Comment #1Amendment: Proposed MINHERS Addendum 32f, Amendment Effective Dates, Transition Period and Publication, Draft PDS-02Page Number: 6-7 of the draftParagraph / Figure / Table / Note: 502.4.1Comment Intent: ObjectionComment Type: GeneralComment: Given that the Effective Date is the date by which Approved Software Tools must have already implemented an amendment, and given that an amendment’s Publication Date could be 31 days before the default Effective Date, software vendors may be asked to implement a new software release in less than 30 days. This timeframe would be extremely aggressive for normal software release planning purposes. Granted, the SMB has the option to allow additional time per section 502.4.2.3, but NORESCO believes that a more reasonable (but still aggressive) default cutoff would be 60 days. This longer timeframe at least allows for an opportunity to see the published amendment, evaluate the work to implement it, and make a request to the SMB if necessary, all while working to meet the Effective Date deadline. Proposed Change: 502.4.1 The default Effective Date for an amendment shall be the January 1 or the July 1 following its Publication Date or, if that date is less than 3060 days after its Publication Date, then the January 1 or the July 1 that follows.
Given that the Effective Date is the date by which Approved Software Tools must have already implemented an amendment, and given that an amendment’s Publication Date could be 31 days before the default Effective Date, software vendors may be asked to implement a new software release in less than 30 days.
This timeframe would be extremely aggressive for normal software release planning purposes. Granted, the SMB has the option to allow additional time per section 502.4.2.3, but NORESCO believes that a more reasonable (but still aggressive) default cutoff would be 60 days. This longer timeframe at least allows for an opportunity to see the published amendment, evaluate the work to implement it, and make a request to the SMB if necessary, all while working to meet the Effective Date deadline.
502.4.1 The default Effective Date for an amendment shall be the January 1 or the July 1 following its Publication Date or, if that date is less than 3060 days after its Publication Date, then the January 1 or the July 1 that follows.
Return to Proposed MINHERS Addendum 32f, Amendment Effective Dates, Transition Period and Publication, Draft PDS-02