US
comments to SC35 New Project proposals
in SC35 N0200, N0202, N0215, and N0216
Developed by NCITS/L2 on January 29, 2001
I believe that the JTC 1 TAG needs to take a serious look at the work being proposed in SC 35; if taken to fruition and embraced by purchasers or regulators, it could have significant impact on both products and services. It may be time for the US to become involved in SC 35 in order to make sure that we minimize bad impacts on us all. It may also be time to understand that in an era where adaptability is increasingly important, and where there are many vocal NGOs in the US, the industry (JTC 1 TAG) refusal to get involved might have unfortunate public relations consequences.
I have attached several documents from the recent SC 35 plenary which I recommend you review in this context.
<<SC35N0200.doc>>
This is a proposal for a new project on test methods for assessing cultural and linguistic adaptability in hardware and software. This could clearly become a certification tool for all products, both hardware and software. I quote "This international standard will assist in the clarification of marketplace rules for everybody and bring an objective assessment method to measure cultural and linguistic adaptability. It is also a tool for comparing competing products and hence will help in making buying choices."
The Scope is defined as:
"The project will present a test method to evaluate the actual degree
to which a given IT-based product or service can meet cultural and
linguistic requirements while being able to interchange data on a
world-wide basis when appropriate."
What these guys are trying to do is make a standard method that will
be used to produce evaluation checklists, that in turn will be used
by procurement agencies to evaluate your products and make decisions
about what to buy. While the optimistic conclusion is that this will
result in "an objective assessment method to measure cultural and
linguistic adaptability", don't be too surprised when these guys
come up with a method and approach that doesn't fit very well with
how various vendors are trying to address the I18N issues. And also
don't be surprised to find Eurocentric barriers built into the
method.
These are true believers, folks. They think what they are doing is
in the best interest of users. It is quite likely that this thing
will get pushed through and be developed without much vendor input,
and your companies are going to have to deal with the consequences,
eventually.
I suggest you put this on your standards watch list.
From Frank Farance
This NP has several problems. I believe the proposal is "backwards" in many ways.
Additionally:
This week I am in Athens, Greece at the IEEE LTSC (Learning Technology Standards Committee). One topic was localization of learning content. Many people agreed that the localization (cultural and linguistic adaptation) of IT products and services is difficult at best ... it's not simply merely a character set. If it's difficult to create a technical solution and "get it right", then certainly it's even harder to test "what is right". Thus, the notion of being truly "culturally and linguistically adaptable" is difficult to measure (except if it's just switch characters, currency symbols, message catalogs, etc., ... but there are already standards and conformance for these kind of things in SC22/WG14, SC22/WG15, SC22/WG20, SC22/WG21).
I find the subject NP (Assessment of cultural and linguistic adaptability in software and hardware products Test method) to be not clear or consistent.
A standard for a test method is certainly an appropriate goal of standardization. However, I have the following questions on this specific proposal:
A1 Market Requirement - An international standard is essential to diminish bad surprises in global software trade - WHAT ARE "BAD SURPRISES IN GLOBAL TRADE?" I HAVE NO SENSE OF MARKET NEEDS FROM THIS STATEMENT.
A.2 Regulatory Context - Many jurisdictions already have legal and regulatory requirements about cultural and linguistic adaptability – THEN THIS STANDARD WILL BE USED AS A BASIS FOR SUPPLIERS DECLARATION OF CONFORMITY OR CERTIFICATION SCHEMES? WHICH? WHY?
D.1 Conformity Assessment - NO is checked and the following statement is made: "The standard will be a method used to evaluate products and services from a cultural and linguistic adaptability perspective. Conformity will be with the method, not with the evaluation resulting from the use of the method" - TEST METHODS ARE AN INTEGRAL PART OF A CONFORMITY ASSESSMENT SYSTEM. HOW CAN YOU ANSWER "NO" ON THIS QUESTION?
IN D1, THE INSTRUCTIONS ARE "Indicate here if Conformity Assessment is relevant to your project. If so, indicate how it is addressed in your project plan." THE ANSWER OF "NO" IS WRONG. I WANT TO KNOW WHETHER THERE ARE PLANS TO SET UP A CERTIFICATION AND ACCREDITATION INFRASTRUCTURE OR WILL SUPPLIERS DECLARATION OF CONFORMITY BE ACCEPTABLE AND WHY.
REGULATIONS ARE USUALLY FOR HEALTH, SAFETY, AND ENVIRONMENT CONCERNS – NOT FOR "BAD SURPRISES" - SO THE ABOVE QUESTIONS ARE OF REAL SIGNIFICANCE.
<<SC35N0202.doc>>
This is a proposal for guidelines for drafting standards with respect to cultural and linguistic adaptability.
<<SC35N0215.doc>>
This is a "Report on short meeting on possible new projects for elderly and disabled people". It does not, as the title leads one to believe, advocate the employment of these people in SC 35 projects :) Rather it addresses such things as "proposing an NP on specifying the requirements on symbols and icons for elderly and disabled persons" and "test methods for these symbols and icons"
<<SC35N0216.doc>>
The resolutions from the plenary. Note the creation of WG 5 on "Cultural, Linguistic and User Requirements" and the decision to move the "Japanese proposal on five graphical symbols for use on I.T. equipment" forward for fast track approval.