Suggesting an action to mitigate the failings of society is not the same as blaming those societal failings on women. If someone organizes a group of women to try to pass better rape laws, are they blaming the victims for not lobbying enough? Why is it that suggesting anything to help until the situation gets fixed makes everyone assume you don't want the situation fixed?
I'm not defending or attacking his position, I just think these hair-trigger accusations of victim-blaming are harming your cause far more than they're helping, since they make people tune out actual victim-blaming. Regardless of the merit of his suggestion, its silly to say he's blaming the victim when he's not, and clearly didn't intend to. It would be perfectly acceptable to actually argue against his statement, but this "anything that isn't focussed solely on changing society is victim-blaming" is getting ridiculous, and trivializes the disturbing reality of actual victim-blaming. (for example, the quote I read the other day which said "something like that doesn't just happen, she must have done something to get herself in that kind of situation").
As a disclaimer: I don't think his suggestion is a realistic solution on a widespread basis, though it may be helpful in individual cases. Just because someone might suggest, for example, that their sister carry a gun if she goes to the red-light district at night, doesn't mean they're going to blame her if she doesn't carry and gets raped.