CS
The RA provides the "framework". The problem is, there is nobody willing to mandate and ensure that it is implemented. That was the basic issue reiterated by the Nimrod XV230 senior Reviewing Officer, and then reiterated again by Haddon-Cave. And, given the above RA dilutes hitherto mandated regulations to "should" instead of "shall", it can be seen the current MAA regime is a regression.
You are not being pedantic. You are absolutely right.