[Peetwo]

FRMS & the timeline of regulatory embuggerance - 

While HVH in toe with the Iron Ring and their minions, continue to snow-job the YMEN DFO accident report - http://www.auntypru.com/forum/thread-30-...ml#pid9340 - it would appear that Mr Fixit (aka Carmody Capers; aka the smiling assassin) is hard at the GA divide & decimate campaign (GADD)...    

Yesterday via the Yaffa:

CASA opens Consultation on Self-administration
26 September 2018

CASA has opened consultation on the first Part 149 Manual of Standards (MOS) for approved self-administering aviation organisations (ASAOs).

ASAOs administer specific sections of aviation under a CASA approval, and organisations such as Recreational Aviation Australia (RAAus) the Gliding Federation of Australia (GFA) and Australian Warbirds Association Limited (AWAL) are expected to transition to the new Part 149 rules.

Previously, these organisations were approved via individual agreements with CASA
"This consultation draft sets out the full proposed Part 149 MOS that supports the operation of Part 149 of the CASR – Approved Self-administering Aviation Organisations (ASAOs) – for public consideration and comment," CASA has stated. "Previous consultation has supported policy to have a concise regulation and move most of the operational detail for ASAOs into the Part 149 MOS.

"While Part 149 of CASR has been designed for sport and recreational aviation organisations which currently operate under a system of self-administration, the regulation enables any aviation organisation to apply to CASA to carry out a self-administered activity."

The MOS sets out the regulatory framework under which ASAOs will be expected to operate, and the requirements an organisation will need to meet for CASA to issue an ASAO certificate. The MOS covers many areas including:

• aircraft registration
  
• airworthiness
  
• flight operations
  
• flight training
  
• key personnel
  
• safety management systems
  

"The implementation of Part 149 of CASR means that the administration of aircraft operated in accordance with the 95-series CAOs that apply to sport and recreational aircraft would become an aviation administration function," CASA states in the Summary of Proposed Change.

"For the purposes of the prescribed aviation administration functions, the kinds of aircraft subject to self-administration (Part 149 aircraft) are described in the MOS in terms consistent with how they are described within the applicable CAO(s)."

CASA has given the aviation community until 21 October to respond to the draft Part 149 MOS via the Consultation Hub.

Read more at http://www.australianflying.com.au/lates...jcaev8V.99

Here is Sandy's take on CASA 'Iron Ring style' consultation in regards to the VFR ADSB imbroglio...

Quote:-

“CASA has listened to the aviation community and will be developing rule changes aimed at making it cheaper and easier for automatic dependent surveillance—broadcast (ADS-B) technology to be voluntarily fitted to visual flight rules aircraft. This action follows consultation which showed broad support for the voluntary adoption of ADS-B across general aviation. ”

Gosh that’s great and what a remarkable revelation that we would be in favour of voluntary fitment. All that money and time spent on the consultation process will be valued. Hoping it won’t be too many years before those hard working staff find the time to “develop” these new regulations, perhaps after the new basic medical regime is sorted?

I dare say that some of the regulation writing experts will be drifting back to Aviation Hearse after seminars and holidays in northern climes. If Canberra wasn’t so freezing and far from the beach...

But anyway while we wait, thanks CASA, how generous of you. We, your supplicants, are most impressed. Impressed as one being at an open casket funeral and admiring the funeral director’s skill at make up.

And for a perfect example on how much - under the warm & fuzzy CC stewardship - the CASA consultation process has become more conciliatory and efficient over time one cannot go past the more than decade old fatigue management regulatory (Order not Part) re-write (i.e. CAO 48.0).

Current progress: see - https://www.casa.gov.au/standard-page/fa...management

Next steps
In 2018, we will make amendments and develop guidance material to support the transition of the high capacity regular public transport operators.
We will continue to work with industry, including the Technical Working Group appointed by the Aviation Safety Advisory Panel, to road-test changes before public consultation on proposed changes to the regulations. Key changes this year will include amending the prescriptive flight duty limits in Appendices 2 and 3, and improvements to FRMS.

Now let's rewind 5 years when former Senator X had put forward a disallowance motion on CAO 48.1: reference link - http://www.auntypru.com/forum/showthread...86#pid8186

Fast forwarding again, to 30 June 2013 the following are quotes from a AIPA Parliamentary Brief in support of the NX proposal to disallow CAO 48.1: https://www.aipa.org.au/sites/default/fi...3a_002.pdf

---

From pg 2 of the brief:

In summary, the Instrument is a step in the right direction but is unfinished business. There are serious concerns about the application or otherwise of the body of fatigue science and research and the preservation or extension of existing provisions already challenged by parts of the industry as unsafe.

CASA has an abysmal record of regulatory oversight of fatigue management, even without the pressure of trying to get some serious traction on the Regulatory Reform programs that have diverted them for the last 17 or so years. Parts of the industry believe that CASA has seriously underestimated the resources required to implement these new rules and that there will be an inevitable trade-off in surveillance activities of flight operations.

If not disallowed now, this legislation will continue with no incentive for improvement unless and until the inherent risk crystallises into an undesirable outcome. That is not a possibility that this Parliament should allow to persist.
 

---

From pg 5:

ICAO recognises the importance of “operational experience”, but that is a tainted concept if it merely reflects what operators have been doing or what the regulator thinks they are doing.

In Australia, we have already seen how this concept is tainted - recent Senate inquiries that have touched upon Jetstar, Pel-air and Avtex/Skymaster fatigue management processes and largely exposed the gulf between sound fatigue risk management, what operators have really been doing and what the regulator didn’t really bother to see what they were doing. The CASA Special Audit conducted after the Pel-Air ditching revealed all three of those propositions, while explaining a lack of pilot complaints:

…The short planning period, lack of knowledge of possible destinations and lack of support provided by operations staff once doors closed appears to add to this fatigue. All crew interviewed stated that they felt there would be no issues in stating that they were fatigued and pulling out of duty but also felt that they had limited opportunities to fly and had to take these opportunities when they arose… 8

… Most crew interviewed stated that they had been part of a duty that was greater than 15 hours in length but evidence could not be identified that showed fatigue related extension of duty processes had been followed, safety reports had been written following the duty or that management follow-up was conducted as is required in the company FRMS manual. Several interviewees believed that there is a lack of management adherence to safety management requirements and the fatigue risk mitigation strategies as laid down in the company's FRMS manual…9

When CASA was asked about the significance of Jetstar requiring crews on the Darwin-Singapore-Darwin night flight to extend beyond their normal flight duty period (FDP) limits on 12 of 21 flights in January 2011, they responded:

CASA does not consider that these extensions require continual monitoring.
The duty extensions recorded in January 2011 by Jetstar were a result of flight crew agreeing to operate beyond the standard 12 hour initial limits as provided for within Civil Aviation Order 48 Exemption. No breaches of the 14 hour condition were recorded.10

Undoubtedly that is how CASA will regulate operations under the SIE until they expire in 2016, despite the fact that the same flights could not even be contemplated under The Instrument! Finally, from evidence given to the UK Parliament Transport Committee Inquiry into Flight Time Limitations in February 2012 (which we believe to be replicated in parts of the Australian industry):

7.6. More importantly: fatigue is significantly under-reported by the pilots themselves. This is because pilots do not file reports on an aspect that has become a ‘normal’ part of their daily work. Many are afraid their fatigue reports could have negative consequences for their professional future (i.e. reprisals by management) – a phenomenon that is growing – particularly when pilots refuse to fly because they are too fatigued. Indeed UK polling results show that 33% of pilots would not feel comfortable refusing to fly if fatigued, and of those who would, three quarters would have reservations. Once a pilot has decided they have no option but to fly, a fatigue report would be tantamount to writing the evidence for their own prosecution…11

This under-reporting by pilots is exacerbated by CASA being widely seen by the aviation community as having actively disengaged in any intelligent discussion about fatigue regulation for many years. It is highly unlikely that CASA has any defensible
‘regulatory experience’ other than superficial ‘tick and flick’ audit activities and, as such, cannot and should not rely on its perception of the current state of fatigue management to set aside the science or to replicate current rules.

Now rewind to the previous year, before the PelAir cover-up inquiry began, at Senate Estimates: reference - http://www.auntypru.com/forum/thread-10-...ml#pid8209

Coming back to the - unclosed loop - 2 decade old identified safety issue of fatigue, as a passing strange coincidence the following was a short passage of Hansard, from May 2012, that followed Sen Fawcett's ATSB safety loop questioning:

Senator XENOPHON: I will try to make it a very quick one. I keep getting complaints from those who are in safety-sensitive positions in aviation about fatigue issues and that the fatigue issues seem invariably to accompany reports of an oppressive workplace culture, most recently in terms of air traffic controllers. How does the ATSB deal with the particular issues of fatigue management and the performance consequences of workplace culture, given the subjectivity inherent in those concepts? Do you see a role in ATSB monitoring the performance of the fatigue management systems or do you see it as a purely regulatory function? Do you think that the regulatory agencies are doing enough about fatigue risk management? I am happy for you to take it on notice.

Mr Dolan : With your indulgence, I can answer it quite quickly.

CHAIR: Yes, get to the point.

Mr Dolan : Fatigue, when it is detected as a contributing factor in any investigation we undertake, we will look to fatigue management systems to see whether they can be improved to better manage the risk of fatigue in the system. I do not have any evidence in front of me that would allow me to give you an additional comment on the adequacy of regulatory oversight. We have not seen anything that would say it is inadequate. P2 comment - Err (vomit -  ) BOLLOCKS!!

Senator XENOPHON: Thank you.

Next let's rewind a decade to Budget Estimates 2008 (reference Hansard - 

S10855.pdf Size: 1.22 MB  Downloads: 0

S10855.pdf Size: 1.22 MB  Downloads: 0

) to a long but IMO important passage of Hansard between the RRAT Chair Senator Sterle and Carmody (feebly backed by Mr Wight):

CHAIR—Are there any other questions of CASA? If not, I have some that I would like to
put to you, Mr Carmody. Firstly, I would like to talk about one of your orders. You might want to bring someone to the table that may assist with civil aviation order 48, general exemption.

Mr Carmody—Could you hold on for a second?

CHAIR—By all means.

Mr Carmody—It is regarding flight and duty times, I presume.

CHAIR—Do you have it in front of you?

Mr Carmody—I am not really sure.

CHAIR—You do not have the order in front of you. You can pull me up then and correct
me if I am wrong then. Civil aviation order 48, general exemption, refers to flight deck duty time and, in particular, it talks about the actual time the pilots spend in the cockpit; is that correct?

Mr Wight—That is correct.

CHAIR—I am led to believe the exemption order addresses the actual time from the time
they clock on to the time they actually leave the cockpit; is that correct?

Mr Wight—You are talking about the actual order itself?

CHAIR—Yes, sorry, the actual order.

Mr Wight—The order reflects two parts. It reflects the duty time so, as you correctly said,
from the time they essentially start duty to when they finish duty and then it talks about flight time limitations as well. That is the actual flight time, so essentially sort of from pushback tothe flight stopping.

CHAIR—Off the top of your head what would be the difference in hours, would you
know?

Mr Wight—It would depend on the flight pattern that was given to the crew. The crew
could conceivably do an eight-hour duty and only do three or four flight hours. That is
possible.

CHAIR—It is possible that pilots can spend up to another five hours performing other
duties, preparation for departure and what not?

Mr Wight—Or time in between flights where they actually may not be performing any
duties.

CHAIR—Does that affect any particular sector? Is it domestic or international or both?
Mr Wight—The exemption that 48 covers is wide-ranging; it is not limited to international
or domestic. CASA has also had some standard exemptions in place that covers various
sectors of the industry.

CHAIR—Is CASA aware that operators are using alternative flight-deck duty time
definitions to that required by the civil aviation order 48 general exemption?

Mr Wight—I am not specifically aware of that. CASA operators either work to the CA48
or they work to the exemption that has been issued by the authority.

CHAIR—I am talking about the exemption now.

Mr Wight—Okay.

CHAIR—You are not aware?

Mr Wight—I am not specifically aware of the event which you are referring to.

CHAIR—Are you aware then that Australian and International Pilots Association has
repeatedly raised this matter with CASA over a period of some three years?

Mr Carmody—Yes, I am aware that it has been the subject of a lot of discussion by the
Australian and International Pilots Association and others in the Standards Consultative
Committee of which AIPA is a member. Many other organisations are members as well. That is the organisation, the group, that we have in place to consult on our regulations.

CHAIR—Who is on that?

Mr Carmody—It is chaired by an external chair and has a wide range of industry
representatives from AIPA to representative organisations like the international pilots
association and the Flight Attendants Association. It has the major airlines. It has the Regional Airlines Association. It has the maintenance organisations. There are routinely about 60 people at the Standards Consultative Committee meeting. The point I am making is that my understanding is that the Standards Consultative Committee has discussed this at some length and has agreed that there are some issues with CAO 48 but that it is going to be managed under the fatigue risk management system that is being discussed and being brought into place at present. I understand that there is a proposed change to civil aviation order 48 which will offer fatigue risk management as an option for managing duty times. It is anticipated that a notice of proposed rulemaking for this CAO change will be released in September this year.

It has been a very long and complex process and I understand that the Australian and
International Pilots Association is very keen to have it resolved, but I also understand that the committee has discussed it on a number of occasions and this is the course that they have agreed to follow.


CHAIR—What were they discussing?

Mr Carmody—That there are some inadequacies with CAO 48 and that newer approaches
to looking at fatigue and fatigue risk should be in place and we should be offering
alternatives.

CHAIR—You might be able to help me out here, when you say, ‘some inadequacies’, did
it not suit some of the airline operators?

Mr Carmody—I do not know in detail. All I know is that discussions have centred on CAO 48. My presumption is that some operators are having difficulties, or some individuals
are having difficulties, and that is why it has been discussed at length.

CHAIR—I do not have a history in fatigue management in the aviation industry but, for
the record, I have a hell of a lot of experience of fatigue management in road transport. When we start talking about these representative bodies who are well and truly representing over 60 individuals; just about every stakeholder in the industry I would say would be represented on that AIPA; is that right?

Mr Carmody—No, the Standards Consultative Committee.

CHAIR—The Standards Consultative Committee. And if I am hearing correctly they are
having some issues around a fatigue management issue. The issues must be that obviously
they are not happy with it in terms of it being too tight for the operators, or is it too long for the pilots?


Mr Carmody—I would presume it depends on where you sit. Without trying to be
flippant, I would suggest that that is the case. I do not have all of the details but I do know that it is not new to us. It has been the subject of a lot of discussion and a lot of work.

CHAIR—That civil aviation order was not pulled out of a Weeties packet, was it?

Mr Carmody—CAO 48?

CHAIR—The exemption.

Mr Carmody—And the exemption?

CHAIR—They just did not fall out of the sky, did they? They were negotiated; is that
right? They were legislated?

Mr Carmody—I do not know what year civil aviation order 48 was created. I would
suspect that any exemptions to that order would have been on the basis of a request from
someone and I presume, using our latest terminology, some sort of a safety case for evaluation of that.

CHAIR—And it would be CASA’s role to enforce that exemption; is that correct?

Mr Carmody—Yes, I would expect so.

CHAIR—If we have got a host of people sitting around a table under the guise of a
Standards Consultative Committee having some extended issues with a law, it tells me that
something is not working. I am asking you, Mr Carmody or Mr Wight, have you been vigilant in enforcing that exemption or that law?


Mr Wight—Through our normal surveillance process that would be something that we
would routinely check, the exceeding of limitations of how they have been recorded within
organisations.

CHAIR—Do you have to hand your hit record, or score record, or those that are behaving
and those that might be working outside it?

Mr Wight—I do not on me, no.

CHAIR—You may want to take that on notice, if you can, and provide that information to
the committee. But I want to come back to it now. We have got some issues and obviously
there is a representation of the pilots. And I would have thought that if anyone wants to work to safe flying times the pilots would have a large input into that standard. Would that be a fair assumption?

Mr Wight—I think probably some explanation about 48 is that it is a prescriptive
framework that does not necessarily best manage the risks and the fatigue associated with
work and duties associated with work and so the move to the FRMS, the fatigue risk
management system, allows operators to better manage their risks and for them to provide education to their crews about management fatigue as well in a less prescriptive environment.


CHAIR—If we have got a law now that states certain guidelines. Let us say the drink
driving laws and suddenly we raise it from .05 to .07 but we are still talking about it so it is
still all right to drive at .07. Are you trying to tell me that you have set some standards that
you are handed to enforce to make sure the pilots are completely and safely rested in between shifts, that it is not being adhered to and it is creating dramas, but it is all right to break that law?

Mr Wight—I would say that even under the current CAO 48 the operator is still
responsible for ensuring that crews are not put on line that are fatigued.

CHAIR—What if they are not?

Mr Wight—Sorry, could you—

CHAIR—What if they are not enforcing that law? Who does it then?

Mr Wight—If the crews who are going onto line are fatigued?

CHAIR—If the crews are working greater hours than what is prescribed under the
legislation, do we turn a blind eye?

Mr Wight—We do not turn a blind eye, no. If we are aware of the issue then we certainly
would not be turning a blind eye.

CHAIR—I would say that if we had been talking—I should not say ‘we’—if the Standards
Consultative Committee has been talking about these issues of fatigue management for the last three years, then I am forming an opinion here that you are well aware of it; it is not being adhered to—and correct me if I am wrong—but it is not being policed?

Mr Wight—I might say that there is an issue with the 48—

CHAIR—It sounds like there is an issue.

Mr Wight—The question that you are asking is that: are the crews fatigued within the
limitations of 48 or are they actually exceeding the flight time or duty time limitations—

CHAIR—I think I said very clearly ‘exceeding the times’.

Mr Wight—That was an issue if we became aware of that.

CHAIR—You are aware of it now and you have been aware of it. Mr Carmody said there
have been some issues around this for the last three years.

Mr Carmody—I did not say that. I said there were some issues around this. To be fair,
there are some issues around CAO 48. I did not quite say that there were some issues where we knew that people were exceeding the requirements of CAO 48. My point is that the committee which has all these representatives on it is actually trying to resolve this matter and a number of parties are very interested in it. We are trying to work on it and resolve it as well.

CHAIR—In that case, are you aware that CASA Complaints Commissioner, Mr Hart, has
also asked CASA for an explanation of why they, meaning CASA, have not acted? Are you
aware of that?

Mr Carmody—Yes, I am aware of that, but I am also aware of the view that all the
representatives of the Standards Consultative Committee on which the complainants are
represented agreed that this was the way through this NPRM process that this fatigue risk
management work would be done.

CHAIR—Can I ask you then can you categorically commit to this committee that you are
enforcing this exemption to the letter of the law?

Mr Carmody—I would like to review the evidence that the ICC has in front of them
before I make that commitment.

CHAIR—Isn’t it true that Commissioner Hart recommended:

… that the wording and hence the meaning [of CAO48E’s) definitions with respect to …flight deck duty are clear and unambiguous …


and that it is subsequently:

… not within the lawful prerogative of any operator to place or invent any other interpretation with respect to the meaning of those words.


Mr Carmody—I understand that to be the case. I do also understand that in responding to
the question that was raised with the industry’s complaints commissioner I do not think he
was aware at the time of the deliberations of the Standards Consultative Committee and that those who had raised the complaints with him were also aware of the deliberations of the committee.


CHAIR—Carry on.

Mr Carmody—I think had he been aware of the deliberations of the Standards
Consultative Committee he may well have responded differently but I cannot confirm that.

CHAIR—So that I am very clear on that has Mr Hart been misled, has he, or is he
confused?

Mr Carmody—Neither. My point was that he received a request and responded to a
request as far as I know within the terms of that request. What I am not sure he was fully
aware of was that this was afoot, this had been debated and that the Standards Consultative Committee itself had worked out a way through this mechanism and was working assiduously to get itself there.

CHAIR—The Standards Consultative Committee are working around something more
flexible; is that what you are trying to say?

Mr Carmody—That is right. A CAO 48 arrangement, if I understand it correctly, that
includes modern fatigue risk management principles rather than being very prescriptive,
trying to move away from a prescriptive nature to a more outcomes focused result, as we are with all of our regulations.

CHAIR—I have no problem with moving forward with the times. If that is the wish of
both sides of industry it is very hard to argue against, but if we have a recommendation—or, sorry, a law now, not a recommendation—how can you justify not enforcing it until a new one is in place?

Mr Carmody—I do not think I said that we were not enforcing it. I said I would like to see
what the details are.

CHAIR—Commissioner Hart has raised his concerns. Would I be right in assuming that
you have not implemented his recommendations?

Mr Carmody—I have not got his recommendations in front of me but I would say that we
are considering his recommendations in the context of the Standards Consultative Committee deliberations. That is my understanding.

CHAIR—You are saying that the breach has been committed because the FMRS rules are
being developed?

Mr Carmody—Without having the full details of the response, I am not saying that a
breach has been committed. I would be happy to take the matter on notice and look at what the ICC’s response has been. And I will look at the FMRS as well.

CHAIR—I will help you out. And the pilots association who represent the pilots are
making it very clear that for three years they have been bringing to your attention many
breaches. Sorry, I will rephrase that. There is not enforcement of that order.

Mr Carmody—Hmm.

CHAIR—Mr Carmody, we can sit there and ‘hmm’, but if we are talking about fatigue
management obviously there are laws around it for a very good reason and I want to get to the bottom of it. Perhaps this law is not being enforced. I am not talking about my colleagues on the committee here who happen to spend too much time on airplanes now but for the whole general public. We like to think that our pilots are safely rested and ready for duties. But if we have major operators who are getting away with not enforcing the law because they cannot do it themselves and the major enforcement body, CASA, is not policing it, it sends a very worrying message when the pilots are out there saying, ‘Hey, how many more times do we have to scream out: “Enforce the law.”?’ If a new one is negotiated and a new one is enforced, good luck to all. Would that be a fair assumption? It is now 3.30 pm and there is a long way to go. You have taken on notice and you are going to come back to the committee with the records that you have for whatever breaches there have been to this exemption; is that right?


Mr Wight—We can if—

CHAIR—I am actually asking you to take it on notice if you can and come back to us.

Mr Wight—I will take that on notice.

CHAIR—If it is possible to come back before we adjourn by tomorrow night that would
be appreciated. Does CASA believe it has discretion enforcing compliance with the
regulations under its authority?

Mr Carmody—I do not believe we have discretion.

Mr Wight—Not within the current CAO 48.

CHAIR—Why are you permitting airlines to not comply with the law?

Mr Carmody—If I may respond, as I have said before, I am not sure that we are. I would
like to review that information.

CHAIR—Okay. You did say that. That is fair and I will wait with bated breath for you to
come back with that information. Is it correct to say that if CASA were to enforce the CAO
48E definition then the operators would need additional crew to operate some of their
currently scheduled sectors and hence incur additional costs? Would that be a fair statement?

Mr Carmody—I would have to couple that with my previous response. I do not know the
answer to that.

CHAIR—Were such commercial considerations a factor in CASA withdrawing its initial
acknowledgement in 2005 to AIPA that the CAO 48E duty time definitions were being
breached?

Mr Carmody—I do not know the answer to that, either.

CHAIR—Take that on notice, thank you. Are there any other questions of CASA? If not, I
thank you Mr Carmody and Mr Wight and we will now call Australian Transport Safety
Bureau.

This was how the QON was cynically obfuscated answered some months later by Carmody & CO...  

Senator Sterle asked:

CHAIR—And it would be CASA’s role to enforce that exemption; is that correct?
Mr Carmody—Yes, I would expect so.
CHAIR—If we have got a host of people sitting around a table under the guise of a
Standards Consultative Committee having some extended issues with a law, it tells
me that something is not working. I am asking you, Mr Carmody or Mr Wight, have
you been vigilant in enforcing that exemption or that law?
Mr Wight—Through our normal surveillance process that would be something that
we would routinely check, the exceeding of limitations of how they have been
recorded within organisations.
CHAIR—Do you have to hand your hit record, or score record, or those that are
behaving and those that might be working outside it?
Mr Wight—I do not on me, no.
CHAIR—You may want to take that on notice, if you can, and provide that
information to the committee.

Answer:
Compliance against CAO Part 48 and any exemptions under CAO Part 48 is assessed
on all system audits. Enforcement action has been taken three times in relation to
CAO 48 since 1 January 2007. Requests for Corrective Action have been issued 26
times in the same period. CASA also undertakes a range of other administrative
action in addition to Requests for Corrective Action. Disaggregating this data is not
practicable at this time.

---

&..
Senator Sterle asked:
CHAIR—Commissioner Hart has raised his concerns. Would I be right in assuming
that you have not implemented his recommendations?
Mr Carmody—I have not got his recommendations in front of me but I would say
that we are considering his recommendations in the context of the Standards
Consultative Committee deliberations. That is my understanding.
CHAIR—You are saying that the breach has been committed because the FRMS
rules are being developed?
Mr Carmody—Without having the full details of the response, I am not saying that a
breach has been committed. I would be happy to take the matter on notice and look at
what the ICC’s response has been. And I will look at the FRMS as well.

Answer:
If a breach has occurred it would necessarily be a breach under the existing
requirements, not any proposed rules being developed by the Standards Consultative
Committee.

I still keep pinching myself to the reality that all of the above Hansard etc. was from over a decade ago and features the same bureaucrat (ably supported by the Iron Ring), who now sits in the CASA top job - Leopards and spots INDEED??!! 


MTF...P2