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2008-04-02
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Standards Norway’s handling of the vote on OOXML in ISO

The criticism we received after announcing that we changed our vote on the proposal of
OOXML (Office Open XML) from “No with comments” to “yes” after our meeting with the
national special committee on IT, SN/K 185, on Friday, 28 March, was not unexpected. We had
also expected criticism if we had chosen to maintain our “no” statement.

Important factors for us in this matter were:

1. The proposal to send the ECMA standard Office Open XML to ISO/IEC in order to
designate it as an ISO/IEC standard was considered through the use of a so-called “fast-
track”-procedure. This kind of expedited consideration is used by ISO to designate
standards developed by standardization organizations with cooperation agreements with
ISO as ISO standards. These are often industry standards that already enjoy a certain
degree of acceptance in the market. Turning them into ISO standards makes them open
standards that can be maintained and refined in the ISO system.

OOXML is an extensive standard (with more than 6,000 pages), and using a “fast-track”
procedure on this document was a very great effort. There was considerable discussion in
many countries as to whether this procedure was appropriate for matters of this kind.
Nevertheless, this procedure was accepted centrally by ISO and IEC in January 2007 as
the appropriate method for considering the OOXML standard.

2. Prior to the OOXML being distributed for a vote, after being proposed by the
standardization organization OASIS, the document standard ODF had been through an
equivalent procedure without any comments on this being problematic. Many consider
ODF and OOXML to be equivalent document standards, and as ODF had already become
an ISO standard, the question was raised as to whether ISO/IEC can have two competing
standards. This question was settled early in 2007 by ISO and IEC centrally, who stated
that there was no clash of interest between the two standards.

3. During 2007 there was a lot of attention in the Norwegian IT sector regarding the process
surrounding OOXML. The discussion rapidly turned into a partisan debate between
proponents and opponents of OOXML. The two issues, i.e. the use of “fast-track” and the
existence of parallel standards, were consequently discussed by Standards Norway’s
committee SN/K 185 (even though the issues had been settled by ISO earlier that same
year). The great public interest in the matter led to an enlargement of the committee from
6-7 members to 30 members.

4. The public enquiry on the consideration of a proposed ISO standard is of great

importance. This is an opportunity for all stakeholders to state their opinions and to make
recommendations for improvements. After Standards Norway circulated the proposal for
comment, we received 47 responses, 38 said “yes” to the proposal and 9 said “no”. As is
already known, many of the “yes” responses were identical and phrased in a way that left
no doubt that they were the result of a campaign orchestrated by Microsoft Norway. All the
responses were signed and came from known senders. Standards Norway cannot take

Mailing address Street Address Tel. +47 67 83 86 00 info@standard.no Bank account

Standards Norway Strandveien 18 Fax +47 67 83 86 01 www.standard.no 1644 17 27384
P.O. Box 242 Enterprise no.
NO-1326 Lysaker NO 985 942 897
Norway
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opinions into consideration other than those that have been expressed in writing. We
would like to add that there is nothing unusual about receiving identical responses in
controversial matters where stakeholders discuss the matter among themselves and lend
support to one another’s statements.

Norway’s statement in this matter was scheduled to be ready for a vote in ISO in August
2007. At this point, however, there was disagreement on the committee regarding
Norway’s position, though with a clear majority wanting Norway to vote “no”. The ISO
regulations state that in order for a member to get its “no” vote approved, the “no” has to
be supplemented by comments that explain the reason for voting “no”.

At the meeting of 28 March the committee thus focused on dealing with the comments
submitted. According to ISO regulations all comments that lead to a proposal being
rejected must be dealt with in a way that will incorporate them into the proposed standard.
As a consequence the members can then choose to change their “no” to a “yes”, which
was what happened during the OOXML process.

5. Approving a standard requires a qualified majority among the ISO members. A minimum
of 2/3 of the members of the committee that has developed the standard need to vote
“yes”, while no more than ¼ are to vote against the proposal.

Standards Norway had earlier decided to vote “no with comments” even though the
national enquiry resulted in a clear “yes”. The conclusion was thus considered to be a
conditional yes, which we also stated in a press release on 31 August 2007. Standards
Norway emphasized the need for an improvement of the proposed standard, in keeping
with the comments from the mirror committee and the mechanism for voting “no with
comments”.

6. According to ISO’s and IEC’s own rules and regulations the national comments are to be
dealt with at a meeting referred to as the “Ballot resolution meeting” (BRM). The
number of comments (close to 3,500) that were supposed to be dealt with during a short
period of time was substantial, though many countries had similar comments. According to
the Norwegian delegation, the BRM meeting took place in an efficient and proper manner,
in accordance with the rules pertaining to ISO/IEC BRM meetings.

Prior to the BRM meeting the comments from Norway were dealt with in the same way as
the rest of the comments. The editor of the document presented the proposals that
became the basis of the BRM meeting. Two of the Norwegian comments where rejected,
the rest were accepted or accepted with modifications. Naturally, the individual country’s
comments must be seen in context. Discussions at the BRM meeting also led to our
comments having to include decisions that had been taken there.

7. In all standardization work in which Standards Norway participates it is Standards

Norway that formally votes. The usual rule for international work is that when there is
general agreement in the committee we follow the advice that our mirror committees
provide. We have on occasion gone against the majority, and there have been instances
when the committee’s feedback did not permit a simple “yes” or “no” response. In such
cases, when following the usual standardization procedure we can choose to abstain.
When following the “fast-track” procedure we need give notice of our wanting to change
our original vote or not once the result from the BRM meeting becomes available.

8. The main issue at the Norwegian committee meeting on 28 March was to clarify whether
if comments had been given sufficient consideration to allow us to change Norway’s vote
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from “no” to “yes”. Prior to the meeting, 21 committee members had signed an open letter
to Standards Norway arguing why Standards Norway should vote “no” to OOXML. Thus
they had taken a position before the committee had discussed how our comments had
been dealt with. In addition the letter also contained other and previously known
arguments against the proposed standard.

During the meeting it became clear that it was not possible to reach an agreement on the
committee about how well or poorly our comments had been dealt with in ISO.

Following consideration by the committee, at a meeting between delegates from the BRM
meeting, the chairman of SN/K 185 and representatives from Standards Norway, there
was a further effort to create a degree of agreement which did not succeed.

The chair of the committee has a vital role in creating the greatest possible agreement, but
already in 2007 the chair of the committee had flagged his position, which meant that he
could no longer meet the criteria for neutrality. He had therefore relinquished his duty of
chairing the committee’s consideration of OOXML, and for that reason Standards
Norway’s deputy managing director chaired the meetings for consideration of this matter
on the committee.

9. It is correct that a majority of members on the committee believed that comments had not
been given sufficient consideration. However, and in line with what the meeting chair
stressed, Standards Norway’s comments had not been formulated as absolutes. In
Standards Norway’s view, the phrasing allowed some leeway, which was important for
finding acceptable solutions through consideration at an international level. At the
committee meeting during the commentary rounds there were many that made absolute
demands have their comments heeded, confirming that the rigid positions were well
established. Standards Norway thus considered any further discussion as futile with
regards to achieving agreement on the committee.

10. In Standards Norway’s summary of the status of the case following the committee
meeting we emphasized the following;

• On the committee there is a clear majority that is opposed to making OOXML into an
ISO/IEC standard. However, in its overall assessment, Standards Norway must also
consider the result of the formal enquiry, where there is a majority of “yes” votes.
There was greater number of end-users of document standard formats among those in
favor, than those who were opposed to the standard.

• There is agreement on the need for improving the proposed standard, and Standards
Norway believes this can best take place if OOXML becomes an ISO standard now.
Work on revising can start immediately on the ISO committee which is responsible
for this standard, and Norway ought to be in the best possible position to initiate and
participate in this effort. (The ODF standard has undergone several changes since it
became an ISO standard.)

• Standards Norway believes that ISO should critically evaluate the “fast-track”
procedure. We believe that work on OOXML would have been better served if it had
been initiated as a new ISO project. The problem, however, was that the proposer,
ECMA, had good reason to launch the project as “fast-track”. In 2008 Standards
Norway is also one of the 12 members that comprise the ISO “Technical Management
Board” (TMB), which is responsible for standardization work and the rules and
procedures it should follow. TMB has already decided to discuss experience with the
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use of the “fast-track” procedure with the ISO/IEC 29500 process as a point of
departure. The issue will likely be raised at TMB’s meeting on 3-4 June this year.

• ISO is the International Organization for Standardization. As a member of ISO we are,

like members of our sister organization IEC, required to do our best to ensure that the
proposed standards we are working on can be approved as ISO and IEC standards.

On this basis, Standards Norway believes the proposed standard ISO/IEC DIS 29500 Office
Open XML with the comments which have now been incorporated into the document can be
approved.

This process has been very difficult, and the decision that Standards Norway had to make was
not an easy one. We have provided our account of the matter above, and the issues behind
Standards Norway’s vote.