A37575; Re,
It is more the case that some of those in flight standards chairs are simply out of touch with real life accidents over the years. How many of these people assiduously read accident reports published in various journals such as Flight International, Aviation Week, Business & Commercial Aviation, NTSB and AAIB accident reports and a host of excellent readily available flight safety reading matter?
I think you express the issue very well. Yes, it is a problem and, I think, will become moreso as "SMS" becomes a reality and the regulator steps out of it's monitoring/auditing/enforcing role - another thread. We couldn't even get standards people to look at flight data from their FOQA program; - they certainly weren't spending time reading accident reports to see where the problems lie - a curious thing happens when someone goes into the office - they become a manager focused on costs and they lose "the aviator" in them.