This paper presents an analysis of the phonological system of Malay that does not assume the segmental phoneme as its base. The analysis also follows the tradition of J. R. Firth in that it establishes different systems at different points in the syllable. The lowest level at which segmentation is allowed is that of syllable places, Cs and Vs. Prosodic features are measured in terms of Cs and Vs, the feature array being separated into different layers relating to the various parameters of speech, such as phonation and place of articulation. In addition, phonological rules are nondestructive in nature; they can only build structure, not alter it or delete it. As a consequence of this requirement, phonological representations in the lexicon are highly underspecified.