InterGame looks at the role of the testing lab within the gaming industry and the challenges it faces...

Advances in technology have, without doubt, benefitted the gaming and amusement industry. They have allowed for new features to be introduced, superior software and hardware design and firmer control over the industry. But technology can also bring with it obstacles, particularly when it comes to approval processes for varying markets.

As technology changes, so do the needs and requirements of the various regulatory boards, something which testing labs around the world have to continually keep up with. InterGame spoke with some of the major names in the testing field involved in the gaming industry and the next few pages should give you an insight on the tough job they face every day and the challenges the industry brings them…

Trisigma
Trisigma may have only been founded last year, but it has a wealth of experience and knowledge behind it in Frank Otte and Rob Hubregtse and is quickly establishing itself as major testing lab for the Netherlands. Now looking to extend its focus, this year the company will aim to grow the number of markets it offers it services to for both land-based and internet/mobile gaming.

"Thanks to technology we have seen a transition from mechanical slot machines to electronic, from single entity machines to server-based, as well as a move to PC-based software and the changes are bound to continue," said Hubregste. "During all of this we have worked to help the industry and regulators adopt these new technologies and standards, while keeping the markets secure and auditable. Technology keeps everyone involved sharp and on the ball… New technology is fun.

"Apart from the usual adopting of individual internal tooling and training for new advances in machines, it is particularly interesting to see how regulators react to new technologies and how it affects the legal process and requirements. That is why we get involved right from the beginning."

For Otte, the countries with legislation that covers consumer protection and looks to reduce crime and fraud, while legalising all market segments so that it is fair and accepted, have the best potential of good gaming legislation. Without these objectives, he told InterGame, legislation is usually inconsistent.

"Because most national laws still focus on gaming machine approval as one physical product, new creative innovations or modifications are hard to apply due to physical restrictions," he said. "Dividing this approach into a more component based approval system could help all interested parties. It is also important that the legal market is economically strong enough to avoid an uncontrollable illegal market, which is an issue for most markets at the moment."

Looking forward, for Hubregtse it would be beneficial, in terms of cost and efficiency, if legislation wasn’t about the gaming machine entity but more about modularity and standardised interfaces between modules. "This is a model that we promote as it will benefit both the industry and the regulators. However, the old way of thinking, of one gaming machine and regulating this machine, is quite prevalent," he said. "Even online gambling systems are treated quite regularly as just a bigger gaming machine."

BMM
Since opening its doors in 1981, BMM has been helping regulators ensure the integrity of gaming operations. It ensures manufacturers provide gaming equipment compliant with established rules and that operators configure and manage their equipment as required. Its services, for the technical sector of the gaming market, have evolved with the advancement of innovative and technological developments. Conducting tests to confirm a gaming device is compliant with rules is not sufficient to ensure that it will remain compliant with the rules once placed in operation. BMM assists in writing technical standards and internal controls in order to establish transparency in the regulatory process. Upon request, it also provides its own experts to conduct operational audits to verify that equipment is installed and operating as required.

BMM is recognised in over 350 jurisdictions to provide services as required - whether this is actual testing services or in an advisory role to the government. Commenting on the changes within gaming, Wendy Anderson told InterGame: "Concerns with security and integrity have always been the challenge for regulators who author the rules that permit technological innovations. The testing lab works closely with the regulator to assist in analysing new products or changes to existing products to see whether the changes fit within the framework of existing rules.

"The latest issue for operations is the reliability of server-based gaming where the servers are no longer in the same facility or perhaps the same jurisdiction," continued Anderson. "While this concept is already successfully used for wide area progressives, a server-based game using cloud computing will be the next hurdle for regulators. Typically, the non-gaming commercial world will continue to innovate with this new technology and that development and exposure helps pave the path for providing the necessary assurances that regulators will need for adapting and approving."

According to Anderson, often there are bureaucratic and legal restrictions in the jurisdictions that cause delays to the rule-making process as well. "There are some jurisdictions that have comprehensive rules but expedited rule-making processes," she said. "What may be perceived as complex legislation generally results in a well-defined process for establishing clear rules, the end result of which is that the manufacturer knows what to build and the testing lab knows how to conduct its tests. A strong engagement process, while tedious due to learning curves and details, provides the regulator and operator with a greater chance of consistency in their gaming operations."

Eclipse Compliance Testing
For Nick Farley, Eclipse president, internationally there needs to be a standardised approach to regulating types of gaming machines, for the gaming industry to move forward with its regulation. Further, gaming regulatory agencies that engage in a monopolistic testing laboratory model, whereby they ‘contract’ with a single testing laboratory, need to look at jurisdictions where a competitive model exists. "It is quite evident that competition breeds best practices and avails regulators to a wealth of industry experience and new technologies," he told InterGame.

"Australia is one of the only jurisdictions in the world which evaluates the testing performance of the independent testing laboratories operating within the country. We wish more jurisdictions would take this approach’ it is a great way for the regulator to truly known if their authorised laboratory is providing them with a high level of compliance testing or not. Currently, outside of Australia we know of no true measure of a laboratory’s quality."

Eclipse Compliance Testing provides regulatory compliance testing for electronic gaming devices, online slot monitoring and accounting systems, VLTs and VLT central systems, amusement and redemption devices, as well as keno and bingo systems. It primarily deals with North America and has authorisations in Canadian provinces as well as Macau.

"There will always be inherent differences between VLTs, Native American Class II bingo systems, charitable gaming and traditional slot games, but there should not be major differences in how each of these types of games are regulated from one jurisdiction to another," continued Farley. "The way the industry regulates each of these types of games can vary greatly and this complicates the process for the manufacturers and it potentially limits effective regulation for those jurisdictions not up to par with a more robust approach to regulation. A standardised approach would simplify rather than complicate the regulatory landscape."

NMI
NMi offers quick market access to Europe. It offers testing and certification services for both remote and land-based gaming in all regulated jurisdictions. NMi and G4 have also joined forces in the field of responsible gaming and together offer certification and the opportunity for responsible organisations to raise their profile.

According to Eveline Janse, many existing laws in Europe are outdated. "A lot of legislation assumes a single game on a single machine, which is seldom the case now," she said, "so interpretation comes into the process and lines of communication with regulators are essential. With the current rate of technological advancement it would be preferable if laws focused more on the things you want to achieve than specific technology.

"Technology makes our job more interesting. Our team includes a large proportion of software, electronic and communications engineers, as well as gaming professionals, so we are able to understand the innovation our customers bring to us and deal with their technical people on an equal footing.

"What is important is not the volume of tests but to have clarity and consistency in the requirements," continued Janse. "We are experienced in most markets so the processes are quite straight forward for us. The most complex area is the differences between countries, which makes it very difficult and expensive for manufacturers to enter the different markets."
Looking forward, for Janse at some point the whole industry must move to some sort of remote environment, either VLT or server-based or through the internet. "The online model where controls are based around the customer rather than around the point of consumption seems to offer advantages to all parties," she told InterGame.

GLI Europe
Gaming Laboratories International and TST Global provide a wide range of testing and consulting services to the global gaming industry covering AWPs, VLTs, electronic bingo systems, slot systems, progressives, lotteries and more, testing for more than 455 jurisdictions globally. The companies have abundant resource capacity in terms of physical lab space and total number of employees to serve any new jurisdiction that might need its testing and consulting services and an office was recently opened in Puerto Rico to serve the Caribbean and Central America.

Technology advances every day, according to GLI Europe managing director Phil Barow, and protocol standards, such as those from GSA, have helped suppliers’ R&D process and helped to make possible what many perceived as impossible just a few years ago. However, that progress has resulted in devices and systems that are much more complex and more challenging to test than ever before.

"Today’s technologies simply cannot be tested the way they used to be," he told InterGame. "Today’s technologies require teams of engineers and separate teams of mathematicians to fully and thoroughly test devices and systems, ensuring they meet the regulations for each particular jurisdiction.

"Some labs say the new technology has made no difference in their process and that any device and system can clear testing in 10 days, just like the devices and systems from years ago. That is simply understating the reality of today and not acknowledging the complexities involved. At GLI, our goal is to maintain the same speed in testing, which means we have hired additional staff, expanded capacity and assigned dedicated teams. To do otherwise is to fall short in our responsibility to our clients, the public trust and the industry as a whole.

"As an independent testing lab we are professionals who respond to the needs and regulations of our clients," continued Barow, "so, from our perspective, none are more complex, challenging, fair or strict than another; rather the rules and regulations of each jurisdiction are exactly as they need to be to fit the needs of that particular jurisdiction and the public trust they seek to maintain. It is not our role to pass judgment on their rules and regulations; it is our job to ensure that whatever the rules and regulations are, we are accurately testing to those guidelines."