HC - excellent work, 'paper safety' is exactly the right term; management devise box-ticking exercises, spreadsheets and colour-coded charts, using them as metrics to show how well they are managing the risks without actually spending the money required to remove or reduce them.
Sadly the military has gone down this same road with the MAA and a safety management scheme which is delivered with religious zeal - it is mostly arse-covering so no-one ends up in court, generates a massive amount of staff work and doesn't actually make anything safer at all.
Perhaps the parallels are there with the NHS - layers of management proving govt targets are being satisfied by ticking boxes but not enough doctors and nurses to actually treat the sick people.