it is an acknowledge method to use history data in safety management, the obstacle in china is the get the reliable and accurate accident data.
for the 主体层, the causal consequence relationship are not always as obvious as you stated, we have to distinguish the observable facts and our interpretation as well as the underlying cause factors. And the same accident(major accident which is a combination of several rare events ) are not likely to happen again,so we should go deeper to find the root causes which are always management and organizaiton related.These are recommended in Van Court Hare's hierarchy of order of feedback and Argyis' organizational obstacles to prevent efficient learning.
Also, if i was the author of 可靠性安全管理 theory, i would like to link this theory to the energy model and haddon's 10 strageties in accident prevention.