Several years ago I was involved in writing a Part 142 Expositon for a medium sized flying school. There was much back and forth with the CASA FOI as I tried to meet each of the 450 tick box items he had to sign off before we gained approval.
When one piece of feedback came back to me stating that nowhere in the document had I mentioned that the Flying School’s facilities had ‘climate control’ I knew there was something grossly wrong with the system. The cost of that Part 142 Exposition (in addition to a Training Managanent System and Staff Training and Checking Manual that had to be written as well) I estimate would be somewhere in the vicinity of $50-75k. And that manual did nothing to improve safety - all it did was explain the procedures the flying school currently operated under. And I fear all it will have done is create additional burden every time the school has an audit.
A fun fact - the new manuals totalled about 30,000 words. That equates to about 1500 words for every aircraft the school had....for no discernible increase in safety 🙄