I have a process to evaluate and don't want to go overboard forcing the process to create a CCP with no good way to measure it.
Process: We have a sealed polyethylene liner which is packed in a box. In order to pack it (without going into a drawn out detail) we have to unscrew a cap on the line, give the bag a quick shake and reapply the cap. This allows air into the bag which loosens it (bag is vacuum tight) and allows correct packaging.Food items in bulk will be placed into the liner once it is shipped to a customer location.
What are the hazards? In the two seconds it takes to loosen a cap, shake and replace cap, it is very unlikely a bug, hair or foreign item will sneak into the 3" opening and contaminate the inside of the bag.
We have cleaning program, pest control program. We've thought of sanitizing the area in case the cap touches a work surface. We have thought of making the employee wear a hair net incase a hair falls from his head into the little opening during the two second window.
Is this reasonable? This process step is the only time in the entire process the inside of liner (food contact surface) would be exposed.