Kurnal says "Lyle does your application of 9999 to all projects include the management systems too"?
Mmmm! Good point sir! I might be doing just a little too much assuming that the passive and active measures promulgated in 9999 are sufficiently appropriate for our projects without testing the existing management level and in social clubs, that may be found to be terribly wanting! However, the same consideration applies to ADB and TBE, without effective management in place any protective measures could be rendered useless in a short period. Don't know so much about ADB but certainly TBE acknowledges that the requirements made are given on the assumption that adequate management levels are in place. That's a big assumption, especially in my area of operation!
The level of management in place may we'll be adequate for the use Lyle especially to satisfy EL Authorities in your instance as they may well be in the case of places of care as they are both inspected annually by those not afraid to use a big stick. Unlike F&R Service which doesn't like annoying people.