Our HACCP plan currently contains zero CCPs. We are an RTE food processing facility with all components able to be stored at ambient temperature. There is a toasting of our product but that is simply for aesthetics as the raw ingredient(s) that are toasted could easily be put into the finished product without any issue to the consumer; it will just look a little bit different.
According to our Ops Mgr, we control all of the control points after they occur to the point that none of them fall into the "critical" category; to my knowledge, this is based on the risk analysis matrix rather than the decision tree although we do have both as reference documents in our HACCP program.
I am just starting my third week here, though, and ended up identifying an issue today that I would appreciate any feedback on. We use several nut butters, including peanut butter, for our product. Our batching operators add the ingredients based on recipes but there is no second check that the batch operator used almond butter instead of peanut butter. I am thinking from an allergen standpoint; if we use PB instead of another nut butter and it goes into a product labeled as free from peanuts although processed in a facility with peanuts, couldn't that be an issue?
I am thinking this is another support to my argument FOR the use of bar coding as the ingredients used would be captured in real time and we could conceivably even use the software as a double check. If they scan a peanut butter container and it's not in the recipe, the software would return an error message and not let them continue. Heck, that could be a double check for the integrity of ALL recipes. My ops mgr came up with a far simpler idea of getting neon colored stickers to affix to the containers of allergen-containing raw ingredients during the receiving process which I also think is a good idea.
Both the neon sticker and bar coding ideas were nixed by upper management.
Would anyone else out there consider this a CCP? I am so new to this that my head is automatically jumping to CCP but maybe I'm being an alarmist?
P.S. The fact that this thread still exists from 2004 is AWESOME!