Could it be that the penny has started to drop!
As the national regulatory authority (ICAO definition), CASA has simply one role, that is, to regulate. CASA can never be accused of being an Authority on Safe Civil Aviation. They are regulators pure and simple. Lawyers in the Attorney Generals Legislative Drafting Branch and dear old CASA's Office of Legal Counsel know the regulations must be written so as to be enforcable and with a bit of luck (the small print) carry a punitive measure. Safety has nothing to do with it. All of us can point to some Law/Reg that complied with 100% adds nothing to safety, even in some cases being actually unsafe (New Flight Manuals for some aircraft).
All the huffing and puffing on some other threads about parliament making the laws etc is true in simplistic terms, what really happens is some happy chappy in DoT&RS swans off to Montreal and commits us to some obsure ICAO accorde/annex/whatever, and returns to the relevance! of Canberra. Then the 'system' takes over and we at some time later finish up with a new law/reg or whatever. The changes to the Flight Manual are a recent case in point (again). ICAO 'told' us to change the Manuals, not some CASA 'safety' expert having a bright idea.
I certainly understand where TRIADIC is coming from. Any regulation that "had the potential to destroy safety management systems and occurrence reporting and as a result reduce the levels of safety that many have worked for" is a truely sad indicment on regulation as a means of achieving safety. It is another sad fact that both the AG's LDB and CASA's OLC persist in seeing enacted regulations that whilst beatifully written in a legal sense, mean diddly squat to me as a safety manager and operating pilot.
As I said at the start "Could it be that the penny has started to drop!"
ding