Hi!
A very good discussion thread!
From my view point I would say it is possible to have no CCP's provided the pre-requisites are strong including the GMP, which is again based after a thorough HACCP assessment. As long the process of the unit is of low risk or the likely occurrence of the hazards being introduced is also low, this is possible...... but it will be required to do a thorough verifications and validations timely.<BR><BR>However in my opinion regarding, the high risk products or processes, a zero CCP is still doubtful, even though CP are in place too. Even if the hazards are less likely to occur and the severity is high, I would surely introduce at least one CCP rather than having zero CCP.
BR,
J
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