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Comment Classification:

mE = minor editorial

ME = major editorial

mT = minor technical X MT = major technical



Old Wording:

-

Specific Comment:

I have already submitted formal comments on this release of the
standard, I will not proceed again as they were all democratically
discussed and rejected. I just take the opportunity of this ballot to
summarize my reasons for rejecting the new standard.

1. The main general concern is that ISA-88 and ISA-95 are largely
overlapping and no progress have been made trying to decipher the
respective positioning of these standards.

2. The different models (Physical, Process, procedural control) are
allowed to be collapsed and expanded, but more restrictions are
introduced and there seem to be no right anymore to ``rename'' part of
these models. Though there is a significant benefit of describing the
concepts behind each level of the models, the mandatory use of the
proposed names is an unacceptable constraint for leveraging this
standard in the actual manufacturing diversity.

3. (5.3.3): The straightforward matching of process and procedural
control models directly conflicts with the ISA-88 part 3 that
acknowledges the loosely coupled design between processing requirements
(not equipment-aware general recipe) and actual facilities capabilities
(equipment procedural elements) - a Process Operation can very well
match simultaneously a Procedure or an Operation in different
facilities. Part 3 even introduced the MRTC to realize the matching to
align a given facility design to a given processing requirement.

5. (4.4.3.4) There are still irrelevant constraints for equipment
allocation: whey a unit or an equipment module couldn't allocate control
modules from outside the Process Cell? This is the obvious way to handle
most transfers that ISA-88 persist not to take care of.

4. (5.3.4.4) The Equipment module is still prevented to execute anything
else than Phases - The rationale behind this constraint is still
puzzling for me.

6. (5.3.4.4) The identification of Recipe-Aware and Generic Equipment
modules add complexity simply to please software vendors or system
integrators that are unwilling to make their design more flexible.

7. (7.6.1) The ISA-88 batch schedule is no less than a ISA-95 production
schedule - this is a flagrant example on the many overlapping area of
these standard that the committees is try to hide or does not want to
acknowledge and treat accordingly

8. (8) the control Activity Model 100% overlaps the ISA-95 part 3
actovity model. Everyone knows that and this section should have been
totally dropped. This is another example of the above remark..

Suggested Resolution:

No resolution is achievable within the current consensual mindset in the
committee.

Name: Jean Vieille Phone: +33 6 74 45 47 27

Company: Control Chain Group FAX: +33 1 83 62 45 04

Street Address: 10, rue du stade Email: HYPERLINK
"mailto:j.vieille@controlchaingroup.com"
j.vieille@controlchaingroup.com

City/State/Zip/Country: 25560 Dompierre Date: 25/07/2010

Return your comments on or before 28 July 2010 to:

Charley Robinson, ISA Standards, HYPERLINK "mailto:crobinson@isa.org"
crobinson@isa.org

Comments on dISA-88.00.01

Ballot due 28 July 2010