I'll begin with some history. The Recreational Software Advisory Council is an independent, non-profit organization which provides and promotes a voluntary, content-labeling, rating system for recreational software and other media. We were established with the help of the Software Publishers Association in September of last year in a direct response to the threat of legislation from Senators Lieberman and Kohl. They were determined to do something about the rising levels of violence and explicit sexual material in video and computer games. "Night Trap" became their notorious example together with "Mortal Kombat", the game where your winning move is to rip off your opponents head and pull out his spinal cord.

RSAC was faced with a difficult task. It needed to respond quickly to the threatened legislation, but it didn't want to replicate the movie industry's age-based rating system, which had come under increasing attack for being too subjective, secretive and severe on sex, but lenient on violence. Age advisories seemed increasingly inappropriate when research clearly showed that not all thirteen year-olds are the same nor are all parents of thirteen year-olds the same. We were looking for a way to provide objective and detailed information about the content of a software title without making a judgment as to who should or should not see it.

We took as our inspiration, the FDA food labels which give consumers quantifiable information about the fat, carbohydrates and sugars in, say, a can of soup, but it doesn't say if your over 350 pounds, you can't eat the stuff. We were also determined to have an open system, based on criteria which could be discussed, challenged and revised by software publishers, community groups and consumers. And we needed a system that could respond quickly to the tight time frames that most developers in software work under.

One other problem. Interactive CD-ROMS can take, on average, over 100 hours of viewing before you have uncovered all of the content. Multiply that by the estimated 1,500 recreational titles released each year and that gives you a scale of the challenge we faced. It was simply not possible to have a full, prior review of each and every title.

So we turned to Dr. Donald Roberts, Chairman of the Communications Department at Stanford University and an expert on the effect of TV violence on children. He created a content-disclosure system, linked to a clever questionnaire with an in-built algorithm which would branch the publisher through a series of highly specific questions about the level, nature and intensity of the violence, sex and language in the product. At the end of the process, the ratings or advisories are automatically calculated together with a brief descriptor, such as: Revealing attire or Provocative frontal nudity or in the case of "Doom", Blood and gore. If a product does not rate for violence, sex or language, it receives an "All" rating - that is, suitable for all audiences.

Provided that the publisher has completed the questionnaire in a logical way, we will dispatch the rating in artwork format to the company within 48 hours of receipt of their application. The publisher then places the advisory directly onto the front of the box and uses it in promotional material and ads.

As it is a self-disclosure system, we needed to inhibit any inclination on the part of a software publisher to cheat. Once the questionnaire is completed, the company then signs a three-page contract stating that they have fully disclosed and making them liable to hefty fines and threats of removing software from retailers shelves if they have been found to have willfully misrepresented what was in the product. A series of further checks and balances was put into place with the creation of a team of RSAC auditors based at Yale University. Between 10 and 20% of titles we receive each month are sent, together with cheat guides and god codes, to our auditors who then perform a complete review of the product and check the accuracy of the rating. In addition, any consumer group, media watchdog or parent can contact us with a complaint that a product was sold with an inappropriate advisory.

To date we have rated over 350 titles with companies such as Broderbund, id Software, Disney Interactive and Davidson. Retailers, such as WalMart, are beginning to insist on rated titles before they will give them shelve space and companies are increasingly seeing the marketing benefits of giving consumers detailed information upon which to make their purchasing decisions.

Which brings me to the Internet and PICS. The political pressures being faced within the Internet community are similar, if not more severe, than those faced by the software industry last year. The RSAC experience and the RSAC advisory system, itself, may give some grounds for hope. All this year, we have been in close contact with many of the software companies that have developed blocking devices for the Internet, such as, Microsystems Software with their "CyberPatrol", SurfWatch, NetNanny and KidCode. We have kept close to the PICS developments and have signed on as enthusiastic partners to this enterprise.

And we are developing "RSACi" or RSAC on the Internet. Our Working Party deliberations include on-line providers, major software companies, academics and makers of blocking devices. We are tackling a formidable challenge - to adapt the RSAC self-disclosure system to Web sites. The vast number of web sites together with their complexity and amount of material, makes a self-disclosure system far more desirable than a full, prior review system. Our plan is to create the means to deal with the high level of granularity on the Web. Rather than simply authorizing an advisory for a web site, we hope to offer the ability to go into a web site and allow for a much larger number of small rating events. Thus, the high school student can gain access to the Jimmy Carter interview conducted by Playboy in 1976 at Playboy.com, but not the December Playmate of the month.

Under our proposed scheme, web masters would download the RSACi Ratings Questionnaire and go through the site, with the help of those who have provided material for the site, and rate whole sections or pages or even, individual graphical images. Once the ratings have been authorized by RSAC, a label would be attached to each part of the web site and then be read by the blocking devices, such as "CyberPatrol" and either allowed or blocked depending on how the software was configured by the parent.

This new scheme would require different legal and financial arrangements than we currently have for recreational software. Currently we deal with incorporated companies who make games. In the future could be dealing with institutions, community groups and individuals as well as Time Warner's Pathfinder and AT&T's web site. The issue is then raised of whether we charge the content provider or the user for this service. Or do we look to the intermediary, the internet provider, to underwrite us as a ratings bureau. These details are still to be resolved, but we are confident that RSACi will play a major role in providing objective and detailed advisories, compatible with the PICS standard and that can be read by the growing number of screening devices coming on to the market.

In the meantime, it is our sincere hope that Congress will get the message that voluntary regulation of this kind is far more preferable than heavy-handed legislation that is constitutionally unsound and a detriment to the continued growth of the World Wide Web.