Things like the Safety Manager requirement for every 135 operator, and 133 for helicopters, really highlight the issues with these supposedly 'outcomes-based' regs.
A very small operation with one or two non-complex aircraft doing scenic flights and what was previously simple charter work does not need a separate safety manager on the payroll. CASA would say that the intent is for scalable solutions, but you can bet when audit time comes the same paperwork will be needed no matter if you have 2 or 200 employees - risk register, risk assessments, hazard reports, safety committee meetings, incident investigations etc.
This translates to the ridiculous situation where the Chief Pilot is spending a hefty chunk of time and effort ensuring the paper trail is satisfied when the same or better outcomes would be achieved by simply being there, seeing what goes on and taking actions on the spot to ensure the operations runs as it should. Same goes for change management - why would you need a formal documented change management process, auditable by the regulator, to decide to buy an R44 when you already operate a Bell 206? CASA says you do.
For questions like these, I often think of the comparison between what's allowed on the roads vs. in the air. If I bought a 12 seat minibus and started offering pub crawls, why wouldn't I have to employ a safety manager and have a 500 page operations manual? Probably more risk of killing someone that way than in an aeroplane. Or how is it that a petrol tanker and a bus full of people can pass one another at 200 km/h closing speed without having to fill in a risk assessment for every different route they travel on?
There's also the consistency issue - a Part 135 VFR single-engine pax transport flight over a populous area will hit the ground at say 60 kts if the engine fails. A Part 133 rotorcraft doing the same thing would hit at 10 kts or less, but needs to have ensured and documented that there are so-called safe forced landing areas available at all times, when the fixed wing doesn't.
Whether this stuff will really be audited and findings issued is a different story, but the poor Head of Operations of a small operation still has all this administrative burden that is, I reckon, clearly a safety detractor rather than an enhancer.