I've noticed that the regs aren't published yet, at least on CASA's website (CASR part 99).
Reading the NPRM, I think there are questions that must be addressed.
- the few beers at the aero club bar followed by "retrieving one's headphones or helping someone push an aircraft".
- the Birdsville races.
- even going into the ops office or hangar after a good lunch.
Furthermore, I am surprised that the regs actually allow 0.02 percent alcohol, since as I interpret the regs today, the limit is effectively zero.
The problem can be solved satisfactorily by CASA being extremely careful about the definition of "Safety Sensitive Aviation Activities" in their regulations to rule out activities that are not essentially aviation related in that they do not require some form of qualification or training.
If CASA doesn't do this, then my guess is that some very nasty personal vendettas will follow, and eventually the Courts will force CASA to rewrite the regulations for reasons of natural justice.