The main problem seems to be that CASA is trying to treat the Sport Aviation bodies like the Commercial/Charter Organisations. Has anyone asked CASA how are they going to implement their SMS with their PPLs?
GFA has always had an SMS (although it wasn't called that as such) with the club structure delivering ops review through peer pressure, Instructor Panels, Club inspections and Ops panel review of accidents/incidents. GFA has recently rolled out a documented SMS as part of the CASA/GFA Deed of Agreement (which incidently in quantum does not go half as much as it cost GFA to do all of CASA's work on their behalf).
You can see the outline at: http://www.glidingaustralia.org/Operations/OPS_0025.pdf
and the risk management toolkit at: http://glidingaustralia.org/Safety/risk-management-toolkit.html
GFA's big advantage is that every member is attached to a club, which delivers peer pressure and standardisation, whereas RAAus and HGFA can be unsupervised as soon as they reach certification and operate outside FTFs.
I hope RAAus members apply the same peer pressure, as they have to their fellow administators, to their fellow pilots that need counselling in their operations......