Jim, I take your points but any attempt to improve safety seems destined to be mired in administrative process or pushed from pillar to post as no-one has the power to demand change.
If Transport Canada doesn't see the need to acknowledge the weaknesses of their regulations ie no requirement for NVG for this sort of operation, and there is no pressure on the operators to provide because it isn't 'industry standard' - unless litigation identifies blame, how will anything ever change?
Cultural change sounds pink and fluffy but is easily paid lipservice to and ignored by those with their fingers on the pursestrings - people dying in HEMS crashes on a regular basis in the US hasn't fostered a new culture - only regulation will do that.
Hoping everyone will play nice and improve safety for their own sakes is naive and not representative of the 'race to the bottom' that is often complained about on these pages about the helicopter industry.
I'm afraid that the concept of 'just culture' is flawed and only serves to give paper safety not real safety.