Subtitles for the deaf and the hard of hearing on TV
Legislation and practice in the UK
By Chris Higgs (London UK)
Based on the transcription of talk given in Forlì on 17th November 2006.
Keywords: legislation, ofcom, quality assurance, digital broadcasting, live subtitling, legislazione, qualità, televisione digitale, sottotitolazione in diretta
©inTRAlinea & Chris Higgs (2006).
"Subtitles for the deaf and the hard of hearing on TV"
inTRAlinea Special Issue: Respeaking
Edited by: Carlo Eugeni & Gabriele Mack
This article can be freely reproduced under Creative Commons License.
Permanent URL: http://www.intralinea.org/specials/article/1696
The UK has led the way in the provision of subtitling for the deaf and hard-of-hearing (SDH) for over twenty years. If you are deaf, then the UK is the place to watch television: in 2007 over 90 channels will carry subtitles especially aimed at the deaf and the hard-of-hearing. These channels are across the range of analogue, digital, satellite and cable platforms. Away from that, more than 200 major cinemas have the facilities to project subtitles for the deaf and hard-of-hearing. For broadcasting, legislation to provide these services is imposed by the Government and is managed and overseen by Ofcom, the broadcast regulator in the UK. The growth in these services has led to a very competitive market with low cost subtitling rates and service providers looking at more efficient ways of supplying subtitles. My company, ITFC, is one of the leading providers of subtitling and access services in the UK.
In the UK there are 8.6 million people with hearing impairments. They can enjoy many hundreds of hours of subtitled programmes. Recent research shows that SDH are regularly used by some 7 million people and 30% of the deaf population uses subtitles all of the time. Before the most recent legislation was enforced in 2003, only terrestrial broadcasters were required to provide subtitling. The Communications Act of 2003 requires subtitling, as well as in-vision signing and audio description for the visually impaired, to be provided by channels across all platforms. Channels on the digital platforms were set 10 year-targets to achieve 80% subtitling of their output, with 60% to be achieved within the first five years. Audio description and signing have lower targets. Twenty years ago, ITV and BBC were providing subtitles for about 15 hours of programming per week. This has now grown to between 80-90 % of the channels’ output. Other channels’ targets are lower but growing and it is estimated that 95% of programming in peak hours on all channels will be required to carry subtitling in 2007.
In the UK there are now hundreds of channels available. However some of them have a very small audience share and some of them are not aimed at a UK audience. In 2003, Ofcom selected 50 channels that should supply the access services, but this number will be increased to 90 channels by 2007. Of these channels there are two 24-hour news channels (BBC news 24 and Sky News). To decide which channels have to provide these services, Ofcom sets a formula excluding those channels with less than 0.05 % of the UK audience share. As for the other channels (with 0.05% or more of the UK share), if 1% of the channel’s turnover revenue does not cover the costs of providing the service, Ofcom may exclude them from provision in order to ensure that services do not financially burden those channels with low revenue. The cost for SDH in the UK is around 300-350 euros per hour to a broadcaster, and clearly this influences the growth of subtitling. Further exceptions would be given to channels whose programmes may not benefit from subtitling such as the shopping channels; other channels may have technical problems in providing subtitles. As for the number of programmes to be subtitled, BBC has the higher target, 100% by 2008, while for the targets for the non-public sector broadcast channels (cable and satellite channels), everything depends on when they started providing the service. Most of them are moving to about 35% by 2007 and to 80% by 2010.
Ofcom is keen to ensure that a growth in quantity of subtitling does not affect quality. There is Ofcom guidance on how subtitling should be presented to screen. This includes reading speeds, positioning, use of colours etc. Broadcasters must consult with viewers of subtitles to ensure that they are providing the quality of service that viewers require and they must also monitor their output. Ofcom may from time to time monitor the quality of the subtitling output themselves, particularly if there are a number of complaints. Channels with small quotas (some cable and satellite channels) must subtitle their most popular programmes, and all channels are discouraged from using too much repeat programming to fulfil their subtitling quotas. Finally, if there is an interruption to the subtitling service, an apology must be broadcast. The headlines in the Ofcom guidance for subtitling include: synchronization and block-style presentations for pre-prepared programming, although scrolling subtitles can be used for live programming; reading speeds must be controlled and there should be no delay in presentation of pre-prepared programs and no more than a 3 second delay for live programming; two line subtitling is preferred to three lines; colours must be used to denote different speakers and backgrounds used for contrast; sounds and effects must be subtitled where necessary; mouths and any on screen text must not be obscured; subtitles are normally expected to be placed at the bottom of the screen within the safe area; subtitled programmes must be listed correctly in guides, particularly on the electronic programme guides on the cable and satellite services; all programmes carrying subtitles must have an in-vision on screen caption before the programme advising that it is subtitled; finally, all national emergency announcements must be subtitled.
Like many countries, the UK is switching to totally digital broadcasting. In the UK this is to be phased in over a four year period starting in 2008, region by region across the country. Within the plans for the digital switchover there is consideration for “vulnerable” people including those with sensory impairments. Digital technology does allow better quality subtitling for the viewer, as especially designed fonts allow a much clearer text than the current analogue teletext style. This uses a minimum text height of twenty TV lines. Another consideration is that the subtitling service should be retained even when channels are changed, so the viewer switching channels maintains the subtitle service. The downside is that some set top boxes currently in use do not carry subtitles, but it is hoped that this will be improved before the digital switchover. TV For All, a UK consumer experts group, had already recommended in 2003 that the following should apply for subtitler users :
• ease in locating and using subtitles;
• reliability of set top boxes;
• easy access;
• simple navigation of subtitles;
• single and legible buttons on remote controls with simple layouts;
• easy cable connections on set top boxes should be provided as well.
ITFC also provides live subtitling, delivering about 280 hours per week to its clients - ITV, GMTV, RTÉ (the Irish national broadcaster). Though using a variety of methods, the majority of ITFC’s live output is produced with stenography. On some programmes old fashioned fast qwerty keyboards are still used, but it is very rare these days. ITFC is now replacing these methods with respeaking. They have developed some advanced technical solutions to allow remote re-sourcing and have created a large pool of stenographers across the other side of the globe, in Australia, where there is an available resource of such skills. Over 3000 hours (or 20%) of their live subtitling per year for UK channels is produced in Australia for ITFC. This is done with high quality and accuracy, and with minimum delay. It just proves to say, that it is a small world today!
 More detailed information on the 2003 Communications Act available on-line at http://www.opsi.gov.uk/acts/acts2003/30021—i.htm#303; see also Ofcom’s Code on Access Services: http://www.ofcom.org.uk/tv/ifi/codes/ctas/ (last access 20.12.2006).
 Ofcom’s guidelines available on-line at http://www.ofcom.org.uk/tv/ifi/guidance/tv_access_serv/guidelines/#top (last access 20.12.2006).