Station Compliance›Field Notes

Captioning is usually filed mentally under accessibility, which is correct but incomplete. For the next month it is also a program chain security question, because the device that inserts captions into your transmission is equipment the FCC now requires you to secure.

That overlap is worth using. You are going to be walking the plant before September 29 anyway.

Where the two rules meet

§ 11.35(d) applies to EAS equipment, STL equipment, and any remotely managed equipment that routes, processes, or inserts content into the transmission of your programming.

A captioning encoder inserts content into the transmission. That is its function. So it needs, by September 29:

• A password of at least 15 characters with no dictionary words, not reused anywhere else in the facility — or an alternative authentication measure if the device cannot hold one
• Security patches and firmware updates installed promptly after release
• To sit behind a firewall or comparable network segmentation that limits remote management access to authorised devices and users

Meanwhile § 79.1 governs what that same device is producing, and § 79.2 governs what happens during an emergency. Same box, three rules.

The § 79.1 quality standards, briefly

The captioning rules are not satisfied by captions merely existing. § 79.1 sets quality standards covering:

• Accuracy — matching the spoken words and speaker identity to the fullest extent possible
• Synchronicity — coinciding with the spoken words and appearing at a readable rate
• Completeness — running the length of the programme
• Placement — not obscuring other visual content, and not being obscured by it

Placement is the one where emergency operations and captioning collide directly, and it is worth thinking about before the night it matters.

What actually breaks

In small and mid-market television the recurring failures are not editorial. They are plumbing:

The encoder passes through captions it never receives. A network feed arrives without captions, or with captions the encoder cannot parse, and nothing downstream notices because the encoder is doing what it was told.

Local content is uncaptioned. Syndicated and network programming arrives captioned. The locally produced segment, the sponsored insert, the emergency cut-in — those depend on your own workflow, and the workflow has gaps.

The pass-through dies silently. A firmware update, a router change, a format change upstream, and captions stop. On a monitor wall nobody has captions enabled, so nothing looks wrong.

Nobody monitors it. This is the same structural problem as the secondary audio stream: the failure is invisible to everyone in the building and visible only to viewers who cannot report it in a way that reaches engineering quickly.

The audit, folded into the security walk

You are already going to be in front of this equipment. Add these:

1. Turn captions on and actually watch. Ten minutes across a network programme, a local segment, and a break. Not a decoder readout — captions as a viewer sees them.
2. Check placement against your crawl. Trigger a test crawl and confirm the two do not overlap or obscure each other.
3. Check the secondary audio path while you are there. § 79.2(b)(2)(ii) requires emergency information shown outside a newscast to be spoken on the secondary audio stream, preceded by a tone, in full at least twice. The detail is here.
4. Now do the § 11.35(d) part on the same box. Default password? Second interface with separate or no authentication? Reachable from outside the building? Firmware revision recorded?
5. Write down what you found. Nothing gets filed for the security rule — the record is for whoever inherits the plant.

Why bundling them is the right call

Compliance work at a small station fails for one reason above all others: it is a task with no daily symptom, owned by nobody in particular, competing against work that breaks visibly.

The September 29 deadline is the rarest thing in that environment — a hard date that forces someone into the rack with a checklist. Everything you can honestly attach to that trip gets done. Everything you defer to a quieter month does not, because the quieter month does not arrive.

Captioning, emergency audio and program chain security all live in the same three or four devices. One walk, three rulebooks.

The TV scope guide lists what § 11.35(d) covers in a television plant, and the crawl inserter article covers the device most stations have not counted.