I guess this is an extended query to this thread/process -
I'm not in USA or packaging so am unclear for whom this haccp plan is intended ? Is this for (a) a regulatory requirement, eg for USFDA (or ?) or (b) a private standard like FSSC22000 ? The answer usually defines the scope of yr responsibilities as related to yr specific process.
For (a) other US posters here, including yourself, will undoubtedly know more than myself (ie > zero ). (The precise US Packaging regulatory situation may have been discussed previously on this forum, i don't remember, sorry).
For (b) there is likely some direct info. in this forum but depending on the process / standard.
Perhaps you can clarify the situation a little more. Or anybody else in USA of course.
Rgds / Charles.C