Then I wonder why they bothered with the "member of management" thing in the first place. Why not just say that there must be a management representative, describe describe the requirements, and let it go at that? I also wonder what would happen if the whole MR requirement were just dropped. Nothing of significance, I expect.
OK everyone be prepared to pass out on this one....I tend agree with you here Jim, especially your last statement (Does anyone need smelling salts yet?

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I believe (not that it matters because in the end it doesn't), I believe that the MR should be a Senior Person just as the MR is required to be under OHSAS (MR must be a member of Top Management), if committment were true and management involvement real this would be the case. What we almost universally see and have now is that committment and involvement is by convenience, "When I have time I will", and winds up being just another agenda item on a long list of agenda items. (As a private individual I think the "annual" Management Review concept is a sham, especially if that's all they do, especially if that is all they do for review. Where is the committment in that? All it tells me is that it is inconvenient to look at MS performance the other 364 days)
And yeah, I personally question the value of having a 3rd, 4th or 5th tier underling or an external person like a consultant with no real organizational authority being the MR, but then again, what I personally question or believe or want can not and does not enter into the equation. This is where objectivity, impartiality and being unbiased comes into play and too many folks in my industry don't fully understand and maybe can't follow.