In which case, I suppose the blame lies largely with the regulator, would be tricky (as far as I'm aware) for BALPA to do much about it since they'd have to be in dispute with all UK-based airlines at the same time it was introduced.
Haven't got the time to read the entire document but I must admit I'm surprised that the regulator allows it. Mind you, they allow loads of other things which I think a lot of pilots would say they shouldn't (P2F etc.).