Norbert Bollow's Comments on Standards

2009-11-11: What are the decision criteria for DCORs in the JTC1 Directives?

Since the results of the DCOR1 (draft corrigendum 1) ballots for ISO/IEC 29500 have been distributed to the ISO/IEC member bodies last week, it has become clear that there is much confusion about what the relevant ISO/IEC rules (in this case, the JTC1 Directives) say about this kind of situation.

Here's my take on this:

The most obviously relevant clauses of the Directives are these:

15.4.9.4.3 Upon completion of the minimum three-month SC ballot period, the SC Secretariat shall distribute the voting results and any comments received to the SC and shall forward them to the applicable WG Convener or Secretariat. The WG Convener or Secretariat shall distribute the results to the appropriate editor's group. Depending on the outcome of the ballot, the SC Secretariat shall also take action as set out below.

15.4.9.4.4 If no comments or disapproval votes were submitted on the material, the SC Secretariat shall forward it to the ITTF for publication (see Form G22), normally within three months, and send copies of the transmittal letter and the material to the JTC 1 Secretariat for information. For publication considerations, see 15.4.2.1.

15.4.9.4.5 If the general results of the SC ballot were positive, but some comments were received, the SC Secretariat shall also forward the comments to the Project Editor for review when the voting results are distributed to the SC in accordance with 15.4.9.4.3 above. The Project Editor shall prepare responses to the comments and return them to the SC Secretariat together with a revised text of the draft technical corrigendum if any modification has resulted from the editor's review. The SC Secretariat shall distribute the revised text and disposition of comments report to the SC for information, and shall proceed with the submittal to ITTF in accordance with 15.4.9.4.4 above. Each technical corrigendum shall list the status of all amendments and technical corrigenda to the current edition of the standard.

15.4.9.4.6 If the results of the SC ballot are not positive, in forwarding the voting results to the WG Convener or Secretariat in accordance with 15.4.9.4.3 above, the SC Secretariat shall instruct the WG Convener or Secretariat to distribute the results to the appropriate editor's group for consideration and the preparation of a recommendation on further action to be taken.

But what is the meaning of the condition "If the general results of the SC ballot were positive"?

There is no explicit definition of the meaning of this condition. (Hopefully, this lack of explicit clarity will be fixed during the current process of revision of the JTC1 Directives.)

However, there is implicit definition of what "generally positive" means in this context, which results from the above-quoted clauses together with this clause:

9.11.2 Consideration of successive DCORs shall continue until the substantial support of the P-members of the committee has been obtained or a decision to abandon or defer the project has been reached.

Therefore, "generally positive" means that "the substantial support of the P-members of the committee has been obtained".

Now, who judges whether that is the case? This is answered by the following clause: (This is in the context of CDs, i.e. Committee Drafts during the initial development of a standard, but in the absence of any alternative rules for DCORs, that rule will be applied also to DCORs.)

12.6.3.6 It is the responsibility of the SC Secretariat, if necessary in consultation with the ITTF, to judge when substantial support has been obtained. In this connection attention should be given not only to the numerical voting results but also to the attempts made to resolve negative votes and the nature of success or failure to do so.

In this present case, the SC Secretariat has decided that the "generally positive" requirement has not been met. They didn't say so explicitly, but it is stated very clearly in those ballot result N-documents that what happens next is that the ballot results go back to WG4 for comment resolution and coming up with a recommendation of further action. Hence we're in the case of 15.4.9.4.6.

I find it very unfortunate that the decision-making criteria of ISO/IEC JTC1 are so difficult to find and so vague. Whether or not a powerful company with great influence in the responsible WG as well as in many but not all national mirror committees can get a standard changed at will is an important question, but the directives are not clear enough to allow a definitive answer!

The actions of the SC34 secretariat seem to indicate that in practice the directives are interpreted in a reasonable, consensus-seeking manner. But nevertheless, due to the lack of clarity of the ISO/IEC JTC1 rules, there remains reason for concern that possibly the open standards criterion of openness of further development may not be fully satisfied for standards which have been entrusted to ISO/IEC JTC1 for maintenance.

However, the JTC1 directives are currently under revision, and in fact a proposed revised version of these rules has recently been sent to the national member bodies of ISO and IEC for commenting and voting. The plan is to replace the current "JTC1 Directives" document with a much shorter one, which refers to a number of "Standing Documents" on various topics, for example a "JTC1 Standing Document on Maintenance". The current draft for the Standing Document on Maintenance (which is intended for adoption as-is unless there are protests from JTC1 members; the letter ballot is ISO/IEC JTC1 N9869, with a due date of 2010-02-02) is in my opinion pretty bad, since it lacks the implicit definition of the condition "if the general results of the SC ballot were positive", and it does not have any other clarification of the decision criteria either. I therefore call on the members of the various national mirror committees for JTC1 to insist on clarification of the decision-making criteria for corrigenda. There can be no assurance of due process in the maintenance of standards without clarity about the decision-making criteria!


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