I agree, that a more organized approach is to develop the framework for an Electrical Safety Program using the 70E Informative Annex E as a starting point.
But what I see is that companies decide to get into compliance, and then contract for a Power Study.
When we perform the analysis, we use our judgment as to what equipment gets labeled, and provide information on the labels to meet 70E requirements. We provide general training for unquailifed personnel, and more intense training directed at qualifying the appropriate people. In the training class we provide the framework to establish compliance with 70E, recommending that the facility designate a person as the Power System Owner (PSO) who is responsible for all aspects of compliance, to include: documentation; PPE mgmt; EEWP mgmt; LOTO; Preventive Maintenance; etc. If it's a large enough system, we will provide an SKM viewer package for use by the PSO in preparation of EEWPs, documentation, etc.
Mitigation is only considered for areas that are designated by the client as being interacted with.
So what I see, real world, is that 70E compliance starts with the Arc FLash Analysis.