Comment
Keep the original implementation date.
The Regulation 406/19 has a long history through draft versions, discussions at ESEG meetings, ERO postings, etc. The original implementation dates have been postponed before. The Jan1, 2022 has already passed and some groups have implemented new practices. Human's and their organizations have a tendency to put off actions until they are urgent. Pausing the implementation date will likely pause any implementation activities.
Keep the Jan 1, 2022 implementation date, but temper the enforcement of violations with warnings if progress towards compliance is demonstrated.
Submitted March 16, 2022 2:55 PM
Comment on
Implementation Pause of Excess Soil Requirements in Effect January 1, 2022
ERO number
019-5203
Comment ID
60232
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Comment status