It's a tragedy, but ultimately there is only so much we can do. The report says the mother left the bathroom "briefly," but we don't really know how long that was. Was the hair dryer already plugged in and lying nearby so the girl could grab it easily? Did she fetch it from elsewhere, plug it in, then climb back into the tub to use it? Perhaps a GFCI would have saved her, but then so would being taught not to use a hair dryer in the tub. I wonder if this was a one-off occurrence or if she had used the dryer in there before, or seen her mother do so.
Over here in the U.K. we've had the "no sockets in the bathroom" rule for decades. Our new code due out next year is to allow them though, but only if placed more than 3m (~10 ft.) from the edge of the shower or tub (which means that the average size British bathroom will still be "no sockets," since they're not that large). The outlets will be required to have 30mA RCD (GFCI) protection.
