Deviation Risk Assessment

Hello,

I am looking for some insights. Our SQF audit is coming up and we had our pre-assessment audit a couple months ago. When he was here, he had asked for a handful of risk assessments. Currently, all of our risk assessments live in the HACCP Plan which is how SQF wants to see it however, our auditor asked that in addition to the HACCP Plan he also wants to see justifications of the risk assessments separately for non-process items such as our non-gmp walkway, usage of E4 lotion, clothing, etc.  

Does anyone have any examples of risk assessments on justifying some sort of deviation from best food safety practices?

Here's a bit of text I wrote for justifying only sending out seasoning blends for testing quarterly.

"Company employees check every incoming COA for Total Plate Count, and for E. coli and Salmonella. Samples of randomly selected raw materials and swabs from production surfaces are set out quarterly to an accredited third party laboratory for microbial testing, and occasionally for allergens or heavy metals. Company consultants and employees perform organoleptic testing on occasion, often associated with product samples sent by potential new suppliers.

In conjunction with other prerequisite programs such as Supply-Chain Management, Sanitation, Foreign Material Control and Allergen Control, this frequency of monitoring and testing should be able to contribute to the maintenance of control over microbial, chemical and physical hazards. Microbial testing more frequently would not improve this contribution.

Consequently, the risk from not testing more frequently is judged to be low."