Our Company uses several vertical form, fill, seal machines (VFFS) to package various items from ground kit kats to Pecans. Our HACCP plan has the sanitation step as a CCP to prevent allergen cross contact on food contact surfaces, machines, etc. This is a wet cleaning, performed out of place in sanitation bays.
My question is, should we include the dry cleaning process on our VFFS baggers as a CCP to prevent cross contact? Just the machines themselves; jaws, sealer, pull belts, film rollers, etc.