As it turned out, Andrews' analysis for NOAA looked okay until 1999, when SeaWorld's procedures were inadequate to keep Daniel Dukes out of Tilikum's pool, where he died. And, of course, February 2010, when SeaWorld's procedures with Tilikum failed Dawn Brancheau.
Interestingly, the attitudes and views reflected in SeaWorld's permit application to NOAA are an echo of SeaWorld's response when its killer whale Keto, on loan to Loro Parque in the Canary Islands, killed trainer Alexis Martinez just two months before Dawn Brancheau was killed by Tilikum. In that instance, SeaWorld also ascribed the tragedy to the inadequacies and inexperience of a non-SeaWorld park, and after a brief pause in waterwork to investigate, resumed normal SeaWorld operations.
It would be interesting to know how SeaWorld management, knowing what they know now, might have responded differently to Terbush's queries about what SeaWorld had learned from Keltie Byrne's death and how it planned to handle the killer whales involved, especially Tilikum. They likely would never say. But the lesson seems pretty clear: no procedures, even at a park as sophisticated as SeaWorld, can guarantee the safety of someone working closely with killer whales. Which, of course, is what OSHA concluded after Dawn Brancheau's death, fundamentally changing the way SeaWorld operates.