select
    OD_NO,
    COMMENT,
    CNT
from
(
select
    ORDER_NO as OD_NO,
    SLIP_COMMENT as COMMENT,
    (LENGTH(SLIP_COMMENT) - LENGTH(REPLACE(SLIP_COMMENT, ',', ''))) + 1 as CNT
from
    ORDERS
)
order by
     CNT desc,
     OD_NO desc