Creating Accessible Visual Content for People with Epilepsy

Why are we talking about this?

Here at Epilepsy Action, we are aiming to create a world without limits for people with epilepsy. This includes making sure that everybody is doing what they can to remove any limits that currently exist.

One area of particular interest among the epilepsy community is moving, visual media. More specifically, and media that might contain flashing, flickering or blinking images. This sort of content can trigger seizures for individuals with photosensitive epilepsy (PSE), who make up around 3.5% of people with epilepsy.

Part of the treatment plan for all people with epilepsy is avoiding anything that might trigger seizures. As such, it is essential for people with PSE to stay away from flashing or flickering lights or images as much as possible. When it comes to media content, this means ensuring either that triggering content is removed from the content, or that sufficient flash warnings are put in place at the start of said content.

Standards and Guidelines

At this point, the logical next question is, ‘how do we know what constitutes unsafe content for people with PSE?’ Thankfully, there are standards in place to help content creators navigate this issue.

As a broad start, all media content in the UK is expected to meet OfCom’s standards in a wide range of areas, including PSE. To quote:

“Television broadcasters must take precautions to maintain a low level of risk to viewers who have photosensitive epilepsy. Where it is not reasonably practicable to follow the Ofcom guidance, and where broadcasters can demonstrate that the broadcasting of flashing lights and/or patterns is editorially justified, viewers should be given an adequate verbal and also, if appropriate, text warning at the start of the programme or programme item.”

Other authorities providing guidelines for UK content include the following:

• If you’re in the UK and you’re producing content for marketing or advertising, you must follow the Advertising Standards Authority rules.
• If you’re in the UK and you are working in the public sector, then you need to make sure that your content complies with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
• The UK’s disability discrimination laws led to British TV regulators producing the Guidance Note for Licensees on Flashing Images and Regular Patterns in Television. Many online producers use their guidelines to check their content.

Looking specifically at web content (as a lot of the moving media we consume nowadays is online), the World Wide Web Consortium (W3C) is the organisation for international standards on the internet. Their accessibility guidelines recommend that web content:

• Has reduced contrast for any flashing content;
• Avoids fully saturated reds for any flashing content;
• Reduces the number of flashes, even if they do not violate thresholds;
• Provides a way to stop any flashing content before it begins;
• Slows down live material to avoid rapid flashes (as in flashbulbs);
• Freezes the image momentarily if there are 3 flashes in 1 second;
• Drops the contrast ratio if there are 3 flashes in 1 second; and
• Allows users to set a custom flash rate limit.

They finally say that, if the potentially triggering content cannot be controlled (including stopping the content from starting), then the effects should not be used.

Following relevant standards and guidelines is the responsibility of brands and companies creating media content, and it is a mandatory requirement.

There are two reasons for this. For one, it is illegal to discriminate against disabled people, and ignoring the needs of people with epilepsy is a form of disability discrimination. For two, although flashing lights only affect a small percentage of all people with epilepsy, their inclusion without appropriate flashing lights warnings in media content is seen as negligent and discriminatory by the entire epilepsy community. This, in turn, can be damaging to the reputation of the brand/company who owns that content.

Issues with Current Testing

As well as standards and guidelines, there are tests that media content needs to go through to check for for PSE triggers.

In the UK, we have two: the Harding Test, which is used by OfCom to test all media content for PSE triggers; and Clearcast, which specifically looks at clearing adverts for broadcasting.

Both of these tests are based on guidelines originally created in the early 1990s, after an advert for Pot Noodles was thought to cause three cases of epileptic seizures. Since then, modern society has become far more reliant on screens, and said screens have become bigger and better able to handle fast-moving graphics.

That could mean that media content that passes the Harding test might still trigger seizures in people with PSE.

Going the Extra Mile – Japanese Screening Settings

What happened with O2 raises the question of whether the standards for PSE testing we use in the UK need to be updated.

The difficulty with creating new tests to screen media content for PSE triggers experimentation would need to be carried out, and that experimentation would involve exposing people with PSE to potential seizure-triggering content. This does not comply with modern-day ethical standards.

As it happens, there is a stricter set of standards for detecting PSE triggers available than what is currently used in the UK. In 1997, 600 children in Japan were hospitalised after having seizures that were triggered by an early episode of Pokémon. As a result of this incident, Japanese broadcasting authorities created their own test for PSE triggers in media content.

After the O2 advert in the case study above was pulled from public viewing, it underwent this test, and failed. This suggests that, had O2 known about and used the Japanese test when the advert was originally screened, they could have saved themselves a lot of time, money and potential controversy.

If you are interested in doing going the extra mile for people with photosensitive epilepsy, you can test your content against the Japanese standards by going on the Harding Test website, running a new Manual Test, and ticking the option at the end of the Test Details that says ‘Test with Japanese/NAB 2006 spec.

As of August 2024, the test will cost £30 and will ensure that your content is being screened for PSE triggers using the most rigorous standards available. This, in turn, will also save your business a lot of money, time and energy.

Want to know more?

If you found the contents of this article helpful and would like to know more about epilepsy, epilepsy triggers, or Epilepsy Action’s 2024-2030 mission, why not take a look at the information linked below?