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xpensive for the operator at $20K a year but, good for people such as myself that are in the SMS industry!
Do you want to rethink your last post or is the mining company now the operator ?
"we simply work as an agent to have their 'house in order' in prep for future audits....."
You still don't get it do you. The operator is required to"have their house in order" 100% of the time and not just brush the dust off the manuals for external audits. The operator cannot rely on a third party to manage their compliance. Such an arrangement would not meet the requirements of the act for a suitable organisaional structure.
Honestly, I fear for the operator if that is the quality of your advice.