I agree. I think it's something which is poorly covered in some
HACCP plans, however, it should be something you think about. I'm now thinking back to whether I talked about acrylamides in a wafer process... Hmm. Probably not but I should have.
I suppose the reason why is that chronic health effects are easier to establish in a health and safety issue (e.g. WRULD) because it's easy to establish what the person has been doing over a long time period; however, ask someone what they ate last week and they'd struggle to remember. So I suppose I'm implying the risks of getting caught are minimal unless the agent likely to cause the chronic effect is detected in your product.
Interestingly some recent health scares / recalls are around agents which would cause a chronic effect (if any effect at all, some are hotly debated) but certainly not an acute reaction. What I'm thinking of are; Sudan dyes, BSE / CJD, GM foods or food irradiation. I've certainly considered Sudan dyes in a
HACCP plan before and suggested to an auditor that they consider the risks of GM ingredients when auditing a chocolate supplier because of the lecithin.