Comments sought on the developments on the HSE's Fees For Intervention scheme

The Fee for Intervention (FFI) scheme that the HSE are presently following has come in for a lot of criticism.
Latest news on this is:

• Income from FFI during the 2013/14 FY was £12.3M.  As their budget was £17M, this represents a shortfall of £5M.
• The budget for FY 2014/15 is £23M, so we can expect things to get worse.
• HMRC has just stated that as FFI is not a fine (though it smells like and fine and looks like a fine), fees for intervention are tax deductable.

So, if FFI is a non-starter, how are the HSE going to generate income?

In the next few months HSE will begin testing with possible customers the market demand for a fully-chargeable inspection service for organisations with mature health and safety management systems.  In other words, if you are confident enough that you are in control of health and safety, you can pay the HSE, ie the people who could charge you under FFI or prosecute you, to carry out an assessment of your safety measures.

I offer the following comments on this:

1. At an IAC meeting a few years ago, the HSE suggested offering free visits to companies to give advice. The concept of inviting the HSE into your company, no matter how confident you were was greeted with laughter.
2. You would need a lot of companies to make up £23M.
3. If you are confident enough to invite the HSE into your company, there will be probably be little benefit from improvement suggestions they make. So the only benefit would be if the HSE scheme had a "kite mark" type of output that companies could shout about.  My experience with the HSE is that they have been unwilling to endorse or certify organisations, so I can't see this happening.
4. Were the HSE to issue a "kite mark", how would this square with their role of being an inspectorate, ie being the policeman? Surely there would be a conflict.

I'd be interested in people's opinions on this.