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


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.

Yellow Fever: Causing Confusion over Registered Interpreters

Sign Language Interpreters in the UK are regulated by the NRCPD. The main, and only for most, professional membership association is ASLI. The differences are clear cut. One regulates: provides a register, deals with complaints and looks at how to become a stronger regulator to ensure that in future the profession will be protected. One supports and develops the profession by providing training, CPD, information and guidance, representation at all levels and strong networks of interpreters so we are all in contact locally and nationally.

The NRPCD could still do some more work on publicising the register. They initiated the Sign Safe campaign this year, trademarking the term along with the yellow registration badge. With the additional hard work of interpreters the message has been getting out to the Deaf community: an NRCPD registered interpreter has a ‘yellow badge’. A registered interpreter is a mark of someone who has been through training and is safe to practice. Someone who turns up at an appointment with no badge is someone who has not yet gone through training or is not committed to providing a certain safeguard for Deaf consumers, or to those bookings interpreters, where users can submit a complaint.

The system may not be perfect but it is still important we have faith in that system and all work towards improving it.

Even interpreters who have been long time opponents of the register have joined up in recent years. We have come to a watershed moment. The NRCPD have made a few unpopular decisions recently causing uproar. This is partly due to the legality of CRB checks. It is apparently safer to ask interpreters to hold their own CRB checks and to ask the consumer to check them. Not easy when not using a reputable agency, not easy for Deaf people trying to book direct. This decision is in part due to the government changes from CRB to DBS checks and the decision that the spoken language interpreters’ register, NRPSI, could not hold details. (NB: NRPSI after representations from professional associations now includes standard CRB/DBS checks and provides details of security clearances in their listings.) All interpreters know how easy it is for them to be in situations where they are left alone with the vulnerable. The government is of the opinion that interpreters will be in the presence of other professionals at all times which is not the reality. An unscrupulous interpreter could very easily do a lot of damage, were they that way inclined, to the Deaf person they are with. The naivety of the government in making these blanket decisions about interpreters is astounding. They clearly have not consulted nor listened.

Just as we have seen over the last 18 months, the continuing solidarity of NRPSI registered interpreters, despite criticisms or government changes, is still as apparent today. They are supporting and publicising their register in order to distinguish trained professionals from those with no interpreting qualifications.

All Sign Language Interpreters seem to want the same thing: regulation, an independent register, more protection of our title and profession; we just cannot agree on how to do it. Perhaps it is easier for us to rally against each other? Perhaps the only time some of us feel we have a voice is when we are arguing with each other? Or perhaps some of us just do not want to work together or know how. Just as we have seen a split in those supporting the register, we have a seen a split in those willing to be part of ASLI.

A few years ago an alternative membership organisation was set up under the guise of disagreeing with compulsory CPD, a move that later saw a u-turn decision usually only seen in government departments. This very cheap organisation, offering no benefits bar insurance and a badge, attracted interpreters by cost who did not value being part of a profession. Whereas for even less than the membership fee, at around £35, interpreters can get insurance from companies such as Hiscox.

Why bother to mention this association when there are bigger things to focus on? One wonders why interpreters would support an organisation such as this and what the motivation is behind the latest move which does not support the interpreting consumer’s need for clarity, undermines the register and is more evidence of a lack of support for the profession: the latest membership badge is yellow.


Clarity over CPD: It remains with the register

Any Sign Language Interpreter up to date in the UK will by now be aware that compulsory CPD has been introduced by the registration body, NRCPD and revalidation starts from registration renewal in 2013.

Many interpreters complained when ASLI members voted in compulsory CPD as part of ASLI membership. Many believed it would kickstart the NRCPD into introducing it. They did and ASLI members voted to drop compulsory CPD at the last AGM in September and leave this, rightly, with the registration body. ASLI has better things to be getting on with. ASLI can get back to supporting the members and providing support for interpreters to gain their structured and unstructured hours with quality opportunities at discounted prices. This blog has previously covered how to ensure you are completing CPD in a way that is value for money.

Any interpreter worth their weight not only knows the value of CPD but why we should prove we are doing it. For consumers, the profession as a whole and protecting it eventually. Not only do we have clarity but the trend that can already be seen a month on from the vote is that the number of ASLI members is increasing already.

Market Solutions Part 1: Protecting the Profession

There has been much criticism of the outsourcing of interpreting services to private agencies and the problems it causes for the profession on this blog. There have not been many recommendations offered. There will be, over time, a series of blogposts on the solutions we could put in place to counteract negative changes in the market and the subsequent decline in standards in some areas of work.

The most obvious answer to what is happening is to protect the title of interpreter. As a profession of Sign Language Interpreters we seem to bring up this topic every few years but have yet to get to the stage where we can submit an application for a variety of reasons.

Protection of title would mean in order to work legally as an interpreter you must be a Registered Sign Language Interpreter (RSLI). In the same way you can not work as a Social Worker or any number of health professionals unless you are registered with the Health and Care Professions Council. You can not work as a Doctor unless you are able to register with the General Medical Council having completed the relevant training. To call yourself an Interpreter without being registered would incur a warning, a fine and a possible prison sentence.

How can we as interpreters apply for legal status and therefore protect the title of interpreter?
There is much work to do in one sense if we consider the financial climate and the unwillingness to use interpreters who have achieved standards in some areas, especially medical. The NHS has outsourced much of its interpreting services with dire consequences for Deaf people in areas where the contracts provide unregistered signers. In some ways we could get there relatively quickly if we pull together.

One way towards protection of title would be to become a Chartered body. This could be done by NRCPD or even, ASLI.

In order to do so an organisation needs to apply to the Privy Council for a Royal Charter. An example of chartered organisations, whose members are protected, are Royal Institute of British Architects (RIBA), Institution of Engineering Designers (IED), Chartered Institute of Legal Executives (CILEx) and Chartered Institute of Linguists (CIoL).

The steps we need to take and the comments on our progress are below:

(a) the institution concerned should comprise members of a unique profession, and should have as members most of the eligible field for membership, without significant overlap with other bodies.
The NRCPD has the majority of qualified interpreters on the register. More interpreters should become members of ASLI if they wish to work towards becoming protected. Strength in numbers is key.

(b) corporate members of the institution should be qualified to at least first degree level in a relevant discipline;
We can consider this point achieved.

(c) the institution should be financially sound and able to demonstrate a track record of achievement over a number of years;
Whether we are talking about NRCPD or ASLI this is true. Again, there could be more growth and achievement if every interpreter became a member of ASLI.

(d) incorporation by Charter is a form of Government regulation as future amendments to the Charter and by-laws of the body require Privy Council (ie Government) approval. There therefore needs to be a convincing case that it would be in the public interest to regulate the body in this way;
We have all experienced the damage that unregistered and unqualified interpreters can do. It is most definitely within the Deaf community’s interest and the wider public interest in ensuring there are only bona fide interpreters used. For example in the areas of medical, legal and social care where damage can be done to people’s lives or significant costs incurred by the state. Think miscommunication, think misdiagnosis, think mistrials.

(e) the institution is normally expected to be of substantial size (5,000 members or more).
Sign Language Interpreters can not fulfil this criteria at present so we would have to either:
– put the point across that we are a niche profession and apply to be accepted for Royal Charter on the basis of having 1,000 or so either on the register or in training.
– join together with spoken language interpreters in order to bolster our number although any interpreters or membership of an interpreting organisation would still need to adhere to the above criteria.

Another way of protecting the profession through regulation by government is by getting the use of Registered Interpreters into law. It is already a ‘reasonable adjustment’ under the Equality Act 2010 to provide an interpreter. Many organisation are using budgets as a way to renege on their responsibilities and to say it is not a ‘reasonable adjustment’ if they do not have the funds to pay for one. A more guaranteed way is to propose a BSL Bill and incoporate access into the bill as it is in the current BSL Bill being proposed to the Scottish Parliament.

Worth also noting is the current government steer is to ensure all professions in health are protected titles via the HCPC and this extends to anyone who may ‘touch’ the patient. As interpreters we might have to tap the client on the arm to get their attention, we may be doing hands-on interpreting for a Deafblind client or an elderly client may lean on an interpreter or grab their hand for support. For registration we need not only the correct qualifications proving we have reached the National Occupational Standards in Interpreting but also the essentials any professional should have: an enhanced CRB check, professional indemnity insurance, a Code of Conduct and a way for people to complain should you not be providing a good service. Allowing unregistered interpreters to be near the patient exposes them to people who do not have these safeguards. Allowing agencies, via outsourcing, to provide unregistered interpreters means that the government goes against its own agenda, no just for health but in other areas.

Whether we apply for Royal Charter, have interpreting and access as part of a BSL Bill or lobby for specific legislation to cover interpreting legally, government regulation of the Sign Language Interpreting profession fits in with government steer and parts of current legislation. This posting touches the tip of a legal iceberg. With the decline in standards in the provision of interpreting seen over the last two years, the disservice done by the government to Deaf people and the lack of cohesion amongst some groups of interpreters, whichever way we do it, it is about time we put protecting the title of interpreter back on the agenda.

CPD: Avoiding the Expense

In the previous post the importance of CPD was discussed and it was alluded to that they were many other types of CPD not just the high expense, potential low value, sometimes dubious quality training courses. There are of course quality training courses led by experienced trainers who have had years of interpreting experience or for relevant subjects that cover important topics for interpreters and have high value.

It should also be noted that going on a training course about a specific domain such as police work does not automatically mean one is ready to start interpreting at the police station. The level of skill is important and asking for feedback from an experienced peer will give you a better barometer of readiness.

There exists a plethora of inexpensive or alternative ways of collecting and proving your CPD. Most interpreters are aware of these but here follows a small selection:

a) Self-reflective practice – keep a journal on your professional practice. Note down patterns, possible weaknesses or areas for improvement. There used to be a phrase: if you think you’ve stopped learning it’s time to get out. As interpreters we never stop.

b) Study – read some articles on a particular subject and write up what you have learnt. Material never runs out with new research published continuously.

c) Take part in an interpreters’ meetings – either present, attend or, again, write up what you have learnt. This could be an ASLI meeting, peer-to-peer supervision, informal meetings with other interpreters discussing subjects of choice. It is simply about your learning and keeping a record as evidence.

d) Attend a conference – or even deliver a paper or a training course.

e) Attend the Deaf club or a different Deaf event such as a BSL gallery talk, a Healthy Deaf Minds or an Our Space meeting. Or something similar in your area.

f) Volunteer – to do some interpreting, give time to ASLI or the Deaf community for a specific task of interest to you. Campaign work and raising awareness is hot on the agenda with budget cuts affecting everyone.

g) Write – a blogpost, a paper, an article.

h) Mentoring – get a mentor or mentor someone if you are trained to do so.

i) Supervision – slightly different from mentoring in that there is more of a focus on discussion of issues that arise form work.

j) Record yourself interpreting – whether at home or on a live assignment. You can record yourself then watch it back to see if you can pick out anything in particular. After we finish our training we stop doing this as much as we should. Go one step further and do some analysis using some of the tools available such as Cokely’s miscue analysis or use another tool.

k) Use the Internet – to keep up with news, learn new signs, another sign language or brush up on International Sign skills. YouTube is obviously a great resource. There are some existing websites aimed at CPD such as PD4Me and eCPD webinars, some of which may apply to SLIs.

l) Watch someone else interpret – and make notes on your learning. BBC news or Sign Zone can be useful.

m) Learn or research possible different ways of interpreting concepts or phrases. Watching Deaf translators interpret from a script can be insightful and can provide us with more economical ways to interpret a concept or a different way of representing something more visually.

n) Watch or participate in an e-learning seminar which, in comparison to training courses, are often cheaper and sometimes free.

o) BSL coaching – improve your BSL skills by working one-to-one with a coach.

p) Research a new domain and shadow an interpreter working to gain the necessary skills before you start to interpret in the new setting.

There are many more suggestions and the above categories could be infinitely expanded upon.

Some activites can also cover different types of CPD. For example, volunteer to interpret (points), for a talk for which you have to prepare (points), that you can record and use to complete a further analysis (points), and discuss with collegues (points) or use in supervision or mentoring (again, points).

Really the only limit is your imagination so you can steer clear of expensive CPD if you wish. Please leave a comment if you have more ideas to access free or cheaper resources or ways to collect CPD.

The Importance of CPD

CPD has divided the profession, if we are to believe that this was the real reason why an alternative membership organisation was set up.

In reality CPD was voted in by members of ASLI. I voted for it. Erroneously I believe now but only because it took so long for the NRCPD to make it mandatory. Though it was not really a mistake. If ASLI had not have done it first if may have taken many more years.

Why is CPD, as a mandatory requirement of registration, so important?

1) A registration body who has CPD as a requirement is taken much more seriously as upholding the standards of a profession. We would never gain protection of title without it. By that I mean it would be illegal to call yourself and work as an interpreter if you are not a Registered Interpreter. That is the one thing we should be aiming towards. Together.

2) One argument against compulsory CPD is that many interpreters say they do it anyway. Then it is easy. All that needs to be done is record it. Why wouldn’t you want to prove your learning, your commitment to the profession?

3) Another is that it is too expensive. CPD does not just come in the guise of training courses which are often expensive and not always guaranteed to be of good quality. There are plenty of organisations who churn out less than interesting courses with dubious trainers. You can get free or heavily discounted training as an ASLI member too. Another blogpost follows this one which categories some of the many alternatives to expensive CPD.

4) Occasionally one comes across an interpreter who qualified years ago and has done nothing since. They can be hard to work with, it may be hard to even discuss how to work together on an assignment and as result of no learning, they could be out of date, deskilled and unsafe. That, in my opinion, is one of the best reasons for having CPD. Deaf people deserve to have committed professionals of quality, not another category of people making money off the back of the Deaf community.

5) Some interpreters object to the compulsory part, calling it dictatorial and authoritarian. For reasons discussed in point 4, it has to be that way. Some, unfortunately, have to be made to complete any kind of professional development. From another perspective if you are doing it anyway then no-one is forcing you to complete it. You are only being asked to record what you have done and provide evidence.

There were other arguments against CPD when it was being mooted at the time, which are no doubt out of date two years or so down the line. CPD may be relatively new for us and no doubt it will take time to bed in.

For many mandatory CPD is a must and the Institute of Continuing Professional Development sums it up perfectly:

‘Commitment to CPD is also an acknowledgement that becoming professionally qualified is not an end in itself – it is merely the beginning. Updating skills and knowledge on a continuing basis is essential to career progression, particularly given the passing of the ‘job for life’ and rigorously-defined career path cultures.’

For the Sign Language Interpreting profession in the UK, we have seen a paradigm shift, one which was repeatedly asked for and is now being established. CPD is here to stay and rightly so. Most of the profession agree, it is accepted by the majority and it will be the norm soon, if it is not considered to be so already. As always, it unfortunately takes some people longer to accept change.

Post to follow soon: CPD – Avoiding the Expense