In the past, from experience, all FRMS was really, was a way for operators to rort the system "Legally", dependant on the FOI of the day.
I applaud CASA for attempting to sort out the issue, if in fact mitigating fatigue was their motive? But does replacing 4 or 5 pages of intelligble gobbeldegook with 20 or 30 pages of intelligble gobbeldegook really "sort it out"?
At the end of the day it will still come down to whatever the FOI of the day considers appropriate, they are the experts in all things aviation, and of course are highly trained in fatigue management.
I am fearful that FRMS will just end up another piece of "Shelfware", required to absolve CAsA of responsibility for anything, that gathers dust until the next Audit, when it will turn into a "Imminent threat to aviation safety" because there's been a change of FOI.