An interesting point.
Going back to basics, a
CCP is a process such as cooking intended to control a hazard. Therefore if you have a cooking step this would act as a
CCP dealing adequately with many pathogenic bacteria including Listeria. However (I guess not knowing your process) that the real danger is for re-contamination from the manufacturing environment. In this case there is no specific process to prevent this just lots of good measures such as cleanliness, factory design, staff training etc. These latter points would all be described as PRP's.
Also from your question I would add a proviso. This being that
HACCP is in part a vehicle to explain to custmers and government authorities that you are working to best practice. For these reasons I would always be prepared to vary how I wrote my
HACCP i.e. If I lived in the USA I would look very carefully how their authorites prefer to view
HACCP. In the UK where I live we tend to stylise our studies quite differently. Who is to say who is right, but lets not look for unneccessary fights!
I hope I have been of some help.
Best Regards