My company is primarily a distribution facility for spices, herbs, and oleoresins. We already have all our SQF (FSC 26) documentation ready for Modules 2 and 12. We have a HACCP program established and implemented for this operation, and we have identified no CCPs for our distribution operation since we receive all our products pre-sterilized with COAs, etc., and they are shipped as they come in. Our distribution is of bulk bags usually in 50lbs.
We recently acquired a hand-packing license, and we now need to develop a HACCP plan for this new process (and I think as far as SQF goes, this would add FSC 19 to our categories, and module 11). The hand-packaging is only to repack single ingredients (no blending/mixing) into smaller bottles of varying sizes. We do these by hand, however, as our license would suggest, so no machinery is involved (so no threat of metal/foreign contamination)
Our process flow for the hand-packing would be in general as follows:
Receiving --> Storage -->Visual inspection --> Hand Packaging/Bottling --> Heat Seal-->Boxing --> Palletizing -->Shrink wrap --> Shipment
I'm a little confused as to whether we'll have a CCP, because the only step where any hazards can be a potential would be when the spice is exposed during the transfer from the original bag into the bottle. However, we have SOPs/Prerequisite programs in place to ensure food safety. For example, we have:
1) Strict hand-washing procedures
2) Glove use policy (i.e. Employee hygiene practices)
3) Scoops and utensils policies-including cleaning and sanitizing before and after each different product
4) Cleaning and sanitation SOPs--these include cleaning and sanitizing the workbench that would be a food contact surface. We also have contracted an industry service that have installed the dispensers that automatically dilute the chemicals for the required limits, etc.
5) We're also getting ATP swab test kits for environmental cleanliness to swab food contact surfaces for cleanliness before each use.
So my question then is if we have all these Prerequisite programs and SOPs in place, do we then have a CCP at the Hand Packaging/Bottling step (or anywhere else)?
My hunch is no, but I'm not sure. If it is a CCP, would the ATP swabbing of food contact surfaces be our control, or would testing of the product be our control?
Thanks for your help, community!