Hi Andy,
I wouldn't consider labeling a CCP, just a production check. It can't influence the safety of the product per se, but it can mis-identify it. As for the sealing process: how do you test that the seal is good? We produce bag-in-box, so we just put a 20kg weight on bags to test the seal. That's not possible with bottles.
Test each step against the standard decision tree. Is it the last opportunity to reduce that particular hazard (CCP) or does another step do the job just as well (Control Point)? Also be aware that you need to put in some form of control measurement for it to be a CCP, Below is a HACCP chart from a bottling plant.
STEP NO.
PROCESS STEP
STATUS
CRITICAL LIMIT
MONITORING PROCEDURE
CORRECTIVE ACTION
RECORD
RESP
8.
11
Pasteurise
Fill Bottles
CCP3
CCP3
Minimum temp 83.9oC.
Minimum filler temperature 80C
Record temperature every 15 minutes
Record temperature every 15 minutes
Will automatically recirculate water until temperature rises.
Inform Technical if temperature drops.
Pasteuriser log sheet
Pasteuriser log sheet
Filler Operator
Filler Operator
.
STEP NO.
PROCESS STEP
STATUS
CRITICAL LIMIT
MONITORING PROCEDURE
CORRECTIVE ACTION
RECORD
RESP
15.
Bottle Rinse
QCP
Water jets reach bottom of bottle
Visual check
Stop line and hold product back to last good check
Pasteruriser sheet
Filler Operator
11.
Fill Bottles
QCP
Brix as per the finished product information sheet
Start and hourly throughout run
Segregate product and investigate reason
Finished product sheet
Operator
18.
Cap bottles
QCP
Secure cap.
Check at Start and hourly throughout run
Stop and correct machine. Test previously packed product.
Finished product sheet
Operator
20.
Apply code to bottle
QCP
Visual Checks
Check at Start and hourly throughout run
Stop line, correct fault quarantine product
Finished product sheet.
Operator
25.
Apply labels
QCP
Visual Checks
Check at Start and End of Run
Stop line, correct fault, quarantine product
Finished product sheet.
Operator
27.
Apply code to outer labels
CP
Visual Checks
Check at Start and End of Run
Stop line, quarantine product
Finished product sheet.
Operator