SMS systems only work if they have data that is meaningful. Each airline may seem to be swamped in data, that however is not the case for dealing with extremely low incidence, but high consequence events.
But I don't think this is a scenario that suffers from a lack of data. Near misses and incursions are frequent enough that they are well characterized. Nor is it that difficult to project risk from repetitive danger. The risk, in this case, and in many other cases, is known and has been accepted.