I looked into the question of what counts as reasonable care and wrote up my conclusions here: https://www.lesswrong.com/posts/kBg5eoXvLxQYyxD6R/my-takes-o...
Also, while reading your article I also fell onto https://www.brookings.edu/articles/misrepresentations-of-cal... while trying to understand some terms, and that also gave some really good info, e.g. the difference between a "reasonable assurance" language that was dropped from an earlier version of the bill and replaced with "reasonable care".