Safety is a menacingly powerful word.
While many safety aspects can be quantified with historical data, assessment qualitative and emotional aspects tend to vary with the situation or implementation. I operated with SMS requirements throughout my career that ranged from, “How you will mitigate this risk” to “Prove to me that this risk won’t be realized”. Yes, you can be too safe. To say that openly casts shade on you and your organization. But good intentioned imposition of requirements in the name of safety can easily paralyze an operation. Some of the periodic reporting requirements alone in the NPRM will prove onerous for a small operation.
This is a companion discussion topic for the original entry at https://www.avweb.com/features/reader-mail/top-letters-and-comments-january-20-2023