In response to FDA's comment regarding the process operations inclusive in CCP
2, your firm added some clarity to include the "racking and pre-cooker staging"
steps. However, FDA made a point that the CCP doesn't include the actual "Precooking
Steps" as identified in the HACCP plan; that operation is covered
independently in CCP 3. The CCP in the HACCP plan should more accurately
identify "Pre-cooking staging" or "Initiation of pre-cooking" rather than "Precooking"
as one of the operations covered by the CCP time limit.