To answer your question more broadly, I think we just need to agree to disagree. I don’t see anything in your reply that addresses the fact — sorry man, it’s a fact — that TOR’s actual text never discusses how to adjudicate failure consequences. It’s just not in there. In fact I will repeat the entirety of the RAW right here:
If the acting player fails his roll, he doesn’t accomplish his objective. When this happens, the Loremaster narrates the consequences of the missed task. This usually follows intuitively from what the player was trying to do.
First graf comment: “this usually follows intuitively” to me is a signal that this is a fiction-first failure: if you failed to sing a song that rallies your friends, then your friends aren’t rallied; if you failed a Lore test about what lives inside Mirkwood, then you misremembered.
Whatever the case, the Loremaster must make sure that the task as a definite impact and produces consequences that cannot be ignored.
Second graf comment: Marvelous! Yes, good, no whiffy failures. Everything has “a consequence.” But based on my first graf reading, close reading to me says “make sure it appears in the fiction” and a broader, more charitable reading might maybe fold mechanical consequences into that. But it’s not actually there. I have to guess that it’s there, and Tales seems to imply that that’s okay.
Also, I’m not seeing in TOR Rev that the Hazards table is “a suggestion.” Page 160 says roll and apply the consequences. They’re explicitly not suggestions, although maybe they were in 1E? (The narration explaining the intersection of Role + Hazard, now those are “suggestions.”)
All this said, I think I’ve got a workable solution for my own game and I don’t need to keep going down this rabbit hole. It’s pretty obvious to me what their intent is and where the writers are coming from.