Exemption for Direct Food Contact Packaging

Has anyone filed for a scope exemption?

I'm in another query with management and now consultant who is asking for me to request exemption of our direct contact product from our audit scope.  We would then only be requesting certification for indirect contact (secondary packaging) products.  It's all run on the same equipment, on the same production floor at the same site. 

As I understand,  request to exempt product needs to prove that the exempted product does not put audited product at risk.  Direct Contact boxes are a higher risk product than the low risk indirect product we want to be audited for.  I just don't see how I can prove the need for exemption.  SQF told me they would audit the same way because Direct Contact products are being produced, so we should just include it.  Your thoughts?

Yes, people have filed scope exemptions.

However, based on the information you just provided I don't think you have 1 iota of a chance of getting an exemption on a food contact item that is run the same equipment.

I couldn't agree with you more.  I have explained this repeatedly.  There are too many cooks in the kitchen at this point and I'm the only one versed on this code.

The consultant they brought in is the one who recommended requesting this exemption knowing what I just outlined above. SMH. 

I am sticking with my recommendation for direct food contact audit.