I think you've laid out pretty clearly the argument about the requirements, about needing the staffing to actually do the oversight. I don't want to get into that, but the other two items you talk about in SMS are immunity from enforcement action and confidentiality for self-reporting.
I've been looking at the situation with the Cougar crash off Newfoundland. Would there not have been some sense of enforcement of a requirement to upgrade the equipment there, when it was clearly noted prior to this crash that the equipment needed to be upgraded? Shouldn't that have been the subject of an enforcement action?