I don't think so either. There is documentation of the possibility of symbol 
substitution, but nothing about placement of commas, nothing about continuation 
symbols, and a piece about embedded blanks being possible. Particularly this 
latter could be affected by the embedding of comments in such a way.

For the processing of the PARMDD data set(s), explicit documentation of the 
processing of comments (if it is done) would be required.

As far as I can tell, if you want to put PARM='LUMP', you could have:

Dataset 1: L followed by blanks
Dataset 2: U followed by blanks
Dataset 3: M followed by blanks
Dataset 4: P folowed by blanks

How would you tell, if that is possible, where a comment was? There's no 
specified requirement to "break" at a specific column on on a comma, as one 
long "string" of up to 32760 characters are created.

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