We handle fresh citrus out of Florida and are audited by Primus annually. For more than a decade the fact that our drencher (first step after fruit arrival) was not a CCP consideration or talking point with them, but this past year, I lost points because it wasn't and because I refused to make it one. I'm hoping it was just that auditor and not a new wholesale "we know better than you do" logic by them (He stated that he had been told by Primus that ALL recirculated water systems were to be considered CCPs). After that, I wrote a separate deep-dive five page HACCP-based justification on why it isn't to try and better protect myself from future auditors. Using the Codex Alimentarius logic, the crux of the analysis is below (if it helps you out). And for the record, I have very strong direct science for my industry, location, products and activities, so this is all based on them:
Question 1: Do control preventive measure(s) exist?
Yes, the company employs a sanitizer (PAA) to the recirculated water prior to its application to prevent cross-contamination. Based upon the Yes answer, move to Question 2.
Question 2: Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?
No. The purpose of this step is apply a fungicide to the fruit. It is not intended to reduce or eliminate the possibility of biological contaminants on the citrus fruit. Based upon the No answer, move to Question 3.
Question 3: Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable levels?
Yes. Should the PAA sanitizer application fail, it is possible that cross contamination of the fruit could occur, leading to elevated levels of biological contaminates. Based upon the Yes answer, move to Question 4.
Question 4: Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level?
Yes. There are multiple steps (identified below) that occur later in the process steps within the packing house that been scientifically proven to reduce the possibility of biological risk (pathogens) to an acceptable level.
Anyway maybe this will help you a little somehow....