HARPC HA - ready-to-cook finished good but lethality steps

I transitioned from a fried food USDA plant to an FDA plant with simulated meats.

For USDA, I am cooking raw batter to lethality.  For FDA, I am cooking raw batter but the end consumer will be "cooking" the product.  

Based on my HACCP experience, this heating step is a CCP for USDA.  Would I consider it a CCP/lethality step for ready to cook or is it just a processing step for product quality?

Advice?  Examples?

I transitioned from a fried food USDA plant to an FDA plant with simulated meats.

 

For USDA, I am cooking raw batter to lethality.  For FDA, I am cooking raw batter but the end consumer will be "cooking" the product.  

 

Based on my HACCP experience, this heating step is a CCP for USDA.  Would I consider it a CCP/lethality step for ready to cook or is it just a processing step for product quality?

 

Advice?  Examples?

It appears you are referring to an RTE versus NRTE finished product (often described as cooked and pre-cooked respectively).

Since a hazard analysis for traditional HACCP includes consumer use and assuming the NRTE product has a labelled, validated, cooking instruction the latter step should eliminate any microbial hazards. Accordingly, for NRTE, the preliminary heating step will not be associated with a (microbial based) CCP.

Thanks Charles!

The hazards you are identifying will be "controlled by a later step", specifically the lethality validated process in the instructions.

This could be one of the atypical HACCP variations where you might not have a biological CCP even though there are known biological hazards.