Brian
I think 2003 also like SASless. But TSB do mention such terms were being used well after delivery to Cougar too.
SASless
Your point about the FAA is noted but it is the job of the applicant (Sikorsky) to show compliance (i.e state they have complied with the rule and how) and then for the FAA to verify that.
Where the FAA may well be at serious fault is in the re-interpretation of the rule after the failure in August 2002.
As that resulted in a means of compliance that differed from all former (and since!) loss of lube tests I believe that should have been recorded as an Equivalent Safety Finding on the TC Data Sheet and at least it would have been visible and rightly open to challenge.
The fact they did the first test the usual way does rather indicate that Sikorsky (and FAA) understood what should have been done but fudged it with the bypass system in a panic when the failure occured. The apparently lengthy debate the JAA had seems to have been, at least, in part due to that re-interpretation.
Winnie
The crew had a right to expect (even if they didn't understand FAR29) a gearbox that could run for 30 minutes after any credible type of oil loss because that is the requirement in the latest FARs which Sikorsky were happy to trumpet they complied with.
Sikorsky and FAA should have had a wake up call after Broome which showed that there were failures that were not extremely remote that the bypass system could not cope with.
I wonder if they need a better system knowledge.