Good point.
In the definition: "a step" = one particular point in the process.
Pest Control is not applied at one point in the process. Thus it is usually not considered to be a CCP.
It seems to me that some people are confused about whether a preventive control (FSMA terminology) has to be a CCP (HACCP terminology) because they consider a non-CCP preventive control as being "important", and therefore "critical" so it must be a CCP.
In my opinion, a CCP is a process control activity that is done during the handling, processing or manufacturing of food items. There are other control activities that occur outside of a production process.
So, Charles C., do you agree:
- All CCP's are Preventive Controls.
- Not all Preventive Controls are CCP's.
Yes, I stand corrected. A CCP is an important and necessary (essential) control activity. However, there are many control activities that are not CCP's: Pest Control, Food Defense, Supplier Approval, etc.
The confusion about terminology arises because of so many different codes, schemes, regulations, etc. that are not using the same terms for the same issue.