Sorry Charles the internal baking temperature that is set up now for the CCP is 140 Degrees Fahrenheit. This standard was set up long before I was here and I am questioning it as a CCP.
Dear jwatford,
Thks for the clarification.
A product core temperature of 140degF is about 60degC
Baking not my process area so I am treading slightly cautiously. 
From a purely baking POV, 140degF seems quite low in comparison to most of the core temperature values I’ve seen mentioned in other threads here. A temperature below this may well not readily achieve the typical requirements for pathogen elimination (eg 6D reduction) unless the process time is very long.This micro. characteristic would support classification as a CCP unless accompanied by a simultaneous, quality auto-rejection event.
For comparison, the haccp plan I extracted from earlier has a baking step of 140degC / 55min so as to achieve a critical core temperature of (minimum) 72degC (approx 162degF). (my chart for a 6D destruction of L.mono. starts at core temperature of 63degC for 17min. [However if yr haccp anaysis is based on Salmonella as a target pathogen the corresponding time will be shortened]).
It would be interesting to know how a core temperature of 60degC was validated as yr critical limit if baking is set as a CCP and for what time of baking. 
Rgds / Charles.C
PS - (Added later)
As far as (haccp) raw material risk is concerned, although it's subjective, you may have to consider the concept that some ingredients are automatically considered (from general experience) to be a potential source of certain pathogens, eg Salmonella, L.mono,.This is regardless of COAs etc.
Similarly to Dunkleyt’s comments, it seems to me you need more info. on yr process regarding (a) yr current capability for target pathogen reduction, (b) the specific ability to quality-reject product which has failed to reach a core temp. of 140degF ,(c) the relative micro. implications of (b).
I suspect the “conservative” option of nominating baking a CCP is likely to be the less argumentative route as far as auditors are concerned but you need to validate yr critical limits.
I also suggest you have a look at this thread which addresses some related micro. problems –
http://www.ifsqn.com...ion/#entry58612
Edited by Charles.C, 07 September 2013 - 01:28 PM.
added PS