FE Hoppy, the anomaly with the Embraer (and other aircraft) results from the differences in terminology in various regulations, their slow amendment rate, and evolving technology.
In Europe, the certification of fail passive systems, as above, is limited to 50 ft (JAR-AWO), but the operating limits (RVR minima) can be less than the ICAO definitions via JAR-OPS.
IIRC the system that you describe is classified as ‘Super Fail Passive’, which was pioneered by the Avro RJ (50 ft DH, 150m RVR).
Thus, it would necessary to qualify the original question to give a meaningful answer.
I might be better to consider, in order, the aircraft system status, the certificated limits for that equipment (including an airport element), the operational limits (regulator and company), and finally what the crew qualifications are.