Just out of curiosity, how do auditors and others react to the use of a visual description of the color?... I was asked what was wrong with the third analysis, and when I replied that I knew the third sample was different because it smelled differently than the other two (Yes, I'm old enough that I was taught to smell chemicals carefully) I got the strangest look, and was asked "what could that possibly tell you?"
I once tested strychnine for pharmaceutical use ( added to an aphrodisiac formulation ), and the last pharmacopoeia I found with a suitable monograph had a taste ID test ( two small crystals on the tongue - should be very bitter - it was! ).
We used to put taste, smell, texture tests down as "Organoleptic Evaluation" results. I think the term is still used in the food industry.
In my experience, auditors don't worry too much about "report only" descriptors, provided there is evidence that client and provider have previously agreed. Most regulators have the information present, but make it report only.
The EP 5.0 puts the product visual description and some other properties under a subtitle of "Characters" and then notes " The statements under the heading Characters are not to be interpreted in a strict sense and are not requirements ". USP notes of the Description section " the properties are not in themselves standards or tests for purity even though they may indirectly assist in the preliminary evaluation of an article".
We had one client's auditor suggest that we use the Pantone colour system ( probably because it was used in some downstream product packaging specifications ), however their own R & D staff nixed it because they didn't want the expense and hassle of the charts and lighting systems, especially as the Pantone equipment wasn't designed to view bioactive chemical powders.
We also had one auditor who picked up on national terms, eg dairy cream in NZ is more coloured than cream in the USA, so we were asked not to describe colour as "cream" or use any other terms that may match actual products. That seemed rational to me, so was surprised it came from an auditor.
Please keep having fun,
Bruce Hamilton