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  1. #1
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    An insider's take on what's wrong with the ESRB and ESRB response

    Whilst quite long, it's an interesting read on how games are rated, something that isn't often clear.


    I used to scoff at videogame reviewers who complained about all the terrible games they were "forced" to play. I don't do that anymore, because I understand. I worked for the Entertainment Software Rating Board (ESRB), the industry's only official body for evaluating and labeling game content, and I rated approximately 700 games during my time there.

    So I know what it's like to play (and, more often, watch) lousy games. More importantly, I know what's wrong with the industry's rating system, which has had a rough ride lately after the Grand Theft Auto Hot Coffee scandal, Manhunt 2 Mature-rating controversy, and -- worst of all -- pressure from politicians to legally regulate the system.

    I'd like to point out the problems and offer solutions. But first, a word about the ESRB itself. The majority of the people I encountered there were hardworking, intelligent folks who were just as passionate about videogames and the gaming lifestyle as you or I. My intentions here are to speak to those at the ESRB who truly care about videogames and to kick them out of their complacency. You have the power to change the ratings system before it becomes irretrievably lost. Something desperately needs to happen here because the alternative -- a government mandated and controlled rating scheme -- is a downright frightening concept. Here are six ways to improve things....

    1. Reboot the system

    The ESRB should be flexible, ready to change quickly or move forward as fast as this rapidly evolving industry. They did adopt the E10+ rating in 2005 and hired six full-time raters this past spring. While these changes are nice, I believe they need to go a bit further.

    First and foremost, the ESRB's ratings system desperately needs to be updated. Its fundamental flaw is the "lame duck" Adults Only rating that no one will support (Nintendo, Sony, and Microsoft have repeatedly stated that no AO game would be allowed on their consoles, while retail outlets like Wal-Mart and Target have refused to stock AO-rated games, thereby banishing them to a retail version of the Phantom Zone). ESRB management has talked about changing the system, but for now that's all it is -- talk. Any monumental change would have to be approved by the board at parent agency the Entertainment Software Association, and they do nothing on a whim. My suggestion is this: Change the letter ratings to E(veryone), E(veryone)10+, T(een)13, T(een)16, and M(ature). AO goes the way of the dodo and Mature now becomes the top of the scale, recommending that players be 18 and older to purchase. My other strong suggestion is to do away with the static content descriptors ("cartoon violence," etc.) and use a more free-form approach like the Motion Picture Association of America, which tailors its descriptors for specific movie content.

    2. Play the games

    What the general public may not know is that the ESRB's current pool of full-time raters (six people: three men and three women) does not actually play the games that they rate. They just watch submitted videotapes or DVDs of someone else playing the game. Now, when the switch was made from the use of a large pool of part-time raters to the current group of full-timers, the ESRB did decide to have the full-time raters actually play games as well, but these were rarely games that we dealt with in the rating process. They were just "random" titles from the vast ESRB archive, culled for busywork. And the raters were only required to play the games for four hours, anyway. For some titles, this is more than enough; for others, it is woefully inadequate.

    Instead of watching videotapes or DVDs of gameplay on a never-ending quest for the ever-elusive "pertinent content," I would strongly suggest having the raters play the games to completion and carefully log their findings throughout the playtest. I've already heard the ESRB's argument on this one: "That'll take way too long and it will compromise our turn-around time." My solution to that is simple: Hire more people. The ESRB is a relatively small organization with about 30 full-time employees. This can be bolstered a bit, and I'm sure the developers and publishers can wait an extra week or so for their ratings if they know that a better, more thorough job is being done.

    3. Forget parity

    Parity to the ESRB is like dots to Pac-Man or blood to Dracula -- a life-sustaining fuel. The logic goes like this: If game X gets a Teen rating, then it stands to reason that the sequel will get the same and so on and so forth into infinity. In my time as a rater this concept just handcuffed us more than helped us, because nine times out of 10 the other raters had no idea that the game we were viewing was the sixth in a continuing franchise. Not knowing "the parity" became a huge, confusing issue. Forget the whole concept of parity, or minimize the dependence on it, and judge each individual game solely on its content and nothing else. It just makes things easier that way.

    4. Drop the curtain

    I used to tell a joke while working at the ESRB that their acronym should be changed to CIA -- I never understood why the board was so secretive about their modus operandi and why we, as raters, couldn't be known to the general public or ever speak to a reporter. I finally asked about this and was told that it was for our protection, to "save" us from unscrupulous publishers or journalists who might offer us money for a favorable rating or some inside information. The idea of it sounded absurd to me -- people going to those shady lengths over game ratings? Seemed a bit excessive....

    Realistically, there is nothing to hide at the ESRB. Everything was above board as far as I could tell and all the employees are well-adjusted adults who can handle themselves in complicated situations. But by acting in a secretive, mysterious way, the ESRB creates an appearance of impropriety. This serves no purpose. And if the day does come when the ESRB drops the curtain, then the general public would be in a position to offer its own ideas on improving the system as well.

    5. Let the raters rate

    It was my understanding when I was hired that I would actually be rating games. Unfortunately, that wasn't the case in some instances. The raters were viewed as more of an "electoral college," and our ratings were not always the final ones issued. Sometimes, we'd see a full letter rating change (a game we gave an M would be lowered to a T, for example, or a T raised to an M). Other times it would be a simple content-descriptor change (we would give a game the "mild cartoon violence" descriptor and it would be changed to "comic mischief"). To be fair, if/when our ratings were altered, it was usually just a simple content-descriptor change. But when this would happen, we were rarely given a sufficient explanation as to why the rating was tweaked. This was extraordinarily frustrating. The other raters and I would debate long and hard to come up with what we thought was a logical and intelligent rating for each and every game. To have it changed without any input from us was, in a word, ridiculous. Trust the raters. I know, firsthand, that they are smart and conscientious people. Let them do the jobs they were hired to do.

    6. We need competition

    Back in the day, the ESRB wasn't the only game in town. For a time, Sega and 3D0 had their own internal ratings systems, and there was also the Recreational Software Advisory Council, which folded in 1999. I know that the ESRB is the only ratings system "officially" recognized by Congress in 1994, but it seems that Congress has fallen out of love with the ESRB as of late. Who is to say that some upstart entrepreneurs couldn't contest the ESRB's status, especially now? Who says that the ESRB has to be the only game in town? The threat alone of a competing ratings entity would force the ESRB to take a long, hard look at how they are doing things and, in turn, make the necessary changes to move forward. Some may say that a competing system would just confuse things further, that it could invite government regulation because politicians could claim that the industry no longer has the ability to field a single, dependable regulating body. But what I'm suggesting here is capitalism at its finest -- the American Way, if you will. Compete or perish. We all know that the best Madden games are made when 2K puts out a strong contending product, right? So there you go. Competition produces results. Lack of competition...well, you get the idea.


    One example of the ESRB's inconsistency came at the expense of Elder Scrolls IV: Oblivion, which shipped with a Teen rating. When modders altered character models to appear naked in the PC version, the ESRB re-rated the game Mature. Unlike Hot Coffee, however, the content in this case was added by third parties rather than hidden on the disc."

    End game

    In a perfect world there would be no need for the ESRB or anything like it. Parents would do their jobs, pay attention to their children, and make informed decisions when it came to what their children could and could not play or view.

    It isn't a perfect world. I know this all too well. Parents now are busier than ever and things, important things, slip through the cracks from time to time. Being a parent myself, I'm not really happy about that, but I cannot change the way of the world. I can only try to change my piece of it.

    The ESRB's way of doing things isn't perfect either, but it's what we've got...so let's fix it before things really get out of hand and a new government-appointed "Secretary of Interactive Entertainment"" is making the decisions as to what we can and can't play.

    I know I don't want that. I know you don't want that. And I know that the people at the ESRB don't want that. Let's all make damn sure it doesn't happen, shall we?
    And the response from the ESRB president:

    A ratings system that meets parents' needs
    ESRB President Patricia Vance responds...

    A wise man once famously said that when it comes to addressing complicated issues everyone is entitled to his own opinion, but not to his own facts. So, in light of the article penned by former rater Jerry Bonner, it makes sense to consider some basic facts about the ESRB.

    The primary mission of the rating system is to help parents determine what games are appropriate for their children. To achieve this goal, ratings must be useful, consistent, trustworthy, and align with consumer expectations as closely as possible. Our organization and some highly credible independent sources -- such as the Federal Trade Commission (FTC) and the Kaiser Family Foundation -- believe we are meeting these criteria for success. Most tellingly, America's parents agree, as evidenced by the fact that 85 percent of them use the ratings according to research conducted by Peter D. Hart Research Associates.

    The FTC recently reported to Congress that the ESRB sets a "high standard" for other entertainment industries and called the ratings "a useful and important tool that parents increasingly use to help them make informed decisions about games for their children." The Parent Teacher Association (PTA) joined with ESRB in 2006 to promote the rating system to parents, after recognizing that the ratings provide parents with reliable information. Endorsements such as these are clear evidence that the ESRB is effectively fulfilling its pledge to parents.

    While it would be nice to satisfy the desire of every individual who has an opinion about the ratings, it is essential that we reflect the cultural norms of our society at large. Our current system accomplishes this task. And, as anyone who closely follows the industry can attest, we have never taken an "if it ain't broke, don't fix it" posture. In recent years, we have made numerous and significant enhancements to the system, such as the addition of the E10+ rating category and strengthening of our enforcement system. We will continue to do so if such changes serve to improve the effectiveness of the ratings. Mr. Bonner's article contains numerous misleading statements, factual inaccuracies, and misrepresentations with respect to key aspects of the rating system. The author also fails to mention the unique and limited nature of his six-month tenure at the ESRB, when a wholly new staff of full-time raters was being hired and trained. Using that period as a basis for overarching statements about our system for assigning ratings is, at a minimum, highly misleading.

    He implies that we arbitrarily change ratings after the raters have done their jobs. This is not the case. We highly value our raters' recommendations, and their opinions are always the principal determining factor when assigning a rating. But they cannot be the sole criteria on which a rating is based. To avoid confusing parents, consistency in how age ratings or content descriptors are assigned for similar types of content must be part of the process. This consistency is, no doubt, a key factor in the high levels of use and satisfaction among parents today.

    In the rare case when an adjustment is made to a particular recommendation from our raters, it is done only when it is obvious that [one of] their findings contradicts previous ratings for similar content, does not reflect cultural norms that have been established through public-opinion research, or would cause consumers to question the reliability of [our] ratings information. Our raters are informed of any adjustments. Indeed, we use such changes as a key component of the raters' training process. And, contrary to Mr. Bonner's contention, the fact that a title being rated is part of a series has no bearing on the decision.

    The thoroughness of our submission requirements and rating process ensures that all pertinent content is considered in a final rating assignment, and that our raters have an opportunity to view that content. Playing a game, which involves individual choices about which of several paths to pursue, provides no assurance that a rater will be exposed to all of the content they need to see in order to assign ratings. Once again, the author has it wrong. It is not a matter of time and resources; it's a matter of electing the most effective way to ensure all relevant content is reviewed.

    The author unfortunately also confuses our efforts to ensure the integrity and trustworthiness of the ratings system with unnecessary levels of secrecy. It is regrettable that the author does not appreciate the importance of protecting the confidentiality of the raters to avoid even the possibility of undue influence from external sources. At the end of the day, ESRB stands behind each rating it assigns, and the process by which it assigns those ratings. Speaking on behalf of all of the incredibly hardworking and dedicated ESRB team members, with whom I am extremely honored to be associated, we are grateful for all of the support we receive from the public and industry members alike, and we will continue to do everything in our power to ensure that the ESRB rating system remains an effective and trustworthy resource for parents.

    -- ESRB president Patricia Vance
    http://www.1up.com/do/feature?cId=3166933

  2. #2
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    With out knowing the who is telling the truth, its all really pointless.

  3. #3
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    The rating system is flawed just like the movie rating system. If anyone really wanted to get into or buy a movie/game that is not rated for their age group, their are ways around it. Sneaking into movies, getting your older brother buying you games etc. The rating system isn't more than an annoyance for the younger people, it doesn't hinder the smarter ones.

    The only way I can see this change is government sanctioned ratings and more control over the boards but that wouldn't benefit the gaming scene in any way.

    Best to just leave things as it is and just tweak a few things. I agree with removing the AO rating, no game EVER made or going to be made is going to get that rating. There was only one game I remember from PS where it was given that AO rating. Now if the porn industry decides to dabble in making AO games then well Sony, MS or Nintendo will not allow that anyways. No point in having a rating when it doesn't rate anything.
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