I don't think it is so much about them making their own rukes as much as it is about having some pretty ordinary staff on the ground trying to interpret and apply them. Unlike a few others, I actually think MAF is trying to do the right thing in a general sense, but they just aren't very good at it. I know a little bit about their recruitment practices and training and I think it would be fair to say that they tend to take pretty much anyone who got a C in high school biology - or knew someone who did. A lot of the inspectors have a pretty thin grasp the areas they are supposed to know about and what they are looking for, and tend to hide behind the rules rather than appear incompetent - and like all government departments, they tend to have some pretty onerous paperwork attached to the simplist of processes. It is just a pity that they don't actually have knowledgable staff who are empowered to make some decisions 'on the ground'. That way the whole process would be a lot faster, fairer, and more transparent. Don't hold your breath though...