As far as I seen, brewing is concidered food processing and thus has to comply with food processing regulations.
Depending on you local authority, some are as strict as if it were meat processing or dairy, and others realise the difference and are.... more flexible.
With this in mind, your critical control points can be as few or as many as to satisfy you and the regulations.
The bigger breweries are quite detailed in they HACCP programs as even small mistakes could mean big problems and money.
For us, just the malt we have CCPs points from the growing of the barley, malting, deliveries, storage, milling, mashing, lautering, and disposal.
And these CCPs vary some, depending on where the malt is coming from. (Germany, U.S., Denmark)
Some CCPs include specifing variety of barley, size of kernels, moisture content of barley going to the malster as well as the malted barley.
Certifications(Organic), cleaning of the barley and malt, cleaning of shipping containers, etc.
Hope this help.