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Sure safety tools are tools, however the X card in particular is a very bad one for live play.  Your system sounds like the best implication of the X card that i have heard, the verbal form is what I am against.  Where people gotta raise their hand or verbally say no, or there is someway for people to tell it was Gary who played the X card.  As someone who is disabled I hate having to be singled out because I am uncomfortable, there have been cases where speaking out about my uncomfortably has been more uncomfortable, saying that I'm sure the people I was playing with wouldn't have judged me or made shifty eyes at me but the irrational fear that they would kept me from expressing that i wanted what was happening to stop.

The other problem with the X card is that while I imagine you and other will uses this along side other tools and talking to players etc, the wider implementation of the rule is just to slap a band aid over the problem and never address underlining issues or themes with their players.  I feel there are better way we can design these tools, and even better tools out there in the world that already are a thing other than the X card.  Also some tools designed by marginalised people would be excellent.

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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.