HACCP plan I have inherited needs updating for CCPs.
We are a whole grain flour mill. No metal detection at this time. Current HACCP plan has CCPs- labeling for allergens, and Hand washing for the introduction of more pathogens (since pathogens are inherent in raw material and our product which has not been subjected to a kill step). I want to remove hand washing as it is in our GMPs and kill step is passed on to customer via warning.
Needing a CCP at the last possible point I have decided to skip our rare earth magnets as a CCP and focus on the sifter screens which come after magnets in process/flow. We have implemented pre-operational check of sifter screens (screens, sifter basin and bolt count) at the beginning of every shift, every production run and after every 2,000 lbs of grain milled during large runs.
I know that metal detection is the way to go, but since we do not have this in place would the sifter screens be a legitimate CCP with the pre-op checks and mid run checks?
I have put our rare earth magnets on the pre-op check and daily or post shift cleaning schedule. However I have not considered listing this as a CCP since it is upstream from sifter screens.
Any suggestion on how to make this work and if this can be a trusted CCP is greatly appreciated.