That also doesn't include those decisions judged to be wrong on-field but 'correct' in terms of a (non) VAR intervention. Using those, the numbers are really big. For example, against Brentford, the panel said Carlos should have got a pen on field but VAR was correct to not intervene, so it's not an error. But that error isn't added anywhere.
The explanation for a lack of intervention by the unofficial VAR spokesman Dale Johnson is that the fall for the 1st one doesn't reflect the force of the kick. But when you review it in slow motion, it looks not a lot. But I've been booted on the ankle like that, even not as a foul and it's painful. Add to that he's nowhere near the ball and it's a pen.