Your product is frozen pastries. From what i understand in those two words, i will assume :
- that the product is quite dry. What is the water activity of your product ? is it below or above the minimal aw for bacterial growing ?
Typically, on pastries, you will find funghi growth, not bacteria.
- that the product is stored and maintained at -18°C. What is the risk that the product comes to a temperature that allow bacterial growth ?
If the temperature is correctly monitored, you maybe will have a product at -15°C, when alarms will warn you that there is a problem. But you still have time to react. This step is not strictly a CCP, because there is no chance that the risk will grow enough to cause illness.
However, you probably have a legal requirement, so you need to respect this temperature and prove it. You will thus follow same rules as a CCP.