Sunfish, I just aim to say it as I see it.
Arm out the window,
All I can say is you must have severely impaired vision.
What Sunfish has to say is spot on.
Aviation is one of the few (if not the only) technical areas of Australian industry, where highly detailed and prescriptive regulations have not been succeeded by risk assessment based performance (outcome) regulations. The modern construction industry could not exist in Australia, at any price we could afford, if performance /outcome based regulation has not superseded the old prescriptivist regulations, and the latter (like aviation) had remained in place.
Sound familiar, we have aviation rules that we cannot afford, are not outcome/performance based, make little contribution to risk reduction (safety, if you insist) but hamstring the industry at all levels, and not just with the costs.
Fact is, if risk assessed performance regulations were applied to maintenance, the regulations/MOS would be about 10-15% of what we have.
How do I make this claim: because within CASA, in about 1999, we carried out a major exercise with the then existing regulations, it was quite amazing what we could dump, needless to say, the "iron ring" has a fit of the vapors and took over, the very idea was all too much for them.
Indeed, to quote a senior CASA legal person of the day:"Neither the Australian aviation nor CASA is sufficiently mature for outcome based regulation".
The sad call, recently, by a number of aviation associations, for yet more (a third level of) prescriptive regulation probably means there was some truth in said legal person's views. The fact is most Australian industry and commerce (and aviation virtually world wise) use two level legislation, and Act, and Regulations made under the Act, and here is the aviation community calling for (and, as a result the Forsyth Report recommending) a third level of regulation. Which, by the way, we already have, in the MOS, so we will probably wind up with four levels of legislation.
CASA will have a field day, I am certain CASA can't believe its luck, with the industry calling for yet more regulation.
Some of you probably think that the current rules for maintenance as EASA based, because CASA keeps saying so, but in fact they are nothing like the equivalent EASA regs, which are a very good effort at outcome based regulation.
Few of you will know that CASA was the last Commonwealth instrumentality to adopt competency based assessment --- but look at what they have done to it, once adopted ---- indeed, I am of the view that a number of the ways competency is to be demonstrated for Part 61 is just plain dangerous, and fly in the face of current knowledge, and manufacturer recommendations.
But, Hey!!!, what would the manufacturers and the rest of the world know, compared to CASA.
Tootle pip!!