Yes, this is the typical nuke methodology. Make the tail wag the dog.
The concept is simple, but we geniuses can't help but to make it as complicated as possible.
The only reason in the world why you would need to track PCE's is to learn how and why they occur so that you can prevent them. PERIOD.
Do we do that? No. We count them, track them, analyze them, and do anything except use this information to help us improve our methods.
If you are counting PCE's as though the number itself was indicative of anything, and hammering people or companies based on this alone, you might as well be that guy with OCD who counts parking meters or pickets in a fence. Instead of worrying about how to get that number down, you need to look at what the number is telling you.
PCE's can tell you lots of things. They can indicate that your survey frequency is inadequate, or your maintenance program, or your protective clothing requirements, or maybe that your workers aren''t getting the right training, ...etc.
Should you count PCE's on modesty garments? Well, is there something they can tell you that you would not otherwise know? I would want to know as much as possible, but putting too much emphasis on the number of PCE's leads us to try to ignore some of them.
So, it really doesn't matter if your plant and the next one are "playing by the same rules". What matters is that you get a grip on the cause of the events. If you do that, the numbers will take care of themselves.