Charles,
Thank you for your comments. I throw my hat into the ring with the following in bold.
Dear MarkH,
Thank you for yr attachment. It's a thoughtful and useful document.
A few items seemed rather odd to me,eg -
Quote
the program will enhance the safety, wholesomeness, economic integrity, and quality of food products
The HACCP Program as presented focuses on safety ? But perhaps it depends on the scope of "enhance". 
I plead guilty by reason of consensus. "We" implies multiple inputs, POV and bias. Those of us with a bias towards simplicity and focus (Food Safety and Defense) were "influenced" by the minority that considered flowery phrases to be of great importance. Rank does indeed have it's priveledges. And one should not fight battles they can not win. So the propaganda remained.
(1) AFAI could see, there is no mention of some rather fundamental haccp terms, eg risk.
We are "package in package" distributor and other than defining a few temp controls CCPs, believe that PinP was a suffcient defense. Seems the FDA and SQFI agree.
(2) The acceptable (critical limit) maximum temperature for frozen (I presume hard-frozen) goods reception / storage freezer of 20degF (-6.67degC) seems out-of-line. Validation ?
Touche! The final determination of 20dF was made at a level much higher in the Food Chain than I. Not sure why 0 to 31dF would not work as well, but it is what it is.
(3) No mention of corrective actions other than their reporting. Maybe elaborated elsewhere.
To an extent. We maintian that HACCP, along with GDP/GMPs are foundational to our SQF program. To this end, the focus is on the higher level SQF program. C/As are addressed as related to the program most relevant and addressed in that context. Fortunately we discovered a software suite that allows us to capture, assign responsibility for and track to completion all C/As from cradle to grave. This was tested greatly in our recent audit.
(4) IMO, the haccp plan should additionally be reviewed by the person designated as responsible for the Plan. This appears to be the HACCP Coordinator.
Again, as in (3), ultimate responsibility for review/revision/validation of the HACCP program resides with the resident SQF Practitioner(s). While annually the HACCP team is involved in the review, SQF is seen as the final authority.
(5) No requirement of a designated SQF Practitioner ? 
As above, the HACCP program is a component in our enterprise. If I were not concerned about SQF certification, I would incorporate all of what you suggest into the program.
Regardless, thanks for the sample.
Charles, thank you! I have come to appreciate many of the wise ones on this forum and have learned much about this subject in a global context. It is one thing to attend training and then return to that slice of heaven we call home. Quite another to engage in intelligent conversation with our professionals. Again, thank you.
Rgds / Charles.C
Best regards,
Mark H
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