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HIA Substitution protocol

Shelflife


Referees in Ireland
In the Northampton Bath game, Bath used ten replacements.

One of those was for an injured prop but the one I'm interested in was the Barbeary one.

Up to the 58th min Bath had used 5 subs they then Replaced no 8 with no 23 (substitution no 6) leaving a replacement hooker and SH on the bench.

No 23 received a head injury and left for a HIA on 60 mins, replaced by no 8 (temp replacement).

On 71 mins 16 replaced 2 (substitution no 7)

On 72 mins 23 failed his HIA so that substitution became permanent (substitution no 8)

On 76 mins 21 replaced 9 (substitution no 9)

Is it the case that a permanent replacement of a failed HIA doesn't count as a substitution ? Or did Bath make a mistake ?
 
There is this clarification (3) from 2018 which implies that it is ok, but assumes that it is after all normal replacements have been used. I can't find any further update since then.
20. If a player is removed from play for an HIA and that team have exhausted all of its substitutions, is a temporary replacement allowed?

Yes, if all substitutes have been exhausted a temporary replacement for head injury is allowed. If a player requires permanent removal following a head impact event, irrespective of the medical room classification, that is immediate & permanent removal or off-field screen, the player who is the temporary replacement will be permitted to remain on the field even if the injured player does not return after expiry of the 10 minute off-field period. To be clear a tactically substituted player can return to play to replace a head injured player, even if other replacements have not been used.
 
In my experience, this is right, with an exception for front row - even if subs are still available, a trained front rower who's been subbed out can still go back in if there are no unused STE front rowers on the bench.
 
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