last chance to challenge new 2257 regulations

[basschick]

this is the url for public comments regarding the new 2257 regulations.

http://comments.regulations.gov/EXTE...TOKEN=32402361

if you can think of a comment, please send it to them. the calmer and more well thought-out our comments are, the more chance they will be effective.

i see many more effective ways to keep track of i.d. - and the new regs don't take holidays into account!!! you need to be in that office from 8 - 6, mon - fri, period the end.

seems like we could all register our sites and content with an agency, or all producers could and we could use their registrations. or we could have all i.d. in a special folder on our servers that is only open to the government. i'm sure that would take less man power than in person inspections.

[Lee]

Or there is always another option of a central library

Our lawyers are actually assessing the 'legalities' of this option now for us :thumbsup:

Initial details though do seem to be promising for this option :angel:

Regards,

Lee

[basschick]

not unless the new 2257 regs are changed - 2257 very clearly states that the 2257 info be stores at the producer's primary place of business - and the same rules apply to secondary producers as producers.

the problem is that i've heard from several lawyers in our industry, and they're not all saying the same things as one another. these new rules have no history of enforcement or interpretation, so i suspect some of what they are saying is guess work based on prior similar situations. and it isn't our lawyers who will go to jail if what they tell us is wrong...