Very interesting topic.
I was combating with me since last month on this same topic. We were going to establish new food product facility and while I was analyzing hazards, i found zero CCP in process. But deeply I thought about the system without CCPs is not looks nice or professional. When I present my study results to my superior, he asked to put at least a CCP in process. I argued with him that there is no mandatory requirement to insert CCP to the process if we analyse it professionally.
What ever, I learned following things through above incident. Please leave your comments and I need to improve my knowledge.
1. When we have 1 or 2 processing steps, probably it is zero CCP process.
2. If we do not change the temperature of product or do not treat them to change their microbiological and chemical quality, same as above.