GD # 506 - CASA no longer approve an Operators manuals, systems, S.O.P, structure etc, they accept. There is a huge difference in the legal meaning of approve and accept,
601# 507 - The real world shows that an OM is acceptable to the particular FOI or AWI at the time of acceptance.
Let's have a think here – If the CASA are going to 'accept' an exposition, then they only need take a new application over the counter (accept it) collect the money (lots of) and same day issue a certificate. Piece of cake – no fuss. The holder is then solely responsible for operating legally and if CASA audit at a later date and "discover" breaches, then it would be fair to prosecute, fine, shut down or whatever.
But they don't "accept", to even get a new or variant aircraft approved to an existing AOC the process can take a frustratingly long time, cost a bomb and drive you nuts. If they are actively interfering, requiring changes, amendments and forcing SOP which are making the CP cranky, then they are "involved".
To operate a couple of bloody big busses, the RTA don't want an Operations Manual, just insurance, licensed drivers and off you go. God help you if you are operating illegally; why, because the RTA was not involved in the 'operational approval' that's why. They just accept your cheque and you are on your own hook.
It cannot be both ways, if you are part of the approval, you are part of the problem. Read the audit items for Pel Air again, then tell me CASA are not complicit.