How To Communicate With Standard Organisations

A note from a friendly member of a standards committee to everyone who submitted "comments" on MS-OOXML to their national bodies:

You need to make sure that whatever is your main point of criticism of MS-OOXML gets accepted as a "technical comment" rather than as a "general comment".

There are three types of comments, "editorial", "technical" and "general". The distinction is important because "technical" comments are the only type of comments which matters for the ISO/IEC process of approving or rejecting a draft international standard.

The "general" comments are purely informational only. They are good only for influencing the general mood of committee meetings and for influencing the committee chairman to make him willing to support you when you try to get your main point of criticism accepted as a "technical comment".

The distinction between the three types of comments is as follows:

  • "editorial" comments refer to issues which can be resolved by changing the wording of the draft standard document without changing its meaning,
  • "technical" comments refer to issues which can be resolved by changing the wording of the draft standard document in ways that change the meaning.

For example "The MS-OOXML spec contains patented elements (for which no clearly GPL and LGPL compatible license is available)" is a "technical" comment in this sense because the problem can be solved by changing the draft standard so that it does not any longer contain any references to such patented elements (the way to achieve this would be to throw out most of the meat of the MS-OOXML spec and replace those technical descriptions with
descriptions of how things are done in ODF - clearly a technical change.)

If anyone doubts that complaints about patents are to be considered "technical" comments in the context of the ISO/IEC process, and that such complaints are supposed to be taken very seriously, point them to part 1, section 2.14 of the "ISO/IEC Directives". By contrast, complaints about the wording and lack of LGPL compatibility of Microsoft's so-called "open specification promise" are not "technical" but rather "general" comments, because no matter how one might change the text of the draft standard that isn't going to change the fact that there are issues with the so-called "open specification promise".

Sample Submissions

Submissions from professionals critical of ooxml are to be found on our submissions page.

Formatting of your submissions

National standard bodies provided appropriate document templates for objections (original word version) (French version: ODT DOC). General, technical and editorial comments are to be separated for their convenience. Objections should be technical and refer to the sections of the ECMA standard document. The distinction is important because "technical" comments are the only type of comments which matters for the ISO/IEC process of approving or rejecting a draft international standard.
You can send your submissions in CC: or BCC to gro.iiff|lmxooon#gro.iiff|lmxooon so that it gets archived.