Can I omit micro sampling?

GOOD VALIDATION PRACTICE (cGVP) CLEANING VALIDATION
1

Is it possible to omit micro sampling for a CV program if I can justify the omission by claiming:

  1. We can effectively reduce API/detergent residue to a determined limit
  2. Clean equipment does not sit for longer than 10 days
  3. Equipment is sanitized after cleaning and before use
  4. Purified water is used for final rinse
  5. Water is not allowed to pool in equipment (i.e.: equipment is completely dry)
  6. Micro testing will be captured during our quarterly environmental monitoring

This is for a solid dose company, no liquid, all oral, nothing sterile.

I don’t have a problem doing the micro sampling but it starts to look more an more unnecessary as I try to justify doing it.

Thanks for any input.