and conducted under a specific variation approved by GCAA on the basis of a risk assessment provided by the operator, that provide a level of safety equivalent to, or better than, that achieved through the prescriptive fatigue management regulations.
FRMS
A data-driven means of continuously monitoring and managing fatigue-related safety risks, based upon scientific principles and knowledge as well as operational experience that aims to ensure relevant personnel are performing at adequate levels of alertness
Note the requirements for "risk assessment" and "data".......ASRs are a very important component of this.
ASRs go to the very top and if there is an issue it will be changed. That's apparently what happened last time we did the 3 pilot trips. If you are fatigued file!