IGW
Yes, they are but the jobs usually gets dumped on some poor sod.
The real problem, for JAA manuals at least, is that whoever wrote the spec in JAR OPS didn't have the faintest clue about technical writing (it was probably dumped on another poor sod). Trying to use their numbering system is a real pain. It's not so bad when you are dealing with inspectors in the UK, for example, but with those from countries whose native language is not English, and where everything has to follow the numbering exactly, it can be impossible (especially with Part B).
I hope that whoever takes over the specs in EARSA has the sense to ask!
Phil