After a few delays, on March 16, 2015 new FCC rules went into effect that better outline closed captioning quality requirements for video content providers and broadcasters. AST’s mission is to provide affordable, top-quality closed captioning services, and one of our core values is education. Consistent with those goals, if you are a video content creator and have been asked to provide a certificate of compliance with FCC Rule 79.1, then this post and the accompanying resources below should help you understand how to ensure compliance with these new rules.
In regards to FCC Rule 79.1, video producers need to know that CaptionSync captioning will satisfy the standards covered in paragraph (j)(2) as long as you select the correct options when you create your account and make your submission. To meet all of these requirements you must select the Cinema Certified Result Review and follow these steps when you submit content in your CaptionSync account.
To understand the quality regulations of FCC Rule 79.1, we have picked out the key portions (below) from the lengthy legal jargon to help you understand what standards CaptionSync and the Result Review team maintain for compliance. If you believe other laws and regulations may apply to you, please see our captioning compliance reference page here.
Paragraph (j)(2) covers requirements related to quality, accuracy, synchronicity, completeness, and placement. Synchronicity includes regulations on captioning song lyrics. You will need to provide AST with lyrics and notes about placement so that our transcribers and Result Review team can ensure correct placement. Another important subject covered is the placement of captions, which must be done in a manner that does not block important visual information. CaptionSync and the Result Review team require a MP4 file in order to change the captions and move them to their necessary placement.
Requirements that CaptionSync Can Meet Under FCC Rule 79.1(j)(2):
(2) Captioning quality standards. Closed captioning shall convey the aural content of video programming in the original language (i.e. English or Spanish) to individuals who are deaf and hard of hearing to the same extent that the audio track conveys such content to individuals who are able to hear. Captioning shall be accurate, synchronous, complete, and appropriately placed as those terms are defined herein.
(i) Accuracy. Captioning shall match the spoken words (or song lyrics when provided on the audio track) in their original language (English or Spanish), in the order spoken, without substituting words for proper names and places, and without paraphrasing, except to the extent that paraphrasing is necessary to resolve any time constraints. Captions shall contain proper spelling (including appropriate homophones), appropriate punctuation and capitalization, correct tense and use of singular or plural forms, and accurate representation of numbers with appropriate symbols or words. If slang or grammatical errors are intentionally used in a program’s dialogue, they shall be mirrored in the captions. Captioning shall provide nonverbal information that is not observable, such as the identity of speakers, the existence of music (whether or not there are also lyrics to be captioned), sound effects, and audience reaction, to the greatest extent possible, given the nature of the program. Captions shall be legible, with appropriate spacing between words for readability.
(ii) Synchronicity. Captioning shall coincide with the corresponding spoken words and sounds to the greatest extent possible, given the type of the programming. Captions shall begin to appear at the time that the corresponding speech or sounds begin and end approximately when the speech or sounds end. Captions shall be displayed on the screen at a speed that permits them to be read by viewers.
(iii) Completeness. Captioning shall run from the beginning to the end of the program, to the fullest extent possible.
(iv) Placement. Captioning shall be viewable and shall not block other important visual content on the screen, including, but not limited to, character faces, featured text (e.g., weather or other news updates, graphics and credits), and other information that is essential to understanding a program’s content when the closed captioning feature is activated. Caption font shall be sized appropriately for legibility. Lines of caption shall not overlap one another and captions shall be adequately positioned so that they do not run off the edge of the video screen.
On May 5th, the FCC published a public notice clarifying the procedures necessary for video programming distributors to report programmers who refuse to provide closed captioning quality certifications. The notice emphasizes the part of FCC Rule 79.1 which requires distributors to do everything in their power to obtain certifications from each programmer stating that they have abided by section (j)(2) as described above. For more information you can view the public notice or read this The National Law Review post.