sanitation expectations for dry food operations and should be reviewed by any HACCP team operating in this category.
FAQs
Some foods can be safely preserved by drying or dehydrating them. Fruits such as raisins, apricots, and plums can all be dried for preservation.
Air drying, sun drying, heat pump drying, microwave drying, fluidized bed drying, and cabinet style dryers are some of the ways food processors dry food to preserve it.
The process of blending dry materials together.
The FDA identifies Salmonella and Cronobacter as the two primary environmental pathogens of concern in low-moisture food production environments. Both can survive in low-water-activity conditions for extended periods and must be addressed in any hazard analysis for dry food operations.
A clean break is a documented, fully completed cleaning and sanitizing event for your production equipment. If a contamination event occurs, the FDA uses your last verified clean break as the starting reference point for determining how far back a recall must extend. Facilities without documented clean breaks have no boundary to limit recall scope.
