David As an auditor I would have to agree with you. If you don't have an SHEQ manager who had documented roles & responsibilities key to the organisation then WHO is fulfilling these roles now would be an obvious question. If you had some documentation (corrective action) that you recognised this and were planning to do something about it might persuade me (auditor) its a minor NC and not a major NC. Calculated risk unless you go the fully documented route you mention. Jonty

Thank you for your responses, We have some 20+ procedures that reference a SHEQ Manager, which I am stating that these need to be reviewed as well as the organisational chart to show the role and responsibilities of the new SHEQ Supervisor. My Supervisor states this is not a priority (oh how wrong he is). The problem he has is that he is not a competent person in regards to HS&E and that is where the problem lies. I am saying that the procedures etc need to be reviewed to prevent a major non-conformance, although it would be an easy fix to put right. My view is lets get this right at the start and not worry about putting things right later in the simple terms of health and safety prevention is better than cure. I think sometimes you start to doubt yourself when so many people around you say that I am over complicating things, but I did not receive a five star award by not thinking things through and this forum is a great basis to sound out your thoughts. So once again I would like to thank all that replied to this posting.