In every community, every company, every association, every team there will always be around 5% "Mr Dodgies" who will obfuscate the rules, bend the rules, break the rules, spoiling their sport or industry for the majority. When you're trying for Zero problems/fatalities etc they'll fight you to the death, and have a million ways of staying under the radar.
In the case we are discussing where a Self Administering body is trying to improve conformity, it's always had to avoid going back to prescriptive rule yourself chasing them with new rules. The Audit is a good way of staying at arms length from law suits.
Self Administration works well,in that the dodgy people ultimately have to pay the price of their actions rather than the organization, but it would still be better if those accidents didn't occur.
Prescriptive industries have much the same problem with this rump which has turned avoidance in an art form. The Transport Industry is one of these, and about 25 years ago it introduced Fatigue laws for trucks and drivers of long distance semi trailers. They were ignored. The driver wanted to rest at the correct times but the managers usually suggested that they could, but they wouldn't get any more work.
Chain of Responsibility laws were introduced for that; they were ignored.
A National group of Prosecutors focusing on long distance transport was introduced, and have been quietly sanctioning management for a while, but of course the fines were claimed on expenses.
The Prosecutors stepped up ther stories in the transport media, explained how they work, explained who they were after; those Mr Dodgies. but they were ignored.
The results of one of their most recent cases has just been announced.
Four police officers who had jut pulled over a speeding motorist were kille by a truck driver high on drugs. The driver had been hallucinating and pleaded that he needed sleep but was told to do the trip.
The National Operations Manager was found guilty of failing to follow health & safety standards and jailed for up to 3 years. The company is no longer operating.