The CAA auditing system, at 135 level at least, is crazy.
Ever since the department disposed of their Aircraft that allowed them to have a more hands-on approach to regulation (and better communication with operators), all they do is check that certain manuals detail what they expect, and the operator is safe for another year.
If everybody that drove a car on the roads, was to write a manual for the MoT, that said that "Drivers shall not exceed the designated speed limit on any section of road" we shouldn’t need police cars patrolling for speeding drivers.
When was the last time that a CAA inspector did a 'ramp' check on an operator as they were about to start the engines?
Some operators might get a quick shake up if that happened more often.