Dick, I have to agree. From what I see, there is NO SAFETY BENEFIT in the change whatsoever. Did they do a Cost - Benefit analysis? If so, I would like to see it.....
The document is far too large and very difficult to understand. Obviously written by lawyers/legal support people that have very little or no idea what they are doing and what the unintended consequences are likely to be.
I agree strongly that it must be reviewed by a group that includes significant industry representation.
The PIR will be fun!! (Not)