I have been running our HACCP in a food storage/distribution facility with 0 CCPs for quite sometime now and when the FDA came through I gave them the same argument that I usually do, which has always been acceptable. I told them that we have a robust set of PRPs and GDPs and that we had policies in place to maintain time and temperature. His argument was Form-438 reporting that our HACCP plan is not considered a HACCP plan unless there are CCPs in place. The company was put on notice and we had to create CCPs in the process. It is great that you have a good program to keep them out I am confident that without a CCP you will continue to get notice. I process finished/packaged product and have 14. I would reassess your plan and keep in mind that the hazards are for issues that are "reasonably likely to occur." What you consider reasonable and what the FDA and USDA consider reasonable might not be agreeing at this point.
Edited by Brendan Triplett, 24 February 2020 - 09:54 AM.