The modern certification system has been in place for three decades. The effective date has always been the date that the last required information was sent by the measurer.
I know of no problems that this has caused, and I do not understand why a change is necessary.
The certifiers have always been trusted, and few problems have arisen from this. In the 1980’s when I was a newbie RRTC Chairman, I fired two certifiers. I had received complaints from measurers. One was taking money and not producing certificates. The other was taking a very long time to process paperwork. The firing was preceded by correspondence with the affected certifiers, pointing out the problems and requesting them to fix them. Neither did, and I replaced them. This option remains open to the Chairman.
In both cases I proceeded because of actual complaints from measurers who were getting inadequate service from their certifiers.
There are all sorts of bad scenarios that can be imagined, and it is possible to construct rules and regulations to prevent them, but this route leads to paranoia. I see no benefit in changing a system that has worked well for over 30 years.
There have been no problems that we have been unable to fix on a case-by-case basis, and those we have had to fix have been few and varied.
I suggest we back off on making more rules and policies to fix problems that have not yet existed.