Thanks everyone for the info.
It is staggering that CASA would make a set of rules (CAO 48) and then grant some operators permanent exemption of the rules for day after day operation. I mean the CAO 48 wasn't arrived at surely by a bunch of guys in a bar. It seems that the guys/gals worst affected by this are the back of the clock freighter pilots. It just doesn't make sense.
It sort of reminds me of GA days long ago when the boss used to say how he would like to pay us properly but he would go broke if he did. All went broke eventually anyway. So should these"airlines"
Shame on CASA.