Steven,
I hate it when standards use terms like "when used" or "where appropriate" ambiguously, as they do (IMO) in this 21 CFR 820.250. Maybe they mean what you suggest (non-statistical sampling is okay if you say it is). Maybe they mean if you don't 100% test, then you are sampling, and then you need supporting rationale.
It is much more clear if they use language like this: "Seller shall perform 100% inspection, or, if sampling inspection is used, the sampling shall conform to requirements of blah blah blah..."
I hate it when standards use terms like "when used" or "where appropriate" ambiguously, as they do (IMO) in this 21 CFR 820.250. Maybe they mean what you suggest (non-statistical sampling is okay if you say it is). Maybe they mean if you don't 100% test, then you are sampling, and then you need supporting rationale.
It is much more clear if they use language like this: "Seller shall perform 100% inspection, or, if sampling inspection is used, the sampling shall conform to requirements of blah blah blah..."