The roast is the kill step
Updated
On this page6
Well roasted is not the same as sufficient
A nut can taste and look perfectly roasted after a treatment that would not reliably achieve the reduction required. The reverse is also possible. The two questions are independent, and the maker who answers the flavor one and assumes the safety one is making the central mistake in this craft.
Validation means somebody competent said so
A kill step is validated when there is a documented basis for believing the time and temperature achieve the reduction required for that product. That is work for a process authority, using published data for this food matrix, and it is the equivalent of the scheduled process in the acidified crafts. It is not something you establish by tasting the result.
Then it has to be monitored and recorded
A validated process you cannot show you followed is not a control. Record the temperature and the time for every batch, with the batch code and the nut lot, at the time rather than afterwards. This is the record a buyer or an inspector asks for first.
If you buy roasted nuts, you are buying their kill step
Which means you need to know what it was and have it in writing against the lot you received. A supplier who will not document it is a supplier whose process you are relying on and cannot describe, and that is the position to avoid before it matters rather than after.
Raw nut butters are a deliberate exception
A product sold as raw has no kill step by definition, and that is a different safety case requiring different controls rather than fewer. If you are making one, it is worth knowing that you have chosen to remove the only control this craft normally has.