PURPOSE: To provide a device capable of producing a comment text even when only low-level language program is recorded on a recording medium by recording a low-level language program converted from a high-level language program on the recording medium, and recording it on the recording medium by adding position information representing the comment position of the high-level language program to the comment text.

CONSTITUTION: A low-level language conversion means 7 converts the high-level language program stored in a program storage means 5 into the low-level language program. An index information generating means 8 generates index information consisting of the size information of the low-level language program converted by the low-level language conversion means 7 and the size information of the comment text to which the position information is added separated by a separation means 4. A write control means 9 functions when the index information is generated, and controls a drive 10 so that the index information and the comment to text to which the low-level language program position information is added can be recorded on the recording medium as one data format.