First, let me say, that I don't have any professional knowledge of tea processing. I only know it as a frequent user.
In my opinion metall can only be a CCP, when you have measurements to reduce the risk. For example magnets, metal detection or foreign body detection. It is like OZLEM explained not an O-PRP, because PRP are the basic things. Often also referred al Good Manufactury Programs. (indeed: water, pestcontrol, maintenance, hand washing policies, etc.)
It also depends what your customers do with your product. Tea is not only used for infusion, but also for cosmetics and as an ingredient for foods. E.g. in my country a biscuit producer will introduce biscuits with real tea this autumn. Metal (and other foreign bodies) will be an item then.
On the other hand, although I only use the infusion for drinking, I don't like the idea that I drink an infusion of metals. That is my opinion as a consumer.
Greetings, Madam A. D-tor