Fact 1: The CAA accept CAP371 is not robust enough in the environment airlines are forced to operate.
Fact 2: The CAA accepts that CAP 371 allows rostering practices that are fatiguing without there being any method in place to monitor that fatigue.
Fact 3: The CAA believes that CAP 371 limits are now being used as targets and this is not in the spirit of the guidance.
Fact 4: The CAA feel it is no longer acceptable to justify a fatiguing roster by saying "it is legal".
I can state this as fact because a colleague of mine was at a CAA Fatigue Risk Seminar where they stood up and made these statements.
Imagine my surprise when I see a CAA spokesman say that our FTL's are "comprehensive, robust and protective" .