NRCPD Statutory Regulation Survey

The NRCPD have sent out a survey to communication professionals to assess their thoughts on statutory regulation. The deadline is Friday 11th July.

My answers are below. If anyone has any comments please post in response:

1. Do you support the NRCPD aim of statutory regulation? Yes

I support the aim of statutory regulation. I am not convinced the NRCPD are the right body to hold this as it is still not independent from Signature/CACDP and I haven’t been happy with the way UKCoD have dealt with the AtW enquiry and how interpreters have not been involved as much as they should have been.

2. Do you think requiring registrants to agree to a code of conduct is a good thing? No

The Code of Conduct is too prescriptive and does not allow for the breadth of ethical decision making that a BSL interpreter has to practice every day. The Code of Ethics was much better and reflective of other professions. A teological approach to ethics rather than deontological would be much more suited in the case of interpreters. This is a much more up to date way of thinking in the interpreting profession (see Dean and Pollard’s Demand Control schema).

3. Do you think requiring registrants to continue their professional development is a good thing? Yes

I agree with CPD but do not agree with the way that NRCPD have mandated that some hours should be structured but also limited to only courses about interpreting. This has created a market for CPD courses but not increased the value of CPD to practitioners of more than five years post qualification. For example I would like to attend courses on voice production, mime and another language. I believe these would all enhance my work as a practitioner but none of these courses would fit the NRCPD’s criteria. I have completed most of the courses that are on offer in the market and am struggling to find anything that would enhance my professional development.

The rather arbitrary numbers allocated to structured and unstructured do not make sense and were not created in consultation with interpreters.

The more experience one has the more unstructured CPD is completed rather than structured: peer supervision groups, clinical supervision, evaluating ones work, attending or facilitating interpreter meetings, volunteering for interpreter organisations, reading research and articles.

I also do a number of hours of voluntary interpreting which I often record and evaluate.

I would recommend that NRCPD readjust the hours of structured and unstructured or rather put the total amount of hours an interpreter should complete without being prescriptive.

I would recommend that NRCPD allows courses indirectly related to interpreting to be counted as CPD.

I would recommend that NRCPD consult interpreters when reviewing CPD.

4. Are you willing to meet with members of the NRCPD Board to discuss statutory regulation, continuing professional development and the code of conduct’ if the opportunity arises? Yes

Further comments:

The NRCPD should consider asking TSLIs to take an ASLI trained mentor and provide funding to ASLI to provide this. Currently any RSLI can support a TSLI and they would not necessarily have the skills to offer that support.

Before any statutory regulation takes place Signature should be completed independent from NRCPD.

The alternative would be that another body holds the power to regulate.

When representations about interpreters are made to government the NRCPD should be representing the interests of interpreters as well as Deaf people rather than the view of Signature or UKCoD. This represents a direct conflict of interests and independence is paramount

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PSA accreditation: It has nothing to do with the medical model

PSAThe NRCPD has sought answers from the Professional Standards Authority (PSA) as to whether they could apply as a voluntary register to be accredited. We still have no clear answer but is this really a move towards what some perceive as aligning interpreting to a medical model?

Our history as an emerging profession of Sign Language Interpreters has lead us from the DWEB (Deaf Welfare Examination Board) interpreters to CACDPs first register in the 1980s which mostly consisted of those already working with Deaf people – social workers and Teachers of the Deaf. In the late 1980s funding was sourced and the Citi Services course became the first training course for interpreters. We were moving away from the helper model towards a more professional route into interpreting.

At the same time models of Deafness went from the medical model to social model i.e. there is nothing wrong with the individual that needs to be treated but rather that it is society that causes barriers. Then to a cultural model in which Deaf people have their own culture and language.

If only the government saw Deaf people that way. What we have had since 2010 is an tidal wave of outsourcing of interpreting services which has seen the lowest bidder win contracts across all sectors. This has been especially bad with cash strapped hospitals, mental health trusts and primary care services. Many NRCPD registered interpreters can no longer get any medical bookings now. Many Deaf people are not provided with registered interpreters when attending appointments. The examples of interpreters being used are few and far between. Just see the Our Health in Your Hands work for surveys and, for real life examples, the BSL Act Spit the Dummy campaign. Contract holders often send BSL users to hospitals to interpret who then tell Deaf people they left their yellow badge at home (the NRCPD one).

Outsourcing contracts to providers who are able to get away with not using registered personnel is going back in time and it goes against the government’s health and social care agenda. The only antidote to this is to ensure that all medical services book a NRCPD Registered Interpreter for Deaf people at their appointments. We know the damage it does if they do not. See the RNID’s A Simple Cure report, the TEA report. See the current work by OHIYH. See SignHealth’s long awaited Sick of It report, launching soon.

To ensure only NRCPD Registered Interpreters are used in medical settings is not going back to a time when the medical model is the prevailing paradigm. Sign Language Interpreters will not have to change their behaviour whilst interpreting nor will they be recognised as only being used for appointments. It is merely a step towards providers only being allowed to book Registered Interpreters rather than the situation now where Deaf people sign consent without knowledge of what they sign, struggle to understand how to take medication, their diagnoses, their prognosis and any treatments prescribed.

Whether PSA accreditation will actually get us a step closer to statutory regulation is unknown. Yet. PSA takes responsibility for both overseeing statutory regulators as well as voluntary registers. It requires registers to undertake audits, to make themselves more fit for purpose. The PSA can only improve the NRCPD and strengthen our position in getting ourselves seen as professionals and ensuring Deaf people have appropriate access. At medical appointments.

We will still work in the media, in courts, at police stations, at art galleries, at wedding and funerals, in work places, at conferences and anywhere else that Deaf people are present and want to gain access in a culturally appropriate way, in sign language. Let’s not confuse models of deafness with one of the areas in which we work. Or used to. With some work by the register we may well work in medical settings once more.