What you're saying is true, and when riding in those conditions I choose to wear a high-vis and helmet.

Nonetheless it is victim-blaming to make it mandatory (nevermind doing that in broad daylight). There's always more that could be done ; clown hat, flashing lights, police escort, machine guns, F-35s. We have to draw the line somewhere, and if headlights are good enough for cars, they're good enough for cyclists. Cars would also see fewer accidents if they were covered in high-vis paint, yet curiously no-one is arguing for mandating it.

Where I'm from, you are required to adjust your speed to visibility.
If someone has trouble seeing cyclists who have all the required visibility measures, they are driving too fast, or shouldn't be driving at all.

It's hard to see this as anything else but allowing drivers to drive faster at the inconvenience of cyclists, under punishment of a felony.

Funny, the job site comparison is also in the article:

Cannon said: “In every other hazardous environment, particularly workplaces, we apply an internationally recognised hierarchy of controls: eliminating danger where possible, engineering risks out of the system and separating people from hazards. Only as a last resort do we rely on personal protective equipment. On our roads, we invert this logic entirely, skipping straight to: ‘Be visible’ and ‘Watch out’.”

I suppose pedestrians need hi-viz jackets, too. And a siren on their head.

Put hi-viz jackets on squirrels and deer, too.

Put a warning sign on every tree.

Or, you know, hold drivers accountable for their actions instead of letting get away with literal murder.