I disagree with acrylamide being a CCP. Acrylamide has probably always been a by-product of sugar heating, but wasn't observed until the early 2000s. It also would only be toxic/carcinogenic if present in high levels of food over a long period of time.
Acrylamide is a naturally occuring by-product of highly heating products that contain sugars. Acrylamide is a chemical of concern for Prop 65, and products should be labeled with the warning statement if not meeting requirements for Prop 65.
The US FDA does not assign any maximum limits for acrylamide concentration in foods, nor have they assigned an action level for acrylamide content.
I do believe this should be listed in the HACCP plan as part of the hazard analysis for chemical hazards, and actions you take for reduction of acrylamide (perhaps adding in a processing aid to limit acrylamide production, cooking at lower temperatures, and/or product labeling) should be listed.
Please be sure that you have done your testing and know the acrylamide content of your products, and have done all due diligence to ensure the products meet compliance to Prop 65 regulations. Labeling is probably going to be the most critical compliance measure you can take, as it is could be hard to prove your compliance unless you have done significant work to ensure your products satisfy Prop 65 regulations.
QAGB
