I have several issues operating under the FAID system.
It was based on road transport and rail systems, where the driver could stop the truck when he/she felt fatigued.
1. It does not consider the type of duty undertaken. ie C172 circuits in daylight or multiple night ILS approaches to the minima. They both accumulate the same fatigue points.
2. It assumes that the crew are able to diagnose their own fatigue.
3. The FAID system states that above, from memory 60 points, there should be no use of heavy machinery.
It is a published fact, and the Sleep Research Centre acknowledge this, that humans cannot accurately diagnose their own fatigue level.
The flaw in the FAID system is aircrew operate heavy machinery at the 80 points level, diagnosing their own fatigue level, and due to the nature of the industry, are unable to stop midflight like trucking counterparts.
I am however in favour of a better system than CAO 48.
My two bobs worth.