The answer to FFF's question "Why ask the question" is that the CAA FEs themselves seem to give a different answer when asked. Sometimes they say "Any hold that is part of a published approach" and sometimes they say "it must be on a facility". There appears doubt as to exactly what the ICAO requirement is and so it would be a good starting point to find the dam' thing. If it DOES say it must be on a facility then there is a case for the industry to go back to ICAO and suggest this needs amending as it is no longer practical to achieve this at several aerodromes.
It seems a good idea to be proactive - just for once - but the starting point has to be this ephemeral ICAO document.
All help gratefully received.