Val, I look forward to suitable & sufficient hitting the Courts as it is not defined unfortunately in the order or the new guidance. The other vital term, significant findings is defined, but that definition varies from guide to guide and differs from that in ACOP to MHSW Regs.
So you don't like the FSC, ok but many FRS do send their IOs there as do many from other organisations. The FRA course does explain what constitutes S&S & SFs.
Unfortunately many IOs....especially those who attend other courses....wouldn't know what constitues a suitable & sufficient RA.......so how are they going to challenge one in Court..... and...."Many FRS insist, as a matter of course, compliance with the signs and signals regs."............
I afraid Val that the FRS cannot insist, unless they are prepared to serve a notice....and they certainly cannot prosecute unless employees are placed at serious risk.
I know many dinosaurs are still out there using the Bluff & Persuation Act but it is for the responsible person to determine what is required following his RA..........not the enforcing authority..............yes they can challenge his RA but I would recommend attending a suitable & sufficient training course.....perhaps one on prosecution procedures......before doing so.