Comment from Bo Saxberg
AnonymousSupportBusiness
Summary: Dr. Bo E. H. Saxberg, representing DDO Strategic Services, LLC, supports the draft guidance and suggests a more nuanced classification system for protocol deviations. He proposes a 2x2 categorization based on importance and predictability (Expected vs. Unexpected) to better align with modern industrial process control and risk-based monitoring.
See attached file(s)