If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.
Cirronimbus I don't think you will find many people who will disagree with you, I mean god forbid having the regulator run your SMS!
The issue is the dodgy operator who uses the SMS to their own gain. Then each year when the annual CASA AOC audit comes up all the boxes are properly ticked and "yes the SMS is wonderful" and "works really well!"
The CASA FOIs and AWIs conducting the audit are none the wiser because all areas of compliance seem to be covered. But really the SMS has become a smokescreen to what is really going on.
The bureaucrats back in Canberra don't care because all the 'boxes are ticked', hence 'our area of responsibility and liability' is covered!'