‘Lame’ joke in lift, or offensive comment in workplace?

The problem lies in the rules of the ISA, where a subjective complaint - 'how this made me feel' - is regarded as constituting an objective offence requiring an apology which admits the words uttered were offensive. An apology from Lebow saying 'I am sorry if the words I spoke were offensive to you' will not do. He has to say 'I am sorry for my offensive joke'. Since he genuinely believes his joke was not offensive in intention or effect, this would require him to tell an un-truth to resolve the issue. One remedy would be to apply a 'right-thinking persons' test, as in libel law. But it is hard to try and imagine any generally-held point of view when it comes to jokes like this.