Stats can be used to "prove" anything you want.
As there is a direct corrolation between the size of hard disks and global temp, does that mean that hard disk size has lead to global warming?!
I wonder how many IMC rating holders have been killed during an approach? This would be telling info because this would determine if the approach is really so dangerous you couldn't trust EIR flyers to carry one out safely?
I knew a reasonably high time IR'd pilot who is now ashes scattered in the Pacific Ocean as he managed to fly into a mountain on an approach in a perfectly servicable aeroplane.
IO is right when he says the IMCr (or EIR...) would be self limiting. I wouldn't choose to fly in really !!!!e weather - A choice someone flying for someone else can't always make, which is why I reckon the "not authorised for public transport operations" would make a lot of sense.