I knew I'd shoot myself in the foot. I originally wrote "isn't this standard R/T?" but changed it!
Anyway, I agree. On the face of it, pretty dumb not stating the level you are climbing to... The procedure is probably OK for the locals that are familiar, but the "occasional" international driver? Set up yet again. I'm not letting the crew off the hook; a few big stuffups on their part, but... Perhaps that contributed to the incident being waved off as a non-event by the American authorities... How close do they have to get before the investigations start??
The investigation should have picked up the lack of the "climbing to..." requirement; it seems the PM actually did what they were supposed to do:
not announce "climbing to 4000ft".
The report said they didn't follow SOPs WRT the Altitude Select:
Such action is not in accordance with the operator’s Flight Crew Operations Manual (FCOM) on “Flight Deck Preparation – Before Start” checklist. The checklist called for the assigned or SID limit altitude to be set in altitude window on the MCP.
But the crew didn't have (because they didn't see) the SID limit of 4000ft, so FL310 was the best thing to comply with the SOP...