As I read this, I reflected that most of the regulatory programs overseen by my agency are like this--self-policing and self-reporting. That is, Southwest's response is the expected response under this kind of regulatory approach, rather than being something extraordinary.

To the extent we look at enforcement under this regulatory approach, it is for not only willful non-compliance, but also for failure to report non-compliance, failure to regularly monitor for non-compliance, and failure to correct identified non-compliance in a timely manner. For our facilities, failure to identify the problem inspections for more than a year would represent a significant issue that could lead to enforcement.

It's possible to have a more involved model with more extensive government oversight and staff review, but that model is much more expensive to regulated parties, and often enough, without a concomitant increase in regulatory effectiveness.

-Hayden