Andy, logic is on your side. This isn't about logic, however. Each manufacturer's "Virginia" needs its own approval. Anything that has its own SKU, or product number, needs its own application (with the exception of grandfathered items, provided they've had no changes.)
It's not hyperbole - it's how the regulations are written. I doubt they will stand as written, but that's how they are now.
It's not hyperbole - it's how the regulations are written. I doubt they will stand as written, but that's how they are now.