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§9.3.1

Barely-Existing Columns and Headers

An empty or barely styled column—keep it?

✅ NormativeSettled. The requirement holds as written.📄 Page ruleCan be applied from the page alone.Read §9.3.1 in the RFC ↗

The requirement

The output MUST transcribe what is printed and add nothing. A column or a header MUST NOT be dropped because it is empty, plainly styled or easy to miss, and a label MUST NOT be invented for a cell that has none.

When it applies

Sketch of the printed page — layout, not output
|        | Current | New Program² |
| Rate A | 1.10    |              |    ← all-blank column, proven only by its
| Rate B | 1.25    |              |      header: it exists, keep it
  ↑ blank corner: leave it blank, do not invent "Category"

Four situations look like nothing and are routinely lost. All four are the same failure in one of two directions — a drop or an invention (Never Drop, Never Invent (§2.2)).

Reading the examples. Each one pairs a source page with the output the rule expects. ✅ Sample: the rule applies. ❌ Counter-sample: it looks like it applies and does not, or a rendering got it wrong. A non-conforming output, in red, is shown only for contrast. … marks content left out of an excerpt.

An all-blank body column proven only by its header

A column whose body is entirely empty still exists. It MUST be kept as an empty column, and any marker on its label MUST be kept — a superscript such as New Program² is part of the header text, not decoration.

01

✅ SampleThe rule applies

The Bidder's Response column is entirely blank — proven to exist only by its headersln

Dropping it is the classic error. The merged item cells and the two-line specification values are printed that way.

Source page
Barely-Existing Columns and Headers — The Bidder's Response column is entirely blank — proven to exist only by its header. Source page.
Expected output · the specification table
SL No Name of Item Technical Specifications and Standards Bidder's Response
1 Brand To Be Mentioned By Tenderer
2 Model To Be Mentioned By Tenderer
3 Country of Origin USA/UK/EU or Equivalent
4 Category Cat.6
5 Reference standard ISO/IEC11801, ANSI/TIA/EIA-568-C.2-D, IEC61156-5
EN50399, RoHS Compliant.
6 Conductor Material Solid-Bare Copper
Structure AWG 23 AWG
7 Insulation Material HDPE
Nominal OD 1.0 ± 0.10 mm
8 Twist Direction: S
9 Fillers Material: PE
10 Jacket Thickness 0.60 ± 0.10 mm
Diameter 6.30 ± 0.30 mm
Material PVC
Color Orange/Blue/Gray
11 Jacket physical properties Before aging Tensile strength ≥ 13.5 Mpa
Elongation ≥ 150%
After aging Tensile strength ≥ 12.5 Mpa
Elongation ≥ 125%
12 Cable length 305m/Box
Barely-Existing Columns and Headers · Source page

The Bidder's Response column is entirely blank — proven to exist only by its header

Barely-Existing Columns and Headers — The Bidder's Response column is entirely blank — proven to exist only by its header. Source page.
02

✅ SampleThe rule applies

Column 3 carries no header text at all, only XX filler valuesxx

its header cell stays empty and the column stays.

Source page
Barely-Existing Columns and Headers — Column 3 carries no header text at all, only XX filler values. Source page.
Expected output · excerpt
Data Item for Specified Rating Pool
For the rate period included in the immediately prior rate adjustment filing (or initial form & rate filing)
1. Market Segment 2. Description of rating pool within the market segment 18. Period assumed - beginning date (MM/DD/YY) 19. Period assumed - ending date (MM/DD/YY) 20. Average annual claim trend assumed 21.1 Regulatory authority licenses and fees, including New York State 332 assessment as a % of gross premium 21.2 Administrative expenses for activities that improve health care quality as defined in the NAIC Annual Statement Supplement Health Care Exhibit - as a % of gross premium 21.3 Commissions and broker fees - as a % of gross premium 21.4 Premium Taxes - as a % of gross premium 21.5 Other state and federal taxes and assessments (other than income taxes and assessments) - as a % of gross premium 21.6 Other administrative expenses - as a % of gross premium 21.7 Subtotal columns 21.1 through 21.6 22. After tax underwriting margin (profit/contribution to surplus) - as a % of gross premium 23. State income tax component - as a % of gross premium 23.1 State income tax rate assumed (eg 3%) 24. Federal income tax component - as a % of gross premium 24.1 Federal income tax rate assumed (eg 30%) 25. Reduction for assumed net investment income - as a % of gross premium (enter as a negative value) 26. Subtotal lines 21.7 + 22 + 23 + 24 + 25 27.1 Regulatory authority licenses and fees, including New York State 332 assessment expenses - $pmpm 27.2 Administrative expenses for activities that improve health care quality as defined in the NAIC Annual Statement Supplement Health Care Exhibit - as $pmpm 27.3 Commissions and broker fees - as $pmpm 27.4 Premium Taxes - as $pmpm 27.5 Other state and federal taxes and assessments (other than income taxes and assessments) - as $pmpm 27.6 Other administrative expenses - as $pmpm 27.7 Subtotal lines 27.1 through 27.6 28. After tax underwriting margin (profit/contribution to surplus) - as $pmpm 29. State income tax component - as $pmpm 30. Federal income tax component - as $pmpm 31. Reduction for assumed net investment income - as $pmpm (enter as a negative value) 32. Subtotal columns 27.7 through 31
HNY-IND Healthy NY XX 1/1/2012 12/31/2012 15.2% 0.80% 0.00% 1.54% 2.71% 0.00% 6.16% 11.21% -1.21% 0.00% 7.10% 0.00% 34.00% 0.00% 10.00% 2.40 0.00 4.62 8.14 0.00 18.46 33.62 (3.64) 0.00 0.00 0.00 29.98
XX 0.00% 0.00% 0.00 0.00
XX 0.00% 0.00% 0.00 0.00
…
Barely-Existing Columns and Headers · Source page

Column 3 carries no header text at all, only XX filler values

Barely-Existing Columns and Headers — Column 3 carries no header text at all, only XX filler values. Source page.
03

✅ SampleThe rule applies

Total Weightage Assigned stays blank across five rows, proven only by its headeren

the page prints that blank as one merged box, so it is one cell with a rowspan. The bold TOTAL row closes the table.

Source page
Barely-Existing Columns and Headers — Total Weightage Assigned stays blank across five rows, proven only by its header. Source page.
Expected output
Division of Syllabus for Term II (October-March) Total Weightage Assigned
Summative Assessment II 30%
Section Marks
Reading 20
Writing 20
Grammar 15
Literature 35
Formative Assessment 20%
TOTAL 90 50%
Barely-Existing Columns and Headers · Source page

Total Weightage Assigned stays blank across five rows, proven only by its header

Barely-Existing Columns and Headers — Total Weightage Assigned stays blank across five rows, proven only by its header. Source page.

A blank corner cell over the stub

If the corner above the row labels is blank on the page, it MUST be rendered blank. "Category", "Item" or any other reasonable-sounding word MUST NOT be supplied. An unlabelled cell is data too.

04

✅ SampleThe rule applies

A blank top-left corner cell, ruled off from the Territory label below it3lineperorw

A blank top-left corner cell, ruled off from the Territory label below it.

Source page
Barely-Existing Columns and Headers — A blank top-left corner cell, ruled off from the Territory label below it. Source page.
Expected output · excerpt
HO 00 01 HO 00 02
Territory Fire Wind Water Theft Other Liability Fire Wind Water Theft Other Liability
07922 203.40 84.40 72.39 14.65 23.71 50.03 175.76 72.93 62.55 12.64 20.51 43.22
07924 163.85 67.96 58.97 9.06 16.74 37.73 141.69 58.77 50.99 7.81 14.47 32.65
07926 173.44 69.66 68.24 7.64 19.92 42.17 149.94 60.22 58.99 6.58 17.24 36.45
07927 172.16 69.17 67.75 7.59 19.80 41.85 148.68 59.71 58.50 6.53 17.09 36.14
07928 124.38 49.96 48.92 5.47 14.28 30.25 107.49 43.18 42.29 4.74 12.35 26.11
07930 121.09 48.64 47.64 5.34 13.93 29.42 104.20 41.86 40.99 4.59 11.97 25.33
…
Barely-Existing Columns and Headers · Source page

A blank top-left corner cell, ruled off from the Territory label below it

Barely-Existing Columns and Headers — A blank top-left corner cell, ruled off from the Territory label below it. Source page.
05

❌ Counter-sampleLooks like it applies and does not — or a rendering got it wrong

The same table revised3lineperrowhili

no rule divides the corner from the Territory label, so the label fills a genuinely merged two-row cell — the mirror of the blank corner above. The green row fill is shading and is not rendered.

Source page
Barely-Existing Columns and Headers — The same table revised. Source page.
Expected output · excerpt
Territory HO 00 01 HO 00 02
Fire Wind Water Theft Other Liability Fire Wind Water Theft Other Liability
07001 254.48 105.55 91.56 14.05 25.99 58.63 220.12 91.3 79.22 12.14 22.46 50.72
07002 319.25 155.12 106.57 15.15 32.21 79.9 275.52 133.86 91.97 13.06 27.8 68.95
…
Barely-Existing Columns and Headers · Source page

The same table revised

Barely-Existing Columns and Headers — The same table revised. Source page.

A numbered tier (1) (2) (3)… across the columns

Sketch of the printed page — layout, not output
| State | Premium | Losses |
| (1)   | (2)     | (3)    |   ← a header row: render it

A numbered tier running across the columns is a header row, not decoration, and MUST be rendered.

Dropping it costs twice. The tier also runs the full width of the grid, which is the evidence that every column below belongs to one row — the proof Group and Cohort Bands (§9.2.5) and Bands Inside the Grid (§9.2.1) rely on to show that banded blocks are a single table. Without the tier, both the header and the boundary signal are lost.

06

✅ SampleThe rule applies

A numbered tier (1)–(12) sitting above the real headers with no group meaningxlt

Under (5) and (10) a formula is printed on its own line, so that break is kept.

Source page
Barely-Existing Columns and Headers — A numbered tier (1)–(12) sitting above the real headers with no group meaning. Source page.
Expected output · excerpt
(1) (2) (3) (4) (5)
(4) ÷ (1)
(6) (7) (8) (9) (10)
(9) ÷ (8) -1.0
(11) (12)
Species Initial Age of Pet Earned Premium Earned Exposures Closed With Payment Claim Count Paid Loss Paid Loss Ratio Credibility Credibility Adjusted Paid Loss Ratio Current Factors Proposed Factors Factor Percent Change Inforce Premium at Current Rate Level Premium Impact
Cat 0 5,541,666 20,315 6,558 2,530,125 0.457 100% 0.457 1.000 1.000 0.0% 537,834
Cat 1 2,472,798 8,086 2,747 1,153,674 0.467 90% 0.474 1.000 1.000 0.0% 217,726
Cat 2 2,044,181 6,450 2,948 1,096,456 0.536 81% 0.537 1.000 1.000 0.0% 162,567
…
Barely-Existing Columns and Headers · Source page

A numbered tier (1)–(12) sitting above the real headers with no group meaning

Barely-Existing Columns and Headers — A numbered tier (1)–(12) sitting above the real headers with no group meaning. Source page.

Header bands that are not bold

A band naming a section is a header row even when it is set in plain type. "Lending" over a block of lending figures, or a CA|PPO line above its rates, are headers; demoting them to body rows is non-conforming.

Sketch of the printed page — layout, not output
| Lending    |       |   ← plain-styled band naming a section: still a header
| Commercial | 120.5 |

Boldness MUST NOT decide what is a header. Headers are recognised from position, span and what the line does for the rows beneath it — Bold and Italic Inside Tables (§9.6.2) shows styling is applied unreliably in both directions and cannot carry this judgement.

Blank space beside or below a header label

Sketch of the printed page — layout, not output
| 34 | S |          | [rowspan=3]34     | S |
|    | M |    vs    | ROW_SPAN_CONTINUE | M |
|    | L |          | ROW_SPAN_CONTINUE | L |

A region that is visually blank beside or below a labelled cell MUST be rendered as separate empty cells. The label's rowspan or colspan MUST NOT be extended over it unless the cell is genuinely merged — when the print says so, not when it is inferred.

Telling a real merge from adjacent blankness

Genuine merge — extend Adjacent blankness — separate empty cells
No ruling divides the region: it is printed as one box Ruled cell borders continue through the blank region
The label is centred across the whole span The label sits in the first cell, blank cells follow
A stub label spanning the header tiers (<th rowspan="2">UW Category</th>) A header label that simply has nothing under it

The stopped-divider test. A ruling line that stops is as informative as one that continues. On a bundle-credit rate table the divider beneath Number of Additional Policies stops before the Factor column: that stopped rule is positive evidence that the group covers Car and Other only, and that Factor is a genuinely merged cell spanning both header tiers. What looks like "blank space above Factor" is in fact inside a visibly merged two-row header cell. Where a divider stops, the cell beside it spans.

Most blank-adjacency cases have no such geometry. Absent a stopped divider or an equivalent printed signal, nothing proves a merge — which is why the default is do not extend.

Carve-out. A stub label that spans the header tiers (Multi-Row Header Tiers (§9.3.3)) still takes a rowspan across those header rows. That is a logical merge and this rule does not touch it.

Why this way. A span mirrors what is printed, never what is inferred. A blank cell asserts nothing; a span asserts "this label owns that region", which needs printed evidence. Making merge the default would teach the reflex when in doubt, rowspan — exactly the habit Repeated Identical Values (§9.5.4) exists to suppress. It is also the simpler question: "is this cell's printed content empty?" rather than a semantic judgement, the same test Blank and Spacer Rows (§9.5.1) uses in the table body.

The through-line

Every case here is a drop or an invention. One principle covers all of them, the one also stated in Repeated Identical Values (§9.5.4): never emit less data than went in, and never invent what was not printed.

More

Rule id tables-barely-existing-columns-and-headers · tables columns headers drops