At least the way RagingBull worded it I can't see that as actionable, but then I was always more forgiving as an elder. Those that enjoy their witch-hunts would probably chase this guy down and pin him on something they could label as "apostate" by interrogating him thusly:
So Brother Goatee, tell us just what exactly does, "trusting in the Bible and not the Organization so much" mean to you?
Compare to this:
"If a baptized Christian abandons the teachings of Jehovah, as presented by the faithful and discreet slave, and persists in believing other doctrine despite Scriptural reproof, then he is apostatizing. Extended, kindly efforts should be put forth to readjust his thinking." - Letter dated 9/1/1980 "TO ALL CIRCUIT AND DISTRICT OVERSEERS" from the WTBTS of NY, Inc.
Unless the elders can get him to admit to "abandoning the teachings of Jehovah, as presented by the faithful and discreet slave, and persists in believing other doctrine," then there is no real issue. Even then there has to be "scriptural reproof" and "Extended, kindly efforts should be put forth to readjust his thinking" before it is technically a judicial matter.
If someone is evasive and simply says they have doubts and are discouraged then there is technically nothing even the most over-zealous BOEs can do.
That being said, I know there are plenty of elders that "go beyond" even the WTBTS's draconian rules and regulations.
I'm just sayin' is all ...