JMMoric, you are preaching to the converted. We know what the metrics are. What is acceptable is defined. The risk management tools are well known and have been available for at least 50 years. CASA doesnt use the documents or processes of which you speak.
The problem is that the Department, and its puppet CASA, refuse to use these analytics in favor of voodoo safety prescriptions to the point where nobody cares about safety any more. They just care about compliance.
To put that another way, CASA is perceived by many to just make safety shyte up.
......and whats worse, some allegedly don't even care about compliance because :
a) it is almost impossible to be compliant, and
b) compliance as nothing to do with safety any more.