You need to include the following CCPs or at a minimum demonstrate with hazard analysis that there is no significant hazard:
- Receiving (regulatory approval of harvest areas need to be verified)
- Storage (pathogen formation/growth)
- Processing (packing, shucking, possible hazard of glass and metal inclusion, possible hazard of pathogen formation/growth)
- Allergens (hazard should be addressed with shippers cert tag and/or license #)
State and local water sanitation codes must also be applied to practices, as they are more likely to issue warnings and approvals for harvest closures/openings, etc.
You mentioned that you cold-wet store shellfish. Is this a depuration process or simply storage? If depuration, is the water managed with aquaculture drugs? Nevertheless, water quality will have to be validated, verified, and monitored frequently.
As a shellfish processor I would recommend that you become very intimate with the following documents:
The whole shebang:
FDA Hazards Guidance 4th edition.pdf 4.74MB
NSSP 2013 Final September 28 2014_3.pdf 8.83MB
Chapter 4 Pathogens From the Harvest Area.pdf 2.12MB
Chapter 6 Natural Toxins.pdf 1.98MB
Chapter 9 Environmental Chemical Contaminants and Pesticides.pdf 2.03MB
Appendix 3 Critical Control Point Decision Tree.pdf 1.94MB
An indispensable source for shellfish processors:
Interstate Shellfish Sanitation Conferance
Here are some old examples of shellfish HACCP I did pre 2011. I'm missing a CCP addressing both allergens and processing, but I can't keep everything archived...
It's been a few years since I have had to work with molluscan stock, but hopefully this will help you in the right direction.