The reality is that FRMS is just a tick box within a flawed SMS structure that has no resilience beyond the aircrew member. As pilots we have at least a little more clout than the CC who have virtually no respite provisions that do not automatically result in a performance management meeting.
We also need to be very conscious of the backdooring of the regs by pining a flag of convenience to an aircraft and its crew.
The in-camera discussions at the Senate Inquiry were unambiguous and clearly identified the need to tie FRMS performance back through post day of ops processes Put simply a front end CAO that seeks to prevent a fatigue being a casual or contributing factor is worth jack if there is no tie back to management remedy and response.
Have always said that if FRMS is given more consideration in AOC approval and continuity, then those in management who only ever experience flying in a J or P seat are likely adopt a very different approach.
AT