Watsyors,
The FAF/FAP is not a JAR-OPS requirement.
The term used is "....outer marker (or equivalent position) If no such position exists, the decision to continue or discontinue the approach shall be made before passing 1000 ft. AAL".
So - using the FAP (9 miles/3000 ft. in some cases) as the cutoff could leave you between the FAP and the OM equivalent position (most often the DME GS check) with RVRs below required approach minima - and thinking that you were allowed to continue. Not adviseable, in my humble opinion.
...but always willing to be proved wrong
Brgds
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