Hi Taryn,
What type of HACCP decisional tree are you using?
The way I like to think about eat hazard when completing a HACCP analysis is as follows - what is the risk (ie. pesticide residues on the peas), where is the hazard from / how did it occur (ie. pesticides used during cultivation leading to excess residues on the product), what is the frequency of this hazard (ie. all peas contain pesticides, 1 batch per month, etc ...) and what is the gravity of the hazard on the consumer (ie. pesticides exceeding regulated limit can cause adverse health effects and even death). Using this information, you can better complete a HACCP analysis as is allows you to determine if your PRP will completely control a hazard or if more control is necessary.
In your examples (pesticides, heavy metals, and lubricant contamination) these are hazards which arise from improper supplier handling or practices. I see this being controlled by the following PRPs / procedures:
1) Supplier approval program - using suppliers who have been approved based on their own GFSI certification, self-assessments and onsite audis. You would also request certificate of analysis to confirm absence of pesticides and heavy metals.
2) Receiving PRP
3) Inspection / Analysis conducted by the receiver (ie pesticide testing, heavy metal testing, etc.)
IMO I would not consider this a CCP since your PRP should be more than sufficient to control these hazards so long as they are efficient.
Hope this helps, best of luck!