2.- Lack of the 3rd part of the hazard analysis and the mandatory document (7.4.4)
3.- Training records of personnel responsible of monitoring activities
4- Validations (absence or incomplete protocol)
5.- No Updating of the system (8.5.2)
6.- No analysis of verification activities (8.4.3)
7.- Weak verification plan, specifically related to PRP and acceptable levels of the hazards.
8.- Non identification of external communication activities specifically those related to primary producers (antibiotics, pesticides, micotoxins, etc.)
About PAS-220
1.- No assessment on bioterrorism / sabotage
2.- No addressing of the requirements (or assessment about non applicability of some requirements)
3.- absence of one or more mandatory document
4.- problems on maintenance specifically on equipment related to control measures