January 22, 2004

Subject: INCITS/L8 Comments in Response to JTC 1 N 7335 - Response to JTC 1 Sophia Antipolis Resolution #39: Development of a Solution for the Unambiguous Identification and Interworking of Codes Representing Countries, Languages and Currencies (prepared on behalf of SC 32/WG 1)
From: Dan Gillman, INCITS/L8 Chairman


I hope this response from us is timely enough.

Here is our response regarding document JTC 1 N7335, a contribution from the Canadian National Body.  L8 does not support the plan adopted in this document for two main reasons:
  1. This proposal aims to create a standard that incorporates the content of other standards.  We feel this is very bad practice.  References to standards in normative documents are the usual practice and serve the purpose better.  If the referenced standards change, then the document referencing them is not necessarily forced to change.  This significantly minimizes maintenance.

  2. The reference standards each contain several options that are given equal weight in those documents.  The proposal picks one option from each of the referenced standards.  With respect to these standards, the choices are arbitrary.  This gives the appearance that the authors of the proposal know better than the authors of the referenced standards how to use their standards.  The authors of the referenced standards (projects in ISO TC 37, ISO TC 46, and ISO TC 154) are the experts in their areas, not SC32/WG1. This is not good practice, for obvious reasons.
Dan Gillman
Chair, INCITS/L8

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