We manufacture and pack dietary supplements. We have been making a specific product for 10+ years. During an audit it was mentioned that this product needed to have a CCP indicated in the HACCP Plan. They also mentioned that it should be listed as an acidified food. See quoted text below.
"This product will need a Process Authority Letter. Without the presence of preservatives, pathogens could grow and feed on the vitamins. With preservative present, this establishes a Kill step. "kill step" is incorporating the use of preservatives Sodium Benzoate, Potassium Sorbate, and Sodium Hexametaphosphate as usage concentrations that are operationally viable, and will be effective. On the PA letter, the Kill step will be identified as "use of preservatives" at concentrations listed. Note that the product will be on hold until preservative levels are confirmed."
We would like to continue without categorizing this product as an acidified food as the pH and water activity doesn't fall into the listed parameters. We also never described the addition of preservatives as a "kill step" in the process. We test all raw materials, water, finish product and stability.
Any advice would be greatly appreciated.