CIP for cream fillings

Hi all,

I hope you are all well.

Regarding CIP requirement, we are a bakery factory and we process some of our fillings using soren. It has a CIP system for cleaning only the tank. We did not include this process in our HACCP plan scope but it has its own process flow and HACCP plan if someone will ask. 

Just wanted some opinion if we should include this requirement in our scope?

Thanks,

What was the original reasoning for not including it in the HACCP scope?

What was the original reasoning for not including it in the HACCP scope?

We dont retail fillings that's the reasoning i get from the team and the product will undergo baking process, also we have some filling supplied by approved suppliers. But i have doubts so i made a separate haccp plan for this process. 

In my opinion:

you're cleaning a tank to avoid the growth of bacteria and other microbes and to avoid cross-contamination with allergens.

These products might later undergo heating, but that doesn't mean you have covered the risk of heat-resistant bacteria or allergen cross-contamination.

It may not be a CCP itself, but it's definitely a PRP or oPRP in your own HACCP plan.

As for the approved suppliers: do you include their HACCP and other mitigation plans in their assessment?