Oh boy, I think this would be a huge mistake.
From a HACCP point of view I can't imagine that you couldn't conclude that this hazard isn't reasonably controlled through the use of employee sanitation/GMP training (with re-training timing specified in a written food safety management policy), proper signage (appropriate sign placement in your prep area and in language that all employees can read), a documented Environmental Monitoring Program (doesn't need to be too fancy; perhaps an inexpensive ATP meter or quick indicator coliform test kits), etc.
If you make this a CCP how will you establish you critical limits and monitor that activity effectively? I'm not or never have been in the catering or restaurant business but in my world CCPs are very serious and need to follow the 7 HACCP principals to the letter (or at least darn close to it).