You say "the AFM must be adhered to". But what is the legal situation when the AFM is using words and phrases that are more akin to recommendations and advice, rather than concrete directives?
Are you serious?
You do something outside the AFM's 'Advice' and have a prang....thankfully you survive
It goes to court.
It turns out, that you were operating outside of the AFM's 'advice', but based on experience.
You are asked to show the documentation supporting your operating procedure.
Where do you stand now legally?