It is in a way, because if it's functioning properly, you have people within the organization who theoretically are prepared to pass this information on without risk of reprisal, etc. I don't see how you're going to do that successfully in the absence of whistle-blower legislation, but theoretically that's what the objective is. You get this information, you accumulate it, you study it, and then you can identify risks.
That's the way they're planning to do it, I believe. Rather than having regulatory oversight on the operations, you're going to have regulatory oversight on the SMS program, in the way it runs.