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Old 22nd Nov 2014, 08:53
  #1487 (permalink)  
Sunfish
 
Join Date: Aug 2004
Location: Melbourne, Australia
Posts: 7,535
Leadslead?:

Leadslead, you can stick "advisory" material up the proverbial along with "accepted" operations manuals, "appropriate" procedures and "satisfactory" compliance.
CASA uses these meaningless words to screw all of us, all the time.
Sunfish,
I normally agree with what you have to say, but in this case you are completely wrong.

Quite simply, it is impossible to render all the advisory material as regulation.
Advisory material (CAAPs or ACs - Australia) Acs (FAA) or AMC (Acceptable Means of Compliance - EASA) all have one thing in common, they are "a way, but not the only way" to comply with a regulation.

US and EEC/EASA all run on ACs/AMCs with relatively brief regulations for aviation, the EASA rules are generally outcome or performance based rules, whilst FAA rules are generally prescriptive --- but not to the anal extent of Australia. You have worked elsewhere in Australian industry, which, by and large, runs on two tier legislation and advisory material --- acceptable means of compliance, going by many names -- AS/NZ Standards, just for one.

As I have previously, tackling polio by improving iron lungs is the wrong path, we need a cure for polio.

Trying with complete futility to turn CAAPs/ACs/AMCs into regulation will not work, we need a cure for the polio paralysis that CASA causes the aviation industry.
Leady, I am not suggesting that the current "advisories" be turned into regulation. i am suggesting that the current advisories be turned into recommendations!

The difference being that CASA is required to be responsible for what it recommends, and that compliance with CASA recommendations is an automatic and ironclad defence against punitive action in any form from any authority.

To put that another way, have an accident and kill someone while following CASA recommendations and the law? Sorry Mr. Coroner, talk to CASA, not me.
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