Baking Process for crumbcake

Hi, 

I am trying to develop the HACCP Plan for a crumbcake Manufacturer and I was wondering if there's any biological hazard if they put the crumb on top of the cake when the cake is hot? they basically bake the cake at the beginning and they place the crumb on top of the cake a few minutes later. they bake the final product again for 10 minutes at least 212 degrees. does anyone have experience with crumbcake processing? i would really appreciate it. Thanks, 

Don't have experience with crumb cake however thinking of the HA what I would ask is;

Crumble is usually flour, sugar and butter, are these items under temp control before, during and after prep?

Are the ingredients from Approved supplier's and do you have a LOG or COA for them?

Is the crumble pre baked? or kept cold and not in the danger zone before its added to the cake?

Does the temperature of the crumble cause the cake temperatures to drop to the danger zone before its cooked again?

Is the 212° at 10 minutes hot enough to kill pathogens of concern for the crumble product?

Looking at past history of this product, has there been any complaints or issues related to Bio?

I believe you would have a medium risk here, and the temperature and time controls would lower the risk. It maybe CP or CCP if you find the risk is high enough.

I agree with maple.   Do a kill step verification after the 212 baking, and I think you're good.   We make a crumb  cake here, but non rte.   However, I do bake them in my lab, and could easily pass a kill step verification.

Also, we bake with out topping added to the batter, so only one step bake.   Why not do that?   Make the whole process easier and safer.

Thank you!!