I had a meeting with the SA professor who worked on Fatigue Management a number of years ago.
He said there was no scientific basis behind CAO48 but he wanted to go down the Risk Management line where a single person or organisation would think of a risk then mitigate it in the FMS.
What a load of Cods Wollop!!
How can 1 person or at best a small number of people know better then 50+ years of CAO48 with millions of flight hours and tens's of thousands of pilots operating to it?
I do not know of any accident attributed to fatigue where the crew where operating within CAO48!
How can that not be scientific?
We are being over run by bureaucrats with long degrees with no experience!