I see the logic, and I hope it works. The problem, as always, is people, and the need for culture change that goes with any program designed to achieve compliance. In the energy industry we went through three decades of painful change and we're still not there: its an asymptotic curve that started with us trying to engineer out hazards, then the "management standards" generation, followed closely by QA systems. We're now in the "Hearts and Minds" stage - the space I now work in - where people comply because they want to and understand why they need to - not because they get beaten with a stick. Its a journey, and it takes time.