BRC S&D New Standard

With the recent "what do you think" email regarding revising issue 3 of the standard, what does everyone think should / shouldn't be included?

My view was on contract packing module and how far reaching this is? At present our auditor says ok for open product in bulk being broken down into smaller packs but no mixing undertaken as this would come under food standard. 

Also so many clauses can be N/a based on setup it can be difficult to interpret just based on scope. For example we are N/a for section 5 as no own transport but this is not reflected in scope / exclusions. Should this be more clearly highlighted or not?

I look forward to hearing from you all

Thanks

Simon