HACCP for small lab batches

Hi All -

I need some help with HACCP for small batch production.

We currently fill extracts into gallon jugs through a single piston filler with a filter as a CP, this process is risk assessed in our HACCP manual.

One of our customers orders between 1 and 10 gallons at a time, and manufacturing does not want to set up and use the equipment/process described in the flow chart and risk assessment because it is not cost effective. Our plant manager is insisting that R&D mixes the bulk for the small orders themselves using lab equipment and hand fills it into the gallon jugs. There would be no filter/CP.

How do I incorporate this into our HACCP manual and make it an ‘official process’? Add a new process risk assessment and flow chart?

Thanks in advance, any input would be greatly appreciated!

Can you pour it into the gallon jugs with a sieve in between?  Make some sort of jug holding apparatus that has a sieve above the jug and maybe a transfer container that you pour it into the container, it goes through the sieve, and then into the jug?  That will at least replicate the CP.  On the flow chart you could just put another line off the filler and put your process on there.

Then they would check the sieve as a CP and having a cleaning procedure for the apparatus...

Idk just a thought.

Yeah, I would go ahead and describe the product and the end user and do a flow chart and the whole hazard assessment deal since it is a "change to a process or product".