CC, you are very much correct and this is in fact the problem with the way our regulations are written...... everything is open to interpretation and zero guidance fro the powers that be.... because they don't know themselves, or if there is guidance material its not readily available....
Hence the way every one get screwed over here, someone comes along and presents an acceptable means of compliance that one FOI says yep good to go. The next audit that happens the next FOI says.... but that's not the way we did it in Big Airship Co Ltd... you don't comply.... do not pass go, collect and NCN for your trouble......