Just a heads up, I won't be giving any direct answers to requests for change - I'm not a subject matter expert on some of this stuff. What I'll do is take your feedback, constructive criticism, suggested amendments and reasoning, then put it to the group (led by Angus Willison, our Safety and Technical Officer), who will consider all the information for the new regulations. Anything that is a serious safety concern can be addressed prior to the new regulations in 2021 and an amendment issued if warranted.
Andrew