1. The Order needs to match the Policy-this is hard to judge without an approved Policy. The Order should describe 4 levels of oversight and the Order should include the 2004-1 IP figure on Oversight showing the 4 levels. 2. A "shall, should, may" matrix needs to be prepared to clearly identify the requirements contained in the order. Many parts of Section 1, Requirements, of Attachment 4, do not contain requirements, and should not be included in this section. 3. The order should identify where other orders have already established related requirements. The order repeats too many requirements that appear elsewhere. These requirements and their sources should be referenced, with only top level requirements in the Order. 4. The magnitude of the changes needed to this Order appear to merit a re-issuance in RevCom after changes are made.

Editorial
1. The Order needs to incorporate more guidance and requirements by reference, rather than repeating or revising it. 2. The basis for the list of orders to be changed is unclear. For example, why does P 450.4 need to be changed? Why does O 414.1B need to be changed? It seems very irregular to include requirement 4.a.]]>