I am performing a review of a HACCP plan that is currently under a "fully-cooked, not shelf stable" category on our USDA GOI.
The previous team at this facility determined that temperature would be a valid CCP for our process to control the growth of S. aureus. We currently receive fully cooked, cured and uncured/naturally cured bacon bits from suppliers in bulk packaging (5-10lbs. bags), and fill them into smaller portion controlled packaging for use in a condiment kit for a salad.
We currently receive COAs from one supplier stating that their water activity is <0.8500 which is the benchmark for shelf-stability for the USDA from my understanding. However, there is a second supplier that provides different SKUs we use (cured and uncured) which has a spec that states their water activity will be <0.9000. They have sent me some justification they have in regards to how this product can still be considered shelf-stable via their processes. They are also a USDA inspected facility.
Can I still use their justification to help in the removal of our current CCP for temperature given the product is essentially "shelf-stable"? We do have our SSOPs, GMPs, and PEM Programs as pre-requisites.
Any help/feedback that could be provided would be appreciated. I can attach the plan in a future post if needed.
Thanks in advance to everyone!