International Organization for Standardization

International Electrotechnical Commission

ISO/IEC JTC1/SC34 - Document Description Languages

TITLE: Resolution of FCD 15445 ballot comments
SOURCE: Editors of ISO/IEC 15445
STATUS: Submitted for NB approval.
REFERENCES: SC34 N0010 Final CD Text for ISO/IEC 15445 (ISO HTML)
SC34 N0011 Final CD Ballot for ISO/IEC 15445 (ISO HTML)
Final Draft International Standard ISO/IEC 15445 (ISO HTML)
ACTION: Review for approval.
DATE: March 18th, 1999

Resolution of FCD 15445 ballot comments and Preparation of FDIS

Comments were received from the National Bodies of Japan and the UK. The editors also received editing instructions from Mr. John Spangler of the ISO.

The National Body of Japan

All 8 comments are accepted. The editors wish to thank the Japanese NB experts for their careful reading of FCD 15445 which has much improved the quality of the text.

The UK

Comment 1: Copyright.
Please note that the editors have no ability to modify the copyright claims of other organisations which already claim copyright on the HTML language and its specification. Our copyright statement recognizes the existing rights of other organisations.
Comment 2: Links to other texts not under the control of ISO/IEC
ISO/IEC 15445 contains electronic links to the referenced specification, however any further links contained in the referenced electronic document are the responsibility of the owner of that document; the W3C.

ISO editing instructions

The editors have received editing instructions from Mr. John Spangler of the ISO regarding ISO-HTML. These have been applied where possible, but there are some exceptions. The exceptions are listed in the annex to this contribution. We would like to draw the attention of NB experts to the importance of points 1) and 2) in the reply to Mr. Spangler.

Preparation of the FDIS

Following application of the NB comments and the ISO editing instructions, your editors have prepared the Final Draft International Standard for submission to the SC34 secretariat.

NB experts wishing to bookmark the Final Draft International Standard should use the Permanent URL: This URL is indirect and is resolved at the moment of reference to an ephemeral physical reference. Some popular browsers, when asked to "bookmark" a document, bookmark the physical reference. It may be necessary to use the bookmark facilities of the browser to establish the correct Permanent URL.

NOTE: The User's Guide to ISO/IEC 15445 is available at This is not an ISO/IEC document.

Files containing the SGML Declaration and the Document Type Definition specified by ISO/IEC 15445 (ISO-HTML) are also available:

Annex: Letter in reply to ISO editing instructions

The following text is a draft of an e-mail reply that the editors have prepared to be sent to Mr. John Spangler of the ISO in reply to his editing instructions.

Hello John,

David Abrahamson and I are the two co-editors of ISO/IEC 15445, aka
ISO-HTML.  This project is original in a number of ways, and we would
like to seek your advice on the correct manner of applying your
editing instructions dated 99.03.01.

Our document is marked up using ISO/IEC 15445 ISO-HTML and we have
developed a style sheet which follows the directives as closely as
possible.  However some differences remain.

1) ISO-HTML makes normative reference to the W3C
Recommendation for HTML 4.0.  The reference version of HTML 4.0 is the
electronic version, not the paper.  We refer only to certain clauses
of HTML 4.0 and we do this electronically from our reference version,
which is again electronic.

2) The ISO/IEC will not own the technical content
of this Standard, which belongs to the W3C.  We have worked closely
with the W3C, and the editor of the W3C Recommendation for HTML 4.0
participated in our editing work as an Invited Expert, advising us on
the excerpts of the Recommendation that we should use.  All of the
core content of FDIS 15445 is already freely distributed by the W3C
and we believe that it is essential to have the same free HTML-based
delivery for ISO/IEC 15445.  A PDF document, although electronic,
would not be satisfactory for the many W3C readers - ISO-HTML is
already being used as a starting point for further work in the W3C on
Mobile Access to the WWW.

Since ISO-HTML uses material which is already copyrighted by others we
use the copyright statement

   Copyright (C) 1999 IETF, W3C (MIT, Inria, Keio), ISO/IEC, 
                      Roger Price, David Abrahamson. 
                      All Rights Reserved.

   Notice: Because the U.S. Department of Energy has supported the
   development of SC34's standards (under contract DE-AC05-84OR21400),
   it makes the following assertion:

   The U.S. Government retains a paid-up, nonexclusive, irrevocable,
   world-wide license to publish or reproduce the published form of these
   documents, prepare derivative works, distribute copies to the public,
   and perform publicly and display publicly, or to allow others to do
   so, for U.S. Government purposes.

NOTE: The inclusion of our names is _not_ intended to restrict in any
way the ISO/IEC use and sale of ISO-HTML, nor the NB right to publish
and sell: we seek to ensure that nothing we have written or developed
for the standard can be stolen and copyrighted by anyone else.
Experience with the development of software on the Internet shows that
"leakage" is inevitable and that such protection is essential,
throughout the entire life of the software.

3) The paper version of ISO-HTML which you have seen is obtained from
the "print" facility of a browser.  Although a printout is sometimes
convenient, we believe that the full practical usefulness of ISO-HTML
comes from the close integration with HTML 4.0 provided by the "point
and click" functionality of a browser reading the HTML.  Apart from
the internal procedures of JTC1, we have never been asked for a paper

4) The cover letter of the editing instructions asks for camera-ready
copy.  Is this needed for an electronic document, where the paper
version consists only of the cover page, which is created by the

5) The editing instructions call for separate pages for the title page
(p.i), the foreword (p.iii), the introduction (p.iv) and clause 1
(p.1), however in an HTML document, the entire document is a single
page, without page numbering.

6) The instructions call for a title at the top of page 1.  It seems
unnatural to find another document title in the "middle" of an HTML

7) The even and odd headers the instructions ask for are not possible
with ISO-HTML and CSS1.  

We have a simple Unix-based development process for ISO-HTML
documents.  This is described in the ISO-HTML User's Guide which,
although not part of the ISO/IEC Standard, we would be very happy to
share with the ISO/CS.

Best Regards,
Roger Price                    Dept of Computer Science, UMass Lowell

Roger Price   [email protected]
David Abrahamson   [email protected]

Valid HTML 4.0! Validated to ISO/IEC 15445!