cmi.comments and their usage

Question from a client:

Our scorm engine is working well. We are having an issue with some content that running on it and I wonder if you could clarify.

We are having an issue with the scorm engine and just need clarification of something as I think it maybe a client issue.
In scorm 1.2 the cmi.comments is used for collecting data about the sco. Is this data read and write?

i.e can you edit the contents of this field and completely replace the contents or can you only append data once you add.

e.g user logs in and add a note to cmi.comments then they login and add note 2 if the content does a get value to get note1 then append that to note2 and writes this back to the lms should the data be {note 1, note 2} or will it be {note 1} {note1, note 2} (appends to exiting data)

I hope this makes sense.

Just looking for clarification and any help would be greatly appreciated.

My interpretation of the SCORM 1.2 standard here is that this field is entirely managed by the content.  Just like suspend_data, the content may call LMSGetValue("cmi.comments") and then manipulate that text how it sees fit.  It can append "note 2" or it can simply replace "note 1".  Put most simply, the comment will contain whatever the content puts in it.  It the example above, that would be {note 1, note 2}.  The LMS does no appending on its own.

In SCORM 2004, however, things get a bit more sophisticated.  cmi.comments_from_learner becomes an array, like objectives or interactions, rather than the simple field it was before.  While this still depends on the content to manage things by keeping up with the indexes, it does clarify the subject a bit.