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Subject: CD01 -- 8.2.1 Referencing Table Cells
This section appears to be directly clipped from ODF 1.1 section 8.3.1 without change other than removing the examples. The section is purely informative except for the last paragraph, which deals with punctuation. The text preceding the last paragraph is worded as three compound passive voice sentences with subclauses, none of which establish any normative requirements whatsoever. However, it appears that a TC co-chair views the matter appearing before the last paragraph as establishing conformity requirements. <http://www.robweir.com/blog/2009/05/update-on-odf-spreadsheet.html> ("SP2's implementation of ODF spreadsheets does not, in fact, conform to the requirements of the ODF standard ..."); <http://www.robweir.com/blog/2009/05/follow-up-on-excel-2007-sp2s-odf.html>. ("First up is the question of whether the ODF documents written by Excel 2007 SP2 indeed conform to the ODF 1.1 standard.") (The latter article quotes the portion of ODF 1.1 that mirrors section 8.2.1 in Committee Draft 1.) As a matter of international law, a technical regulation must specify [i] "any objectively definable 'features', 'qualities', 'attributes;, or other 'distinguishing mark' [ii] of an identifiable product or group of products [iii] only in mandatory 'must' or 'must not' terms. WTDS 135 EC - Asbestos, (World Trade Organization Appellate Body; 12 March 2001; HTML version), ΒΆΒΆ 66-70, <http://www.wto.org/english/tratop_e/dispu_e/cases_e/ds135_e.htm>; reaffirmed and further explained, WTDS 231 EC - Sardines, pp. 41-51 (World Trade Organization Appellate Body; 26 September 2002), pp. 41-51, <http://www.wto.org/english/tratop_e/dispu_e/cases_e/ds231_e.htm>. (Under the Agreement on Technical Barriers to Trade the same document must simultaneously be capable of serving as both an international standard and a technical regulation (and as a procurement technical specification under the Agreement on Government Procurement); therefore, those case precedents govern.) JTC 1 Directives is in harmony, requiring that international standards "specify clearly and unambiguously the conformity requirements that are essential to achieve the interoperability." ISO/IEC JTC 1 Directives, (5th Ed., v. 3.0, 5 April 2007) pg. 145, <http://www.jtc1sc34.org/repository/0856rev.pdf> It follows necessarily that for product characteristics to be conformity requirements, they must be drafted using mandatory terms. If the TC desires that the sentences under discussion establish conformity requirements, then they must be rewritten as conformity requirements rather than as informative advice; i.e., in active voice using the "shall" and/or "shall not" requirement keywords definitions established by Annex H of ISO/IEC, ISO/IEC Directives Part 2: Rules for the Structure and Drafting of International Standards (5th Edition, 21 December 2004), <http://www.iec.ch/tiss/iec/Directives-Part2-Ed5.pdf>. See also ibid., pg. 11: "The same term shall be used throughout each document or series of associated documents to designate a given concept. The use of an alternative term (synonym) for a concept already defined shall be avoided. As far as possible, only one meaning shall be attributed to each term chosen." One does not specify conformity requirements in passive voice sentences that merely inform; they must be stated imperatively. As to the last paragraph, it attempts unsuccessfully to express normative requirements using the term "must" which is not defined by the specification as establishing an imperative. Annex H, supra, is crystal clear that "must" is improper in context: "Do not use 'must' as an alternative for 'shall'. (This will avoid any confusion between the requirements of a document and external statutory obligations.)" I am aware of no external statutory obligation bearing directly on the form of punctuation used in cell addresses beyond a more than somewhat ridiculous reading of the EC Asbestos Panel's ruling that would forbid "shall" from being used to express an imperative instruction. In distinguishing between legal and standard conformity requirements, JTC 1 has established a useful semantic distinction that in no way undermines the intent of the EC Asbestos Panel's ruling. It therefore appears that using "must" in context is forbidden by JTC 1 Directives. Best regards, Paul E. Merrell, J.D. ("Marbux") -- Universal Interoperability Council <http:www.universal-interop-council.org>
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