Alternatives to the ESRB?

Smartbomb co-author and friend-of-Game|Life Aaron Ruby caused a stir last week on Next-Gen when he slammed the ESRB game ratings system for failing to take gameplay into account:

...the system is geared to mimic systems used for other media. It’s not constructed to even acknowledge videogames as a kind of communication through models, a medium that is different in kind from TV and movies.

So now he's back this week with a new piece that explores alternatives to the ESRB, in particular calling the notion that ESRB raters couldn't possibly have the time to play through the games they rate "a total and utter red herring":

It’s absolutely not necessary for raters to experience every possible game state a particular title is capable of in order to rate gameplay rather than movies of gameplay. Instead, a method that allows raters to easily and arbitrarily access any part of the game world is all that is needed. It’s really not that tough. Game reviewers have been doing this for years.

Hey, if this makes game ratings "less vulnerable to government intervention," as Ruby states, I find it hard to mount much of a defense. But would it really stave off the feds? It's not like this would have prevented Hot Coffee.