I liked compressor stall's call:
A good tool in the right hands, a dangerous exploitative one in the wrong hands.
'bout sums it up really. Same as CAO 48 and thier various exemptions: no system will stop the 15 to 20% who will abuse ANY system.
But what fascinates me most about the FRMS is it's introduction. Firstly we had the NPRM. I will talk about the helicopter industry response as I am not familiar with the thrust of the fixed wing response. The overwhelming response was to reject the proposal that CASA put forward, which essentially was that they were suggesting that the shortfalls of CAO48 and exemptions should be addressed by "an operator devised" fatigue system that could be put up for approval by CASA.
As absolutely NO guidelines were provided other than that the operator would have to prove it's validity. There was no standard set by CASA, nothing to base your research on, nothing to judge methodology with, just a statement that CASA would decide if your suggestion was valid or not.
Suprise suprise, the helicopter industry suggested an overhaul of CAO48 and exemptions (because they were working) and totally rejected the individual operator designed system suggested. Further, it was stated that CASA, being the overall body responsible for such things as RULES and SAFETY might actually research and design a system for ALL operators so that individuals did not have to finance individual research projects with NO DEFINED SCOPE METHODOLOGY OR OUTCOMES so that CASA could pass subjective judgement.
What came out was dumbfounding. After industry rejected the individual designed system proposed and suggesting an overhaul of CAO48, CASA turned around and said that having fully consulted the industry and examined a large amount of response, the industry had rejected the current CAO48 and was therefore happy with the proposal to introduce an individually designed system. WTF?
They used the request for an overhaul of 48 as grounds to wash their hands of the responsibility of properly funding and researching fatigue issues, and requiring each individual operator to fork out itself. It then made the change over WITHOUT NOTICE effective from the next renewal of the operators AOC. This meant that those whom had just renewed thier AOC had three more years to use their exemptions, whilst if your renewal was the next day, your exemptions were all cancelled immediately regardless of existing contracts. Out on the same fire line it meant that some operators were restricted to CAO48, and others were still operating on the old standard industry exemptions and flying substantially more. What could be fairer than that?
Now we can pay a university mob to give us a truck drivers fatigue system and CASA are happy. I wonder what liability insurance that uni has? Are they fully aware of the ramifications of an aircraft accident as a result of their research into truck drivers?
