Yes, that's essentially it.
Normally, if you're going to impose criminal liability—or penal sanctions, if you want to put it a different way—there has to be an intent to carry out, or the negligence, which is the intent here. I'm trying not to sound too much like a legal nerd, so everybody can follow. There has to be that connection between the accused person and the act being carried out.
My concern is when an owner or a manager—especially when undefined—doesn't have that necessary connection. I'd like your comments on that.