John With the parent directive up for review, I'm expecting that early replacement to CDM 2015 will follow agreement by the Member States that OF COURSE they didn't intend that TMCSD should apply to Martha Nussbaumer (Italian case). But HSE used this case as an excuse to rush through replacement regs. Even HSE's rather optimistic Final Impact Assessment for CDM 2015 says that the regs are going to cost domestic clients £3m per year. Not really a vote winner going forward.