That seems too simple to me. Can they afford to test enough rockets to empirically validate an acceptable failure rate for high-reliability components? If it should fail 1/500 flights, for example, how could they validate that in testing?
ULA has over 100 launches without failure; SpaceX's record is around 19 out of 20. My understanding is that SpaceX will need to reach ULA's level of reliability to succeed, especially to launch humans.