I know the OSAP is not an FMS approach, that's the whole point.
There is a limitation in the RWFM that REQUIRES all instrument approaches be "retrieved" from the FMS.
You can't retrieve the OSAP, therefore the limitations section indicates you cannot execute the OSAP approach. Specifically BECAUSE it is not an FMS approach!
Reading the limitations section, "Instrument approaches must be carried out in accordance with an approved instrument approach procedure", (which the OSAP is), "that are retrieved from the FMS data base" (which the OSAP is not).
Hey, we've been doing OSAP's in the 139 for 5 years now, a pilot brought this up. According tto the limitations section we shouldn't be.