I take it that you mean "ready-to-use coated paper cups". Personally, I would like to think that this would fall under BRC-IOP category as it does fulfill the meaning of packaging but on a ready to use basis.
From a risk assessment point of view, I see a remote possibility of a physical hazard risk occuring but perhaps bacteria from poor handling or cross contamination opportunities while chemical hazard is another possibility from non-food grade coatings.
From the viewpoint of an effective GMP in placed and a sound suppliers' assurance program, IMO, the HACCP Plan should really have no CCPs at all.
* I am about to start a HACCP Program on the production of "cologne-infused paper towels" and I am just beginning to wonder if the cologne is a factor that I should consider seriously as a chemical hazard or place on the label "Not Meant For Consumption" 
or "Do Not Insert Into Mouth" 
What do you guys think?
Thank you for your information related with my question. Can I learn the complete name of IMO.
Regarding to your question, from my point of view, Chemical hazard can be risk why? You know Alchol should be Ethyl Alcohol, if instead of ethyl alchol, methyl alcohol can be used, it will cause vital effect on human. Of course producer will assure to use Ethyl alcohol, but it can be sabotage that can be done workers ( who knows ) so it is good approach to write warnings as you indicated, it can be preventive action at consumer point for this probability also. On the other hand dosage of ethyl alcohol can be important to monitor for possible chemical risk. Effects of excess amount of dosage on infused paper towels should be evaluated.
