I'm going to ponificate again, but there will be a point at the end I promise.
Accident stats are becoming available in Japan but the history is limited, and as Mar Scuba points out the majority of incidents that don't result in severe injury or death are not reported for fear of adverse publicity.
Diving accident stats from DAN around the world, and BSAC in the UK suggest that 80% of all diving related accidents occur at the surface, and the majority of those are boat related.
That said, focus here is the dive operations, not just those that also provide boats, and O2, EAPs, good breifing materials etc should be universal requirements.
An interesting point is that point is that dive shops (ie people or organisations that provide instruction and guide services) carry all the legal responsibility, while dive operations (ie people that provide tanks, boats, and other facilities) have almost none.
The problem here is that the dive operations control most of the important factors in accident mitigation. Dive shops rarely have any control over tank type, quality, or fill, boat procedures or entry and exit methods.
There have been several incidents in Japan over the past 5 years where, following a serious incident, the Dive shop has been forced out of business, while the Dive Operation which was the root cause of the accident have continued largely unscathed. More importantly perhaps, with out learning from their mistakes either. This is sort of chicken and egg, the legal persuit of the dive shop is because they have liability insurance while the operation does not, but in the public's eyes the dive shop must have been responsible beause they were the ones legally persued.
Once again the above is most relevant to the Tokyo/Izu/Chiba area were there is a clear distinction between Dive Shop - Dive Operation - Tank fill services. It would seem that elsewhere the situation is more vertically integrated, as it is abroad.
So I guess my point is that Dive Operations should also be required to carry liability insurance just like DMs and Instructors, even if they only provide tanks and boats.
Given the widening scope of this thread I'm changing the provisional name of our proposed standard to "DiveSafe" until someone comes up with something better.
Titan