It’s unclear how soon it could be “practicable” for DHS to apply revised personnel policies more widely, given that a federal district court has issued an injunction against the labor relations, adverse action and appeal rights provisions as they were published as final rules. A federal appeals court last year upheld that injunction, although it said that the planned changes in appeal rights were not yet ripe for a decision since no one has been subject to discipline under them. Should DHS put those provisions into place—largely involving shortened timeframes for appeals and less discretion for MSPB to overturn management actions—unions could file another court case as soon as they could prove someone was harmed by the new procedures. Numerous pre-existing labor contracts that will not expire for some time also could stand in the way, and if the DHS plans get put on the bargaining table, the process could be prove to be a slow and contentious one.