Jim you wrote:
"I cannot say for certain that I would write this up. I said I probably would. What grounds? Probably 4.1 c. QMS controls must be effective. On its face this situation is ludicrous".
then:
"In the example given, a punch press operator that is identified as the management representative with no outward evidence of being a manager should raise any auditor's eyebrows.
If indeed the ONLY evidence that the punch press operator is a member of management is that a member of top management says they are, that is even more suspect.
That wouldn't get YOUR attention?"
Firstly, you inserted your interpretation - not what the standard says - 'shall appoint a member of the organization's management" not member of TOP management as you wrote!
There's a big leap between getting someone's attention, when auditing, to dig further and what you're proposing. You say you wouldn't write it as a non-conformity, yet you behave as if it is! You seem to position yourself on the fence then not give any indications as to what it would take to get you off the fence, other than feelings or opinions? It reads to me that you've made up your mind that this person, even though we are only given a title, can't in any way be the Management Rep...
Further, you gave no indication to any reader as to what evidence you would seek to see if the situation is effective. Maybe we don't 'like' a press operator as MR, but if the place is small enough, they don't have a lot of 'titles' floating around, then maybe it works. I certainly don't agree with any non-conformance that would lump this under 4.1 - what's that got to do with the situation in hand?