Is product thawing considered to be a step in the process? If product thawing occurs in an official establishment, is it required to be a CCP?
A5: If an official establishment is thawing product, it should be considered as a step in the process and evaluated as part of the hazard analysis. If, as part of the hazard analysis, a food safety hazard is determined to be reasonably likely to occur with product thawing, 9 CFR 417.2(c)(2) requires the HACCP to include a CCP somewhere in the process.
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