Playing the game or common sense
Of course don't forget MSA 3 Pg 23 which notes "common sense is the guide in any case" - always assuming your common sense is the same as the auditor/customer!!!!
In my opinion It does not say use GR&R in all cases, it says use the appropriate MSA technique for the situation. This could be as little as calibration trend analysis, to the full box of MSA toys.
I have found to date (famous last words), by specifing the MSA considered to be appropriate during
APQP, and I use an extra column on my version of the Control Plan to record this, none yet have questioned me too deep to raise a NCR.
Big problem is rewriting historic Plans just to show this as I've only got nine years to retirement.
Martin in the sunny UK