It is also not recommended to generate random numbers from javascript. Read
This used to be the case 20 year ago, but today browsers come with secure RNG seeded with device's entropy. Wallets like MEW use it and it's not a problem.
OP, why not use Shamir's secret sharing? I think Ian Coleman has mnemonic tool for that, and it would allow for a better setup than this. Currently you have a seed which is useless alone and passphrase that is impossible to memorize and is useless alone. But with SSS you can create N of M setup where each shard is equal and you don't need them all to get the key.