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Re: inversor86 post# 16766

Wednesday, 02/20/2013 9:12:16 AM

Wednesday, February 20, 2013 9:12:16 AM

Post# of 22684
Read the last line of my last post.
Ever sine the proposed scheduling rule was published back in December, I have been consistent in saying that the the final rule would most likely be published at the very end of February or the first week of March.

The author of that article is saying the same thing, but I don't think he really understands the process. For example, there is no "45 day response period". DEA has historically taken between 20 and 65 days to publish the final rule after the close of the 30-day public comment period. So 45 days is about the average, but there is no "45 day response period". And it is an error to call it a "response period". After the public comment period ends, the DEA must review the comments received and take them into account when finalizing the rule. When the final rule is published, it must contain a summary of the comments received, and the DEA's response to those comments.

There are other technical/terminology issues with the article, like the author's use of "30 day hold period", when what he is referring to is the normal 30-day "lag" period between the publication of the final rule and the date on which it becomes effective. However, that lag period may be waived in Belviq's case, which would mean that the rule might become effective upon publication.

Any legal analysis I post may not be relied upon by anyone for any
purpose. If you want legal advice you can rely on, hire a lawyer.
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