Off the line, there are no hazards as it is fully cooked risotto, balled and fried. There are no temperature points during these stages that we need to meet for killing any bacteria as it is boiled for 20 minutes then flash fried after cooling. And again, it is a RTC product with instructions.
This is where I start to over-think things, as the Risotto is fully cooked in a kettle, then formed, batter/breaded and flash fried. At almost all stages it IS ready to eat, however we do not market or sell it as that. Do I need to mark down that we measure temperatures, adding in an extra step, as there is no need to? Or just leave this out of the HACCP plan altogether?
My inexperience may show here, so take my comments in context as someone who doesn't deal with RTE/RTC in his facility. But when you say "There are no hazards" because it was boiled for 20 minutes, that right there sounds like a possible
CCP to me because you make it sound like a kill step. Meaning, if your boiling step fails, there is a risk of micro contamination down the line. Have you verified the 20 minutes is sufficient (micro test history should be sufficient)? Are you verifying it actually boils for the full 20 minutes? Can you tell if someone shut the machine down early and didn't fully complete the kill step?
The main physical hazards I can think of would be metal pieces, but we metal detect the product, and the machines have very little moving parts. Other than that, if it occurs, plastic bag or paper bag fragments. I would assume that is more of a quality issue?
Absolutely it can be a safety issue. The US FDA has 7-25mm called out as a possible choking hazard, so if you expose
any FM in that size range it's a concern. Anything hard or sharp under that size can still break teeth or cause cuts.
With all that said, you have to assess whether or not it is likely to occur and whether or not it would be a significant hazard, and it will be specific to your process. If you're metal detecting because there's a chance your machine could start throwing off metal and you wouldn't otherwise know it, could be significant, could make your MD a
CCP.
Your plastic and paper bag fragments sound unlikely from your statement, but it's a good idea to make sure employees are trained to watch for torn and ripped packaging.