(Sigh) here is one link. Here is an example of the fact that there is no such thing as a US SMS program as defined.

SMS Implementation and Practical Considerations for Business Aviation Operators | Universal® Operational Insight Blog

"You can be denied entry into an ICAO country if you do not have an active SMS program. For example, France is currently looking for an “approved SMS” from charter operators (when requesting permits). However, no U.S. operator can actually comply with this, as the Federal Aviation Administration (FAA) is not yet in the business of approving SMS programs. Also, Bermuda has been requesting evidence of SMS for private non-revenue operators. The problem is that there’s no real definition of what a fully mature SMS program looks like, and it’s difficult for anyone to gauge whether you have an effective SMS or not. So, non-compliance issues are hard to predict."

It is not right now, not until the FAA decideds what it looks like and publishes a rule.

You are wrong about your new QA program having nothing to do with SMS. For example the Advisory Circular has four "pillars" or components of an SMS program, one of which is Safety Assurance. I am betting you cannot link me to something that says that the QA program is NOT a part of an SMS, any more successfully than I can link you to something that says it is - which only proves my first point. But nonetheless, if a carrier chooses to use a crappy QA program for the SA, then so be it, they can, they are allowed to, as there is no definition of what it has to be. If they can show an IOSA auditor that the have a Safety Assurance program that is built around this QA thing, that satisfies that requirement.

Which takes me to my last point, which I don't want lost - to do any kind of program without the endorsement and acceptance of the pilots is really stupid. LOSA would be a better choice, on that we agree.