We produce haggis which is cooked to 84 degrees C for 65 minutes now, to comply with vac pack guidance. We're currently looking at increasing the salt levels in the aqueous phase as the vac pack control to allow us to reduce the cooking time/temp combination as we would like to reduce energy costs. we produce our haggis in an area we consider raw and we sell it as raw, with clear cooking instructions and the additional warning statement of 'This Product Must Be Cooked Prior to Consumption'; as a result we do not consider it to be a CCP with our control measure being that the product undergoes a final cook by the consumer. We have operated this way for several years and have been audited by FSA, FSS, BRC and numerous retailers and this has never been raised as an issue however we recently had an FSS audit carried out by a new auditor and he is insisting that the control is unacceptable because we can't rely on the customer to cook it properly and we need to consider it a CCP.
We would prefer not to because of the raw area the haggis is produced in - please can someone advise on what they think and if there is another control/validation we can use to justify why it isn't a CCP?
Any help much appreciated.