It is possible and not just in food retail. Its common in fresh produce where the produce is not being processed but just brought in, stored and packed before going out. We have no CCPs and the BRC auditor was very impressed with our HACCP.
Thks for the input. The conclusion might have been different if yr haccp scope extended to a pre-farmgate scenario. I also deduce that yr input may have been somewhat post-farmgate "processed" prior to yr own reception. ( "packed" can have variable interpretations IMEX).
i wonder if the auditorial satisfaction may also be related to history ?
Afaik, the UK fresh produce industry has so far not been touched by any of the various major troubles reported elsewhere, notably pathogenic E.coli/USA. Whether due to luck or some genuine FS control differences i am unaware. (I recall seeing a comparative (US/GB) article on this happy (GB-wise) distinction a few years back which suggested the latter cause but i forget the explanations given).