Excellent point Mike. And with your extensive mod Building experience, you would know better than most. At the risk of repeating here is the timeline.
- The clock starts ticking the day the Final Rule is published in the Federal Register which has not yet occurred but per the FDA will occur on 5/10/16. Nothing will change from the document we are reading today.
- Vendors/Manufact etc have 90 days from the Publication date of 5/10/16 for introduction of new products which is the issue you raised along with others.
- The clock starts clicking on the Congressional Review Act and Congress has 60 days from the Publication date to reject/modify the Final Rule. NO extensions. IMHO, doubtful they will accomplish anything but I could be wrong. If they do nothing or wonder around in the bushes and can't accomplish anything then the Final Rule becomes the law of the land 90 days from the Publication Date in the Federal Register.
Edit for senior moment
When does Congress go for summer break? Memorial Day? July 4th? I have a feeling that Congress will do nothing before the election. Sigh...... Great timing for Obama and the FDA.