Is the RAFAC in a death spiral?

I’ve done some digging and apparently the “mandated training” in question is/was climactic injuries and FA. ACTO8 states FA training is mandated, and EFA must be completed within 6 months of joining. So obviously some are strictly enforcing this, whilst most are using judgment, unaware of this or ignoring it as it’s inconvenient to check for multi squadron events. TBH I can see both sides of doing this and would expect commanders to decide case by case, but if auditors are looking for this and chastising those who allow “untrained” cadets on an activity some commonality would be helpful