Since I no longer work in regulatory, I can't help you from that perspective...but I was at a recent Nat'l Cap. Area Env. Health Assoc. conference and on the program was a sous vide presentation by the Willard Hotel (they have been using this procedure for a number of years) and Cuisine Solutions (the Willard's supplier).
I'm sure one of them could answer your questions, but since you specifically mentioned HACCP, I would contact Sylvie Porphire, VP Global QA with Cuisine Solutions in VA. I have cc'd her so you'll have her email and her office # is 703 270 2907 or 888 285 4679.
Ellen Schroth, RS