The A&P gives a basic level of knowledge as we would expect a mechanic in the UK to have after completing an apprenticeship ( used to be 4 years not 10 days). Once an A&P goes on to take his IA authorisation ( afetr 3 years) he has had more experience & is about level with the CAA license.
It is the FAA who do not allow A&P mechanics to get a start because of the training requirements. In the UK courses are 6-8 weeks, have a exam at the end & the applicant is required to have some work experience before being given a company apporval. In the US all one has to do is records 40 hours of OJT & he then has authorisation, less RII ( Dup insp). The FAA beleive that all the mechanic has to do is read the MM & follow the instructions. Great in theory but when there are tight schedules & commercial pressure, not a great way to ensure airworthiness. The FAA will fine a mechanic if he does not have the MM with him during a job but will not check if he can read English or understand the instructions.
Either way the safety records of both countries are similar & the only problem we face is the increasing shortage of engineers, how to attract new blood into the industry etc.
Simple solution - Pay more money.
Only one draw back is that engineers have never stuck together. Some often slag off pilots for their hours worked & pay but they get what they deserve, we should be getting the same but we need to stick together.