So it sounds to me that the tool itself isn't the problem, but the implementation people have of it? I think a lot of people haven't been properly educated in its use, and that is a major concern. I doubt many people have looked at the documentation, and aren't using the rules of it because they never took the time to learn the rules.
Specifically to the second point: the Xcard is there specifically to negate the need for verbal response. As someone who has had to use the Xcard during a panic attack, it is much easier to touch a card, than verbally express myself, and I think that's kind of the point? That while it might still be difficult, it is easier than the alternative.