Who is responsible for making a safety case.
 

It seems CASA has decided to set some additional rules about attendance of staff in the cockpit. Fair enough, there are pros and cons, but presumably CASA in their wisdom assessed these before bringing down the rules.

But it appears that CASA has dictated these changes, and is now asking the airlines to make a safety case for the changes that they, CASA have mandated.

Another ducking of responsibility by CASA? Where is their safety case for making the changes?

Surely the logical answer is "CASA has mandated the change, the airlines are simply implementing what is required by law". However we know that logic plays little role in these matters.

Seabreeze,
In any regulatory change, CASA has the responsibility for a process that fundamentally starts with the justification of the rule, roughly the "safety case".

As we know, despite the "rules for rules" being Government policy, and despite any number of apparently authoritative guides to the process, the latest being the "Brown Book", the Australian Government Guide Regulation,

<https://www.cuttingredtape.gov.au/handbook/australian-government-guide-regulation>

this and similar are all too often ignored by CASA and quite a few other government organisations.

If an airline wants a concession, they have to make the case for the concession.

Despite Government policy that seems to suggest the opposite, the internal CASA "policy" is "we can do anything we like". Just ask Polar Air. They will tell you it cost them $1.5M to find out CASA can do whatever they like.

Tootle pip!!