Is a Separate HACCP Plan Needed for NPD Kitchen?

Hello,

If a broker of ambient food ingredients has a BRCGS Agents & Brokers certification with an existing HACCP plan for operational processes, is a separate HACCP plan required for their NPD (New Product Development) kitchen?

Would the new product development kitchen add any risks that are not present in the regular operational processes or in the existing ingredients?

From my personal experience, I remember that R&D areas are not really all that strict on separating allergens and using separate tools for them, so that could in theory add additional risk. 

You have raised a REALLY interesting question. My gut feel is "yes" if anyone is EVER going to be eating the food from that kitchen but I have to be honest, when I last audited an NPD kitchen, it was for physical standards, temperatures etc so the outputs of HACCP but did I ever check they had a HACCP plan? I'm embarrassed to say no.

Most NPD kitchens are using vastly different processes to production facilities so in my mind it should be separate, can be a simplified HACCP if permitted in the jurisdiction and by any standard requirements but should be there.