Ed,
We cover this several ways:
6.2.2 Training: We reference a training procedure that makes sure that everyone knows what ESD is, what it does to our products, how to use the supplied infrastructure to control it, and what the customer will get if we don't control it.
6.3 Infrastructure: We reference a procedure for testing all of the mats, painted surfaces, etc. that specific individuals do not have the resources, competency or equipment to verify/validate on their own.
7.5.5 Preservation of Product: We reference our daily ESD procedure here along with other procedures for stock rotation, etc. The daily proc. requires wrist strap, heel strap, cord checks, and signoff. So we are validating the specific individual equipment.
7.6 Control of M&M devices: Our mat and strap checkers are controlled equipment.
I agree with your management. ESD control is a training, infrastructure and handling issue. Think of it like climate control. Maintaining a constant temperature so you don't spoil your temp. sensitive product is not a special process. And you don't have to prove again and again that your product didn't spoil, just prove that the temperature is maintained.
-John