FSMA is my area. Therefore I don't understand this statement:
"Is there any evidence for FDA supporting baking not being a CCP within the traditional haccp scheme?"
It is contradictory in view of HARPC, especially the part about "traditional HACCP scheme" and FSMA. Can you perhaps elaborate?
I will attempt to elaborate.
I deduce this implies that FSMA do not agree with suggestions like "output quality failure" can justify that inadequate baking does not present a potential micro.hazard to the consumer.
Prior to FSMA, FDA implemented (traditional) haccp based on Codex/NACMCF. If my above interpretation is accurate and FDA's (then) opinion was unchanged from current, I anticipate that FDA would favour a CCP at the baking step .
But I have not seen any published examples of FDA-authorised baking haccp plans going back to this period. Hence my query in Post 21.
(A random Literature scan of around 10-15 studies indicated the majority showed Baking CCPs. A few [2-4] did show absence, but with no explanation.)