Flash detection based on frame histogram

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Hello,

I'm developing a tool to detect video sequences that are harmful to viewers with photosensitive epilepsy.

I'm considering to detect flash sequences based on the frames's histogram. The sequences of flashes should not last more than 5 seconds and it is not permitted to have more than 3 flashes in 1 seconds (aprox separated by 8/9 frames in a 25 fps display).

Do you have any tips to how to implement this verification?

I'm considering to base my approach on the difference of histograms along a 9 frame gap.

Best regards.