Heat treated flour and cookie dough

Hello,

I was reading through an old forum from 2014 to answer my question, but with FSMA going into effect I wanted to create a new post. We produce raw cookie dough that we sell to third party companies, and they in turn bake it or sell it on. The ones that sell it on worry me because they sell to customers who may want to eat the dough raw. According to FSMA, it is known that cookie dough is eaten raw, so technically I would say they expect it to be ready to eat. But even if I put into place the best supplier verification program, and even if I test every single lot of cookie dough for pathogens before I release it, I am never 100% guaranteeing that there isn't anything in that dough because the flour we use is not heat treated. We tried looking for vendors who sell heat treated flour and it is not as common of a thing as I thought it would be, given the new regulations. 

Does anyone else manufacture raw dough? Do you use heat treated flour? If not, how do you justify it in your HACCP plan?  

Thank you!

I have industry colleagues who work for a company which manufactures batter, dough, etc.  As far as I know, they do not use heat treated flour, but have a hold & release policy on micro testing, which is completed per batch.

Apart from getting written documentation and/or records from who you sell to, there isn't too much else you can do as far as proof.  Having the proper handling instructions on the packaging material, which clearly state the product should be baked prior to consumption can definitely assist come audit time, but as far as I know, it cannot be considered a "catch all".  Perhaps having the distributors you sell to provide you written documentation that they inform those they sell to of the hazards associated with the product could be of assistance.