I guess the current morass eventually will be sorted out as the result of judicial findings after the inevitable mishaps.
They shifted the legal burden away from themselves to the AOC holder and pilots.
I suspect that present and recent protocols would tie CASA into a judicial action regardless of what they may choose to call the process ?
However,
(a) The Ops Manual in question
For what it may be worth CAAP 215-1(2) imposes the following -
(i) at 2A1.4
Note the requirement to operate company aircraft in accordance with the up-to-date Aircraft Flight Manual (AFM) or other equivalent document (e.g. the company Operations Manual Vol. 2A). (See CAR 54, 138 and 139).
The reference to "other equivalent" can only refer to a 139(3) situation, I suggest.
(ii) at 2AA.1.7
In respect of takeoff and landing data -
The manual must contain information on the method of derivation of the data presented, in agreement with the data presented in the flight manual.
Dud data directions probably get sheeted home to the AOC holder and, perhaps, CASA.
(b) arming auto feather is mandatory (a no go item), but folk may not be using it for SOP reasons
As a certification chap, but not legally competent, I see that as being culpable. No philosophical difference to requiring the pilot to fly outside any other certification (AFM) limitation.
(c) The Bangkok QF brought to light
I don't have sufficient information to comment specifically. However, the usual airline practice is to seek an NTO for any variation to AFM procedure. I would be surprised if QF had not done this ?
One of the points which tends to confuse folks is that parts of the AFM are approved and required per certification standards while other parts are advisory and may be up for discussion.
As to who gets hung out to dry after the wreckage has been cleared away, I guess that is up to the presiding Judge.
It was much simpler when Megan and I were involved in the coalface activities .. an AOC setup involved a straightforward Statement of Compliance analysis of the documentation and procedure set which could then be ticked off by the Regulatory representative. Now, with the likes of some of the CAAPs, one wonders just who is responsible for keeping track of the tie up between the rule book (regs, etc) and the process book (CAAPs and similar CASA documents). It seems to me that a (basically) simple and straightforward bit of work has become a convoluted nightmare by comparison.
Probably we both are better off thinking more about grey nomad things and pleasant places along the GRR and like goat tracks ?