BH # 302 CASA found that the existing and approved procedures needing expanding.
Tricky, subjective business for not just CASA this; they are damned if they do and damned if they don't. All the CASA team can do is recommend (suggest, bully or insist) that a company fuel planning policy is 'compliant'. The easiest way is simply comply with the AFM procedures, that is guaranteed legal. Clear, unambiguous statements in the COM regarding 'fuel planning' policy, flight planning policy and perhaps recommended 'methodology', will cover the operators arse; but regrettably, dump the PIC straight in the cart if policy is not followed. Unless the 'policy is, after the event, proven flawed; round and round she goes etc. Feast day for the legal eagles.
The key (IMO) is company recommended practice and procedure which allows Command discretion (wriggle room) but does not compromise anyone's 'rice bowl'. Deuced tricky problem for all; 20/20 hindsight of course is always through rose coloured glasses.
The problem is that after the event, someone is going to carry the can, if 'they' were part of the problem with 'fuel' then, they can be held accountable. This is most unsatisfactory – for all.