Hi Austin,

I do not know the context of your restriction so my answer may be off
target. Anyway I would like to provide my opinion, but before let me
make you a question?

>The easy solution is to just publish them as PDFs, but that just
doesn't
>seem to be the elegant solution in my mind.

Can I ask why?

My Opinion: Just publish it them on PDF (or any other format as stated
on your SOP for legal reasons), and make a statement on your SOP that
the primary document is in PDF (Master Record).

Now probably you want the information to be available also in HTML or
XML. That is easy, maintain the same page separators (some HTML/XML tag)
and put bookmarks on it. But probably you need to assure the information
presented in HTML/XML is exactly the same as in the Primary Record.
Describe how you assure this constraint by providing an irrefutable
automatic procedure (hard to achieve but can be done).

Another approach is to say that the document in XML is your primary
record, although it may be harder to implement this due to your
organization culture or probably not.

Hope it helps,

Nuno Lopes
Independent Consultant. 



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