I previously worked for a fresh cut produce processing facility. What we did was we would mostly receive fruits/vegetables that were already pre-washed from the supplier and then we would slice the materials and then do a wash.
Prep > Slicing > washing > centrifuge dryer > packing
When you wash the produce, you need to make sure that the concentration of the PAA is acceptable throughout the wash. There are certain produce that will require different concentrations or eat the concentration fast. In my experience, cabbage, onions, and peppers were the worst and deplete the concentration fast. If you don't already have a PAA system that automatically dispenses PAA, it might be something to look into. I know Ecolab, among other companies, have these types of solutions.
I would not identify the wash step as a CCP.
You also need to make sure that you have good sanitation controls in place to prevent any recontamination after the washing process. Also strong GMP practices.
Depending on the environmental program that you have (how many swabs, what you swab, and frequency) that can help your case.
I would imagine that you do not send product out for pathogen testing due to the short shelf life of the product. Do you receive any COAs for the raw produce you receive?