I'm not an atorney but wouldn't section 2 of CAO 82.0 simply set out the 'interpretation' in so far as the CAO is concerned - a little like definitions and therefore only regulatory when applied to conditions. After all it does specify 'Interpretation" in the heading. The conditions for Charter are as stated under 3A headed "Conditions for passenger ...". There is a gulf between the term 'interpretation' and 'condition' in my opinion.
Obviously RPT would be specified in a more formal and specific document appended to the AOC or your operations manual. Same may be applicable to airwork, also referenced to the operations manual.
I would imagine that any regulator would cover his butt by requiring a charter operator to also deal with fuel issues under the operations manual but rely on 3A as a safety net pending operational surveillance and development of such manual.
Surely the operator and the managing or chief pilot would have an obligation to oversee any such operation and perhaps intervene if the mission is running outside the gambit of probability.
Little bit premature to hang the crew without fully considering the procedures they were attempting to comply with. You guys are hip shooters.