Partial Revision Methodology
Partial amendment” does not mean amending only one part of a law or regulatory requirement. When amending a law or regulatory requirement, there are two methods: “full amendment” and “partial amendment.” Full amendment is an amendment method that rewrites the entire text of the article.
On the other hand, partial amendments are made in the form of a “kai-me-bun” (also read “arame-bun” or “kai-me-bun”).
In other words, it is a form of “revise ~”, “delete ~”, etc.
Thus, it is not the case that the amount of revision is greater for all revisions and less for some revisions.
So what is the reason for the partial revision? The main reason is to keep the article numbers the same.
If the article number is changed, the referenced article number of the procedure or other document that refers to the relevant law or regulatory requirement must be changed.
If the chapter numbers in the GMP and QMS Ministerial Ordinances are changed, this is expected to be a major revision process.
To avoid this, the recent revision of the GMP and QMS Ministerial Ordinances seems to have taken a partial revision approach.
In the partial amendment method, when a requirement (bullet) is added, a section number is added, for example, Article 3-2 or Article 3-3, and no change occurs to the existing article number.
Note that the revised text has the advantage of being able to clearly and simply express the points to be revised, and has become a well-established method of amending laws in Japan.
On the other hand, it is difficult to see at first glance what has been revised and how.
In an attempt to improve this point, it has been proposed to use a table comparing the provisions before and after the revision (old/new table) as the revision method, and the old/new table method is currently used in some ministerial ordinances.
In the case of a law, the old/new contrast table is positioned as a reference material for the revised law written in the revised text format.
In the recent partial revision of the GMP Ministerial Ordinance, the old/new comparison table was also used. It is important to note that the old/new comparison table omits the articles that have not been changed.
(Reference: Council Legislation Bureau Column, “Revised Text -Formula of Partial Amendment of Laws and Regulations- )
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