Why not use your management review process? It doesn't say you have to have a procedure for section 4, just that items such as the scope, interested parties need to be documented in something which might be called a quality manual...
If you consider the theme behind the section 4 and 6 requirements, there's a lot of "business planning" hinted at. Doing a SWOT (or similar) doesn't need a procedure. Recording the results, evaluating which risk and opportunities present themselves and developing a plan (per 6.1) is well suited to being put on the agenda of the management review.
Having just gone through the AS9100D upgrade process using this methodology, I was pleased/shocked to hear the CB auditor describe it as "best in class" as an approach...:mg: