The FCC in a February 2016 order clarified who is responsible for complying with closed captioning requirements, and for the most part this order was good news for cable operators, and could potentially reduce some of the inevitable finger pointing that occurs when complaints come in.
Eliot Greenwald, deputy chief of the Disability Rights Office at the FCC, said in a webinar about closed captioning responsibility that “the order assigns responsibility for the quality of closed captioning to video programming distributors and video programmers. Up until this order takes effect, the video programming distributors would be the ones responsible for captioning.”
Under the revised order, responsibility for the quality of close captions falls to the entity that has primary control. Greenwald explains: “Video programmers − those are the people that produce the programming − are responsible for closed captioning problems that stem from production of the captions and transmission of the captions up to the point where they are handed off to video programming distributors. VPDs are responsible for quality problems that are the result of the VPD’s faulty equipment and failure to pass through the closed captioning data intact to the viewers.”
Based on this order then, cable operators and other VPDs appear to be off the hook for everything other than a subset of problems that can occur in the process of trying to deliver closed captions that are accurate, synchronous, complete and properly placed as the FCC mandates. But is that really a safe conclusion?
In fact, while the order does shift the burden of responsibility in a more equitable way, cable operators are still required to receive and address complaints. And the burden can only be shifted “if, after conducting an investigation, the video programming distributor determines that the problem was not within its control but appears to be within the control of the video programmer,” Greenwald says.
In other words, don’t retire that closed caption and troubleshooting equipment just yet – you are the primary line of defense and the burden of proving and diagnosing the causes of faults − at least enough to determine who’s to blame − is up to you.
Monitor Those Streams
One of the more powerful ways to keep tabs on close caption quality is make sure your source-to-edge monitoring system includes compliance monitoring capabilities. The system should check that the captions are present and not in error. When errors do occur, it should let you know how long they were in error and the reason for the error. There are over a dozen types of syntax and structure checks that need to be performed to make sure there were no errors introduced in the transmission chain and that the captions are viewable on the end users screen. And, of course, reporting is more important than ever.
This type of monitoring is what keeps your house in order. But there can be many less obvious cases. There are countless variations in set-top boxes, such as whether they decode only EIA608 or EIA708 as well, and in caption styles and formats. It’s entirely possible that a video programmer may have supplied captions, but they are formatted incorrectly or may fail on one set top box but appear fine on the next.
For example, like in the screen images below you could have black text on a black background or mismatched big and small fonts showing concurrently.
Even though problems like these and many others may not be occurring with your transport equipment (although they could be), you’ll still need to perform in-depth closed caption syntax and compliance analysis using a tool that can decode and analyze compressed video and audio streams. These PC-based tools can perform syntax and compliance analysis and offer the ability to render captions over video, save captions to standard file formats and debug capabilities.
The latest FCC order on closed captions give cable operators a way to shift burden for errors to video programmers, but it’s hardly a free pass. Ultimately, the only way to can ensure you comply is with a comprehensive set of monitors and analysis and debug tools.
Steve Holmes has more than 30 years of video experience. Before joining Tektronix, he spent 20 years with GTE/Verizon installing, teaching, engineering, and managing video and cable TV systems. During that time, he was teaching video transmission and video engineering to non-video engineers. He was involved in one of the first video-on-demand, near video-on-demand, fiber to the home (FTTH), fiber-to-the-node (FTTN) and hybrid fiber/coax trials before the development of digital video compression systems. For the past 19 years, Steve has worked as a senior video applications engineer at Tektronix consulting and teaching test methodologies for broadcast, studio, cable, and manufacturing for customers based in the United States and Western Canada.
