Ah - good spot!
Anyway, it is short and not too sweet. Although it is a valid point, it seems a little picky. I remain unconvinced that a passenger, already submerged in icy water, had the clarity of thought to say "no point in deploying the rebreather because I forgot to take a breath prior to being submerged", or, following implementation of this AAIB recommendation, would now say "oh dear, I seem to be underwater with empty lungs (having miraculously resisted the gasp reflex), I'd better deploy my rebreather and use the air in its cylinder".