Template for comments and secretariat observations Date: 2007-08-30 Document: DIS 29500 – OOXML PAS
 
1 2 (3) 4 5 (6) (7)
MB1 
Clause No./ 
Subclause No./ 
Annex 
(e.g. 3.1)
Paragraph/ 
Figure/Table/Note 
(e.g. Table 1)
Type of com-ment2 Comment (justification for change) by the MB Proposed change by the MB Secretariat observations 
on each comment submitted

ZA General   ge The overwhelming majority view of the South African committee is that the scope of the overlap between the proposed standard and the existing ISO/IEC 26300 standard is significant.  A significant majority view is that South Africa sees no benefit in adopting another standard for document formats in this area.  Notwithstanding this view, and noting the limited time available to adequately study a specification of this length, the South African committee has detailed a number of technical defects in DIS 29500 which has informed its decision to not support its continued progress through the fast-track process. Given the extensive public interest that has been shown in this process, the South African committee has noted the extensive comments contributed by IBM and others that have become available in the public domain.  We have studied these and concluded that, whilst we consider many of these to raise significant concerns, there is no extra value to be gained by repeating, via our comments to JTC 1, such concerns with which they will already be familiar.  Whereas the comments submitted by South Africa are selected to highlight specific concerns, they are not exhaustive.

Even for a highly technical document the proposed standard is extraordinarily convoluted, idiosyncratic and lengthy, making any attempt at compliance difficult. Failure to comply by a developer may however expose the developer to an intellectual property infringement claim.

   
ZA2 General - te The name "Office Open XML" is often mistakenly called 'Open Office XML” implying a connection to the OpenOffice project which does not exist. This naming confusion has been documented and has occurred numerous times, including by analysts and even in Microsoft press releases and blogs. Since “Open Office” is the pre-existing name, by 6 years, Ecma should choose a new name, less apt to continue this confusion. Change the name of Office Open XML to a name which is not confused with OpenOffice.  
ZA3 General - te From the overall document contents, it is acutely clear that no effort has been made in OOXML to start from the existing ISO standard for the representation of documents in XML, that is ODF 1.0, ISO/IEC 26300:2006. We can see no reason for that deliberate departure and contend that unneeded differences are harmful. We therefore request that the OOXML proposal be rewritten starting from the existing standard. Rewrite OOXML starting from ODF 1.0, ISO/IEC 26300:2006, for all matters that apply.  
ZA4 Overview, p1, Purpose of the Standard   ge It is stated that the standard was designed “from the start to be capable of faithfully representing the pre-existing corpus of word-processing documents, presentations, and spreadsheets that are encoded in binary formats defined by Microsoft Corporation”. Creating a new international standard for 'faithfully' representing legacy documents is neither necessary nor desirable.  The South African 'corpus' consists also of a significant number of documents in formats such as WordPerfect and Ghostwriter (for legal texts).  It is not suggested that we promote new ISO standards for each of these. This and all other references to particular vendor  legacy implementations be removed from the document..  
ZA5 Part 1, Appendix   te The reference given for the Zip format does not provide a date or version, though this specification is frequently revised,  The current lack of formal standardisation of the zip format is something which causes problems for a number of standards and specifications which are based upon it (eg. jar, scorm, odf etc). Reference should be made to a particular dated and labeled version of the ZIP format. 

Removal of OPC from this specification and developing it separately, formally and thoroughly, as indicated above, would receive considerable support if it contributed to solving some of the current problems around the specification of zip containers.

 
ZA6 Part 2, Open Packaging Convention   ge The OPC is not dependent on other parts of Office Open XML.  The specification clearly has applicability outside the confines of OOXML.   Indeed the same OPC is used by the Microsoft XML Paper Specification (XPS) which is also being developed by ECMA The Open Packaging Convention (OPC) should be separated from the, already bulky, DIS29500 and presented for consideration as a separate standard.  There is a significant need for an international standard in this area.  
ZA7 Part 3, Section 2.18.3, p90 22-24 ed This sentence is grammatically incorrect and has no meaning in its current form:  “When the resulting Word processing ML package is opened, the HTML document it could be read (if it is an alternate format understood by the consuming application) and migrated into the appropriate location in the main Word processing ML document.” Redraft the sentence correctly.  In such a large specification there may be many similar errors.

Ensure that enough time is allowed to give the entire proposed standard a thorough review.

 
ZA8 Part 4, pp5-1854, WordProcessingML Reference Material   ge Implementation of this subject matter may depend on licensing essential claims of patents issued by the South African Companies and Intellectual Property Registration Office  to Microsoft Corporation, for example ZA200303346 “Word-processing document stored in a single XML file that may be manipulated by applications that understand XML”.   The committee was also of the view that there have been sufficient concerns raised about the robustness of the Microsoft 'Open Specification Promise' and the Microsoft 'Covenant not to sue' as to warrant caution. The patent holder should be encouraged to disclose, and explicitly licence or surrender such IP or patents that may pose a risk to implementation of the standard.  
ZA9 Part 4, Section 2.15.1.28   te The document prescribes its own set of hash algorithms, which are known to be weak, in the face of existing internationally accepted standards such as 'Whirlpool' (ISO 10118-3) and SHA256, SHA512.  The use of such 'home-grown' algorithms, presumably for legacy reasons, is in contradiction to the South African Government's Minimum Interoperability Standard (the MIOS, available from http://www.dpsa.gov.za). Use an algorithm which is compliant with existing National and/or international standards.  
ZA10 Part 4, Section 2.15.1.86 - te This element uses a bitmask to specify a style display filter. The use of bitmasks rather than a set of boolean types makes this data almost impossible to work with standard XML tools like XSLT which lack bit-level operations. Rewrite this subclause to express the feature using XML constructs rather than bitmasks.   
ZA11 Part 4, Section 2.15.3 - te The “compatibility” settings solve no general problem.  No allowance has been made for legacy settings from other applications. Remove the compatibility settings from OOXML.  
ZA12 Part 4, Section 2.15.3.26 - te This is the “footnoteLayoutLikeWW8” element, which is defined in terms of mimicking a legacy application's behaviour. The standard contains insufficient detail on how to replicate this behaviour. Define the intended behaviour.  There are many instances of elements like this in the document which make it impossible to do an independent implementation.  
ZA13 Part 4, Section 2.18.4   te It is a requirement of an international standard that it is developed to meet the needs of a broad international user base.  The embedding of culturally specific iconography into the xml, as for example the ST_BORDER_ART tag  is both a technical deficiency as well as culturally inappropriate.  The reference to a series of styles as 'tribal', 'tribal1', 'tribal2' etc reflects an ethno-centric, Victorian anthropological classification of art which has no place in a modern international standard. Provide full normative definitions for all graphical elements, preferably with appropriately licenced SVG reference images.  Use such hard-coded graphical elements minimally to represent lines, bullets, dashes etc.

Provide a mechanism whereby the artwork can be supplemented.

 
ZA14 Part 4, Section 3.17.4.1 - te The mandated incorrect date calculations for 1900 in the 1900-based date basis is unacceptable. An ISO standard should not be mandating incorrect values for the well-established Gregorian Calendar. To do so will only lead to confusion, poor interoperability and perpetuation of errors. 

This is one of a number of cases in the document where buggy, incorrect and idiosyncratic behaviours of legacy applications are in danger of becoming standardized.  Rendering legacy documents by replicating various arbitrary requirements and defects of past formats entrenches dysfunction and therefore cannot constitute an acceptable technical solution,

Comply with the well-established standards for representing and manipulation of dates.  
ZA15 Part 4, Section 5, pp 3211-4342, Drawing ML Reference Material   te This section describes a new markup language for drawing elements.  The W3C SVG, as implemented in ISO/IEC 26300,  is an existing recognized standard in this area.  The proposal of DrawingML does not further the aim of interoperability. The proposed specification should be reconciled with existing ISO/IEC, W3C and other standards.  In particular, it should build upon the existing ISO/IEC 26300 document standard and extended through the appropriate participatory processes where necessary.   
ZA16 Part 4, Section 6, pp 4343-4960, VML Reference Material   te This section describes a deprecated markup language for drawing elements.  The inclusion of deprecated elements in an ISO/IEC standard is discouraged.  The W3C SVG, as implemented in ISO/IEC 26300,  is an existing recognized standard in this area.  The proposal of VML does not further the aim of interoperability. The proposed specification should be reconciled with existing ISO/IEC, W3C and other standards.  In particular, it should build upon the existing ISO/IEC 26300 document standard and extended through the appropriate participatory processes where necessary.   
ZA17 Part 4, Section 7.1, pp 4961-5198, Shared MLs Reference Material, Math   te This section describes a new markup language for representing mathematical equations.  The W3C MATH ML, as implemented in ISO/IEC 26300, is an existing recognized standard in this area.  The proposal of this Shared ML for representing equations does not further the aim of interoperability. The proposed specification should be reconciled with existing ISO/IEC, W3C and other standards.  In particular, it should build upon the existing ISO/IEC 26300 document standard and extended through the appropriate participatory processes where necessary.   

MB = Member body (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)

2 Type of comment: ge = general te = technical  ed = editorial

NOTE Columns 1, 2, 4, 5 are compulsory.

page of 1

ISO electronic balloting commenting template/version 2001-10


Top