PJ your incorrect
3 months worth of ASR data to the regulator and the rule usually changes.
ORD (Chicago) had 20 months worth of ASRs before the short 24 hr or so lay over was changed to around 48hrs this despite nearly half the ASRs submitted complaining of tiredness , fatigue and noise issue. There should not be a set limit on time or required number of ASRs to trigger corrective action. Yes BM was the Master unfortunately the Master's Apprentice remains as his prodigy and life went on becoming just as creative in his interpretations as BM
GKOC41 your correct regarding the 18 -30 hr the GCAA FTLs were based around the UK CAAP 371 . Emirates stated "commercial reasons" when questioned by the GCAA. So nothing changed .
We don't have a FRMS system and will never see one in Emirates.Has to supported top down.
Will never happen.