Sorry HC, the maths head is not awake up here in NL, only got 2 cups of Java in me so far today, but as you stated the fleet hours just don't cover the requirement and/or the spirit of the clause.
Dan's recent post, #1845 on this thread, highlighted 250,000 hours, a long way away from 2 x 10^7...
My point was sometimes statistics is not the best metric to use, how about good old make it super-safe and non-ambiguous?
Zalt's post got me thinking back to how quickly the TSB homed in on the studs in the first place...surely any relevant incident with this AC type should be included in the Wells inquiry, including a Canadian investigative bodies involvement?
Safe flying
Max