Is it common to find no CCP's?

Since if something is covered in your SOP’s, it doesn’t necessarily need to be a CCP, it seems as though it could be common to have no CCP’s for a product?

Take for instance a dry cookie dough mix that we make. Say that in our SOP’s I cover the following: for ingredients received we’ll inspect them, keep temperature logs, require certificate of analysis from supplier. For ingredient storage, they will be stored in appropriate conditions and used within the proper amount of time. All of our production equipment is cleaned regularly with logs kept and it’s in our SOP’s that all products are checked with a metal detector before packaged and shipped. And that they’re all stored at appropriate temps with temperature logs kept. etc, etc, etc. 

So, if all of those things are addressed in our standard SOP’s, I couldn’t really think of any CCP’s during the process. Is that common? I can’t decide if an auditor looks at it if they would think it looked very wrong because there were no CCP’s or if I showed them our SOP’s, they would actually think it was great and that we were very thorough.

Thanks for any insight!

I've heard from several auditors that it is not uncommon for a facility to have no CCPs at all. As long as proper steps are taken to avoid any issues, they were just happy to see those documented. At my facility, we have one CCP and the auditor actually helped us to be able to remove this one by publishing a separate document to do away with it.

A careful, thoughtful and thorough hazard analysis will reveal whether or not a critical control point is needed.  When we first walked down that path, we hired a consulting firm to guide us and facilitate the development of our HACCP plan.  We determined that a CCP was not required.  Nevertheless I asked that one be developed to give the HACCP program a sense of realism and urgency.  That has proved to be very helpful in raising awareness and focus on food safety issues.  Our system has been audited many times since then.  Auditors come away with the same take - not really necessary, but a good idea.

Good luck!

Hi Timbeau,

I seem to remember seeing reports that there have been several incidents of people/chefs  (strangely) eating raw cookie dough mix and encountering Salmonella.

Theoretically this may not criticise the mix since presumably not claimed to be RTE however it does suggest that (a) some mixes are adulterated, (b) it may be necessary to demonstrate that Salmonella is consistently absent in view of illogical, but undeniable, consumer habits.

i did wonder where the Salmonella was originating from. And how such a likely (?) hazard was handled in a haccp plan.