Possibly. But the point is, there's practically no way they can scape-goat at lower levels over this: management's role is exactly to connect those dots (or, at least, put in the safety culture which ensures the dots are connected, and manage it appropriately).

A systemic failing like this, combined with the more relaxed attitude the FAA took with them, is probably about as clearly a management failing as they could get. I'd put it as even worse than the VW scandal: at least in that instance there were specific cases of malpractice / collusion.