'I would be struggling to find an accident caused by fatigue" quote from CASA, maybe he should do a CRM course, I seem to recall quite a few prominent examples used in CRM training where dog tired crews have flown perfectly good aircraft into the ground where fatigue was the contributory factor and a couple of times where I nearly did the same.
Any fatigue system has to be tailored to the operation and the operator and there is no one size fits all. We could all recount numerous examples where for what ever reason, you have been unable to rest properly, eat properly and where the demands of the job and your private life have kept you at it well past the point you should have stopped.
The problem is it is a vexed issue involving your employment conditions and your employment contract but it can and is a safety issue, so if you cobble together a safety based system your in immediate conflict with the employment system. Pity the poor engineering and ground folk who have no rules to protect them from being worked ridiculous hours in ridiculous conditions.
So in my humble opinion until we get an employment based solution, minimum hours, family-work balance your never going to get a safety based system. So its back to basics, CAO 48 was a great substitute for the lack of a proper workplace award and agreement but it is well past its use by date. Why would you entrust a solution to the cretins in CASA who do not believe fatigue is an issue and can kill you. And we all know how you achieve a solid work place based solution don't we?