Hi, yes, and a well qualified - and now just former AB assessor (over 500 assessments) - I can stress the actual requirement, rather than parroting the ILAC/Region/AB position of the necessity of PT/ILC.
The ACTUAL requirement is in 5.9.1, NOT in the examples. Hence, if the examples do not apply and/or are not available, then bounce to one of the other examples as the method of meeting the requirement. But understand, you must have evidence that PT/ILC is either not available or presents and undue hardship on the lab. An undue hardship is not precisely defined but can be - roughly - interpreted - as if it equals or exceeds the cost of the accreditation, it is an undue hardship.
Yes, I have run across CRMs numerous times, as for testing at least, PT/ILC is limited. CRMs for several fields of testing are quite normal. And in some fields, even CRMs are not available, and so only consensus standards are available.
If you have detailed questions that may not be appropriate here, contact me off-line here.
Hope this helps.