Hi Matt,
The way I've been trained, food safety risks are the primary concern-things that could harm a consumer if there's a failure in that step of the process. When designing a HACCP plan, it's advisable to be selective with what you label as CCP. Since you're highlighting that this step could result in consumer harm if it fails, you will be subject to stricter monitoring and record-keeping if someone audits your plan. Improper boiling of a product might result in a quality defect that isn't fit for sale but most likely wouldn't pose a risk to the consumer if it went to market.
In a brewery setting, broken glass from bottle breakage at the filler would often be one of the only true CCPs. If there was an exploding bottle and no precautions were taken to ensure broken glass couldn't contaminate surrounding bottles, there could be a risk of glass reaching a consumer and causing harm.
A boiling or pasteurization step would definitely be a CCP if it posed a risk of harboring pathogens that could harm a consumer, but it's typically understood that pathogens can't survive in beer. NA beer is a different story and is a hot topic in the food safety world currently. Hopefully, that helps.
Cheers,
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Jason Weihbrecht
GM of Brewery Operations
Oskar Blues Brewery
Brevard NC
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