Standpoint on the quality and means of preparation of subtitles for hearing impaired persons in audiovisual programmes
At a meeting on 26 January 2016, the National Broadcasting Council adopted a Standpoint on the quality and means of preparation of subtitles for hearing impaired persons in audiovisual programmes
1. Legal status
The Broadcasting Act of 29 December 1992 (Journal of Laws of 2015, item 1531 as amended), hereinafter referred to as the “Broadcasting Act”, stipulates that broadcasters of television programmes subject to it are required to ensure the accessibility of programmes for visually impaired persons and hearing impaired persons by introducing appropriate aids: audio-description and subtitles for the hearing impaired and interpretations into sign language, so that at least 10% of the quarterly transmission time, with the exception of advertising and teleshopping, is provided with such aids (Article 18a.1 of the Broadcasting Act).
Article 47g of the Broadcasting Act imposes the obligation to gradually ensure the availability of programmes provided for disabled persons with sight dysfunction and hearing dysfunction on providers of on-demand audiovisual media services through the introduction of appropriate tools such as audio-description, subtitles and interpretations into sign language.
The Regulation of the National Broadcasting Council of 28 May 2013 on the lower share of programmes with aids for visually impaired persons and for hearing impaired persons in the television programme service (Journal of Laws of 2013, item 631), issued pursuant to Article 18a.2 of the Broadcasting Act, decreases the quota of aids for impaired persons in certain television programmes. The Regulation stipulates that the share of programmes with aids for visually impaired persons and for hearing impaired persons in the television programme service amounts to:
1) at least 1% of the quarterly transmission time, excluding advertising and teleshopping, for programmes:
a) with population coverage not exceeding 200,000 inhabitants;
b) transmitted over telecommunication networks other than those used for terrestrial distribution or satellite distribution if the number of individual viewers does not exceed 50,000;
c) whose daily transmission time without reruns, advertising and teleshopping does not exceed 2 hours per quarter on average;
d) specialist programmes devoted to music;
2) at least 5% of the quarterly programme transmission time, excluding advertising and teleshopping for programmes:
a) with population coverage not exceeding 500,000 inhabitants;
b) whose daily transmission time without reruns, advertising and teleshopping does not exceed 5 hours per quarter on average.
In its present form, the Broadcasting Act does not define subtitles for hearing impaired persons. Furthermore, the legislator did not provide the National Broadcasting Council with rights to specify such definitions via a regulation. In the present legal status, the only act that specifies the understanding of the term “subtitles for hearing impaired persons” is the Broadcasters’ Self-Regulation Act, i.e. an agreement among broadcasters of programmes transmitted via digital terrestrial television on the manner of fulfilling obligations resulting from Article 18a of the Broadcasting Act regarding aids for hearing impaired and visually impaired persons in television programmes 
. The Act stipulates that subtitles for hearing impaired persons are understood as:
2. Preparation of subtitles for hearing impaired persons in television programmes
subtitles in the native language which constitute the text equivalent of spoken dialogues or narration, closely corresponding to images visible on screen, containing differentiation among persons in the dialogue (with colours or with the use of text identification marks: initials, character’s name, etc.) and text descriptions of sound effects;
“live” subtitles as a service providing hearing impaired persons with access to audio content accompanying images in near real-time (with a slight time shift), used in news and current affairs programmes;
subtitles that render the dialogues and narration of foreign programmes available via text in the native language.
Quarterly reports submitted to the National Broadcasting Council by television broadcasters on the obligation to ensure the availability of programmes for sensory impaired persons show that subtitles for hearing impaired persons constitute a definite majority of offers of programmes with aids (this tendency also appears in other countries). For example, in programmes transmitted via terrestrial digital television, programmes with subtitles for hearing impaired persons (data for the 3rd
quarter of 2015) range from 5.5% (one of the commercial sports channels) to 36.5% (TVP Channel 1) of the transmission time, excluding advertising and teleshopping.
The clear advantage of programmes with subtitles for hearing impaired persons over other aids listed in the Broadcasting Act (i.e. sign language and audio-description) results from the fact that the inclusion of subtitles in the production process of a programme is relatively easy with respect to technical and organisational issues for media service providers, as well as the least costly process in comparison to interpretation into sign language or audio-description. However, this observation does not refer to “live” subtitles appearing in programmes whose substance relies, in a significant part, on the content produced and broadcasted in real time. These are, for example, news programmes, sports and other reports and programmes with a high amount of political or journalistic discussion, which refer to current events. Programmes of this type have so far been provided with a limited number of subtitles for hearing impaired persons, resulting from technical and organisational difficulties occurring during the process of providing them in real time.
With regard to rapid technological changes, knowledge about the re-speaking
and ongoing work on the use of this method for preparing subtitles for live television programmes, significant improvement is expected in this area.
As far as guaranteeing proper subtitle quality for hearing impaired persons is concerned, general recommendations in this respect are included in this Standpoint. As for more detailed issues, broadcasters of television programmes and authors of subtitles may look for support in specialist source materials, e.g. those listed in section 6: “Final information”.
3. Purpose of including subtitles in audiovisual programmes
The main purpose of including subtitles for hearing impaired persons in audiovisual programmes is to remove the communication barrier resulting from the hearing dysfunction and, in a broader perspective, to provide deaf and hearing impaired persons with potentially satisfactory reception of audiovisual programmes. The level of satisfaction in this respect does not depend exclusively on the manner of preparation and distribution of subtitles (the responsibility of the programme broadcaster/ on-demand service provider), but also on factors that are directly independent of them. This is related to the technical conditions of the method of broadcasting (analogue or digital television) and the manner of distribution (terrestrial, satellite, cable), as well as the properties of receiving devices (teletext/ DVB subtitles), the configuration and the servicing of which depend on solutions applied by the manufacturer (various software types, differing structures, various user settings). Furthermore, the level of the satisfaction derived by the viewer from subtitles for hearing impaired persons in audiovisual programmes also depends on the degree in which the range and the level of vocabulary used in the subtitles corresponds to the user’s linguistic competences and individual expectations.
Developing a uniform formula for editing subtitles which would satisfy the expectations of all viewers to an equal degree is therefore impossible: persons who were born deaf will have different linguistic competences and consequently different expectations with respect to the level of detail, length and size of subtitles than children or people who lost their hearing after early childhood; these competences will also be different in the case of persons with varying degrees of hearing impairment, including the elderly. This problem has lesser significance only when a given programme is addressed to a target group with a specific profile (e.g. children or seniors).
4. Viewers of subtitles for hearing impaired persons in audiovisual programmes
As mentioned above, the audience for subtitles for hearing impaired persons in audiovisual programmes does not constitute a uniform group. In simple terms, this group may be divided as follows:
deaf persons (average hearing loss above 90 dB), including:
- people born deaf or people who lost hearing in early childhood; their first, i.e. native language, is usually the visual-spatial language known as Polish Sign Language; their reading skills in Polish, treated as their so-called second language, tend to be seriously limited;
- persons who lost their hearing after mastering the spoken language; they are familiar with Polish language and can usually perform lip-reading;
hearing impaired persons, i.e. persons with partial hearing impairment (average hearing loss below 90 dB), including elderly people.
It is estimated that there are approx. 45,000 deaf people in Poland, approx. 900,000 people with hearing impairment in at least moderate degree and approx. 3 million people with minor hearing impairment, which makes it possible to estimate the potential audience of subtitles for hearing impaired people as constituting approx. 10% of Poland’s population. The World Health Organisation assumes an even higher index, i.e. that approx. 15% of the population has hearing problems.
Furthermore, subtitles for hearing impaired persons may be used by hearing people for whom subtitles offer additional help in understanding the content of a programme, including foreigners learning Polish, as well as other viewers who, due to a variety of reasons, cannot or do not want to use sound in the audiovisual television broadcast.
5. Basic principles for preparing subtitles for hearing impaired persons in audiovisual programmes
The basic function of subtitles for hearing impaired persons is to substitute for sound – primarily the content of the soundtrack, but also non-verbal sounds (if they appear in a programme), which cannot be identified visually and which carry information of fundamental significance for understanding the programme.
An audiovisual programme contains one version of subtitles for hearing impaired persons, which in practice means that, in the case of a programme not addressed to any particular target group, it must be a version useful for the largest possible audience. As such, a compromise is required due to the diverse needs and linguistic competences among hearing impaired persons. In this context, it is necessary to bear in mind that deaf people who are not familiar with the Polish language or who use Polish to a limited degree may primarily use television programmes interpreted into sign language (Article 18a.1 of the Broadcasting Act lists both subtitles for hearing impaired persons and interpretation into sign language as aids for hearing impaired persons).
From the point of view of the average viewer of subtitles for hearing impaired persons in audiovisual programmes, it is important to ensure that the use of such subtitles comes simply and naturally and that the subtitles reflect the content of the soundtrack as faithfully as possible (any discrepancies between the subtitles and utterances of characters may pose difficulties in reception of the audiovisual programme). Selection of information and abbreviations should be used only when it is not possible to observe the above condition. Two challenges should also be taken into account:
subtitles for hearing impaired persons are intended to provide the content of oral utterances, which means the necessity of reconciling colloquial speech with the rules of written language;
subtitles must appear on screen at a specific moment and fit within the limited time of the broadcast, which may prove quite difficult due to the slower speed of reading compared to the speed of the characters’ speech; furthermore, a lower speed of reading is assumed for hearing impaired persons than in the case of hearing persons.
Therefore, in spite of the clear resistance of certain groups of hearing impaired persons with respect to applying abbreviations in subtitles to audiovisual programmes, this solution is sometimes necessary in order to ensure the required synchronisation.
Taking the above premises into account, the general principles for preparing subtitles for hearing impaired persons in audiovisual programmes may be considered as follows:
information selection: it is necessary to determine which information is needed to capture the essence of the message and how to formulate this information in order to make it understandable for the potentially broad range of users of such an aid; in the first place, these are utterances but also – depending on the type of the programme – non-verbal sounds important for understanding the core of the programme, especially when their source is not visible; however, it is recommended to avoid description of obvious sounds, the occurrence of which clearly follows from the picture;
legibility – good recognisability (visibility) of subtitles: the text of the subtitles should clearly stand out from the background against which it is placed (the need to ensure good contrast, for example via shadowing, outlining the font in black or using a semi-transparent background). Differentiation of characters is possible with the use of text identifiers (e.g. initials, name of the character, etc.) or via font colour (one colour assigned to a given character). It is not recommended to introduce a great number of colours (in the subtitles to audiovisual programmes in Poland, apart from the basic white colour, yellow is usually applied, as well as cyan, green and potentially magenta; the use of red is not recommended) and their use in a given programme should be consistent. The use of special characters (e.g. caps, brackets) may serve to provide additional information (e.g. on the manner of speaking, sounds, background music, etc.);
legibility – proper distribution of subtitles on screen; the so-called spacing of subtitles should take into account the best possible synchronisation with the image (whenever possible, subtitles should ideally be synchronised with cuts and scenes) and the principle that one subtitle should fit within two lines of text (in exceptional situations – in three lines of text). Furthermore, the subtitles should not block out the subtitles from the film, credits (e.g. in news programmes), the lips of speaking persons (to allow lip-reading) or activities important for understanding the meaning and the course of action in the programme;
display of subtitles – time of display, which, on the one hand, should be accurately adjusted to the speed of reading (it is assumed that in the case of hearing impaired persons, the speed of reading amounts to 12 characters with spaces per second on average) and, on the other hand, should maintain synchronisation of the displayed subtitles with the action in the programme. In the case of subtitles for children, the time of their display should be extended. Furthermore, subtitles for children below 11 years of age should be reduced with respect to the volume of text and maximally simplified with respect to vocabulary;
comprehensibility of subtitles: subtitles should be formed from simple and concise (but not overly shortened) sentences and from commonly used words. It is necessary to avoid acronyms or specialist and sophisticated vocabulary; however, the characters’ utterances should not be censored. One subtitle (i.e. text that is displayed on screen and disappears being replaced by subsequent subtitle) should constitute a single semantic whole; the line should not end with a preposition, pronoun, etc. Furthermore, subtitles should correspond to the logical structure of a sentence and be correct with respect to grammar, punctuation and linguistics (unless linguistic errors characterise a given character, which should be taken into account in subtitles);
as far as possible, preserve the character and the style of utterance of characters and the rhythm of such utterances. This refers to the emotional nature of an utterance and the lexical (and not inflectional or phonetic) style, e.g. if dialect or archaic language is used. If it is not possible to preserve such elements, they should be signalled using a relevant strategy, which should make it possible to convey the character of the programme in this respect.
In foreign programmes with voice-over, it is a good idea to synchronise the subtitles not so much with the voice-over, but with the picture, i.e. the original soundtrack of a film. When there are foreign language inclusions in a foreign programme (e.g. a film), which are not translated for hearing viewers, subtitles for the hearing impaired may specify which language was used (e.g. “speaks in Italian”) or quote a given utterance in the original language (e.g. “buongiorno”), so that hearing impaired persons who know foreign languages have equal access to the original.
It is recommended that subtitles for hearing impaired persons be prepared in teletext form when the programme, in line with the knowledge or approval of the broadcaster, is distributed or re-transmitted over analogue cable networks (the service is available after the user selects the teletext function in the analogue television set).
6. Final information
The source materials which were used to prepare the section of this Recommendatory Standpoint devoted to the general principles of preparing subtitles for hearing impaired persons are:
BAI (Broadcasting Authority of Ireland) Guidelines – Subtitling;
bbc.co.uk, Online Subtitling Editorial Guidelines v 1.1., compiled and edited by Gareth Ford Williams, 2009;
CSA (Conseil Supérieur de l’Audiovisuel), Charte relative à la qualité du sous-titrage à destination des personnes sourdes ou malentendantes, Paris 2011;
ITC, Guidance on Standards for Subtitling, February 1999 (standards adopted by the British regulatory authority Ofcom);
Izabela Künstler and Urszula Butkiewicz, Napisy dla osób niesłyszących i słabosłyszących – zasady tworzenia, prepared for Fundacja Kultura bez Barier, 2012;
Izabela Künstler, Napisy dla niesłyszących - problemy i wyzwania;
Agnieszka Szarkowska, Monika Laskowska, Jakie powinny być napisy? Report examining viewers’ preferences with respect to television subtitles, 2014.
Chairman of the National Broadcasting Council
The Agreement was signed on 5 June 2013 by: TVP SA, Telewizja Polsat, Telewizja TVN, Telewizja PULS, Polskie Media (TV4), ATM Grupa S.A. and Stavka Sp. z o.o. In 2015, the broadcaster of Stopklatka TV joined the agreement.
method consists in using a computer programme for speech recognition (such programmes are already available on the market for the Polish language). In live programmes, the re-speaker
listens to the original utterances and repeats the words (or, if necessary, paraphrases them) into a microphone connected to the speech recognition software. The re-speaker also dictates the necessary punctuation marks and other elements (colours, labels of speakers), adjusting the utterance to the perceptive abilities of hearing impaired persons. Subsequently, the re-speaker’swords are processed into a text displayed in the form of subtitles on screen. The entire process should take place with the shortest possible delay in comparison to the original utterance. Bearing in mind the current capabilities of speech recognition software for Polish, the cooperation of the re-speakerwith an additional person who moderates and corrects the resulting text seems to be necessary.
In the case of subtitles for hearing impaired persons received as teletext or whose source is teletext (e.g. decoders of digital cable television), the final result, i.e. distribution of subtitles on screen, does not depend on the broadcaster, but on formatting of the image by the producer of the television set/decoder (subtitles may be displayed differently in sets by various manufacturers).