In the case that food is cooked, blast chilled and reheated, would cooking even be a CCP? Based on the fact that a later step will eliminate the hazard - that being the reheat step to 75°C? Could it be arued then that cooking and blast chilling are just control points?
I will attempt yr original post and latest variation.
You may need to define yr examples more precisely. I have selected one typical textbook situation below.
AFAIK, “reheating” is often routinely used under conditions where the risk assessment implies it is a necessary control measure, ie for a significant hazard. For example –
This operational step applies only to those foods that you listed in Process #3. If food is held at improper temperatures for enough time, pathogens have the opportunity to multiply to dangerous numbers. Proper reheating provides an important control for eliminating some of these organisms. Remember that although proper reheating will kill most organisms of concern, it will not eliminate toxins such as those produced by Staphylococcus aureus and Bacillus cereus or foodborne viruses.
Special consideration should be given to the time and temperature in the reheating of cooked foods.To control biological hazards, it is recommended that reheating be managed either as a CCP in your HACCP plans or as a prerequisite program and be based upon the same level of safety established by the critical limits in the Food Code
reh1 - haccp manual foodservice.pdf 555.5KB
(note that use of a prerequisite is not ruled out)(other sources will differ on the crit.limits mentioned)
Any potential negative risk in the reheat step itself depends on the specific operational parameters, eg product time in the danger zone. I guess this is accommodated within the context of the critical limits (if a CCP).
Regarding 2 CCPs, I think this is a question of “convention”. The occurrence of a CCP both for the cooking step and reheat can be “viewed” in terms of the potential product utilisation, eg 2 processes combined into one. For example see the text (Pg4) in this attachment, –
reh 2 - haccp in school foodservice.pdf 1.36MB
AFAIK, England does not have any legal limits for reheating so Scotland is "one-up". Bit like Tennis ?
Rgds / Charles.C