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

I am a BSL level 3 signer can I charge for signing?

A thorough check of the stats for this site show that there are some interesting search terms that have led people here. Amongst the normal searches for ‘Anonymous Interpreters’ and ‘sign language interpreting blog’ were the below. In a bid to right some misinformation and myths out there, there follows some comments:
BSL level 2 signer pay
Level 6 BSL signer pay
How much do level 3 BSL interpreters charge?
ads for unqualified BSL interpreter low rates
Court signer
Can I interpret in courts with a GCSE

There are two comments:
– The terminology of Signer Vs Interpreter – There is a clear distinction between signers who have some BSL qualifications but have not yet attained fluency in sign language against the National Occupational Standards. Registered Interpreters have attained fluency and have additional training in interpreting. Not everyone with language skills can be an interpreter. Any news item on the Ministry of Justice contract shows that with clearly.
– It is shocking so many people want to either hire those with basic levels of sign language or want to work using these qualifications. Let’s leave Deaf people alone, this includes children, and give them the service they deserve i.e. Registered Interpreters who have the appropriate qualifications and experience.
BSL tutors, you have a responsibility to the Deaf community at large not to encourage those that are unskilled to work as unqualified interpreters.
Do I need to register as an interpreter?
Yes.
Do I need to book a signer for a job interview?
Can children interpret for Deaf parents in the police station?

– The Equality Act 2010 states that Deaf people have a right to access services. A signer does not need to be booked for a job interview, a Registered Sign Language Interpreter does or whichever service a Deaf person has requested such as a Registered Lip Speaker.
– Absolutely not. Using children to interpret is tantamount to abuse. It may have happened years ago but no-one should be using children any longer. The Met has one of the best systems for booking interpreters and its guidelines are transparent.
Why do I need a CRB?
If I set up a business agency why do interpreters need CRB checks?

– CRB checks protect any vulnerable people interpreters may be working with. Any agency should be aware of the importance of these checks especially if they are booking interpreters for the following: child protection, mental health, courts, police, social services and medical bookings. Agencies are not monitored, registered or regulated and this is just one example of why their working practices and their employment standrards should come under close scrutiny. Especially with funds coming from the public purse.
Who is against compulsory CPD?
What are the arguments against CPD?

– The system we have for compulsory CPD is very new and as a consequence too basic. It is nowhere near the kind of regular check an interpreter should have to gauge their skillset. The system of collecting points is not an ideal refection of the safety of someone to practice. Is it just the system of collecting points that people are so against? We have even seen one organisation supposedly set up in opposition of CPD make a major u-turn and they seem to have now accepted that principle though many of their members still do not. A clear indication there is no representation of their membership.
Will the Big Word give me lots of work?
– If you are cheap, yes, or if you do not mind working for less under a sub-sub-contract. Currently Remark and Action on Hearing Loss are providing The Big Word with reduced-rate sign language interpreters.
Sign language devalued interpreters
Spending cuts on interpreters since 2010

– This blog has reported both the devaluing of interpreters and the affects of outsourcing and spending cuts on the interpreting profession in the UK regardless of the law or the government’s commitment to equality.
Access to work fraud
Access to work I need an interpreter not a CSW

– Access to work is currently a bit of a mess. Valued and absolutely necessary to Deaf employees and business owners but the bane of many people’s lives when they spend much of their time trying to get claims assessed, fighting for interpreters rather than unqualified personnel and sorting out the subsequent claim forms. Not only that but some agencies that Deaf people relied on to book interpreters have been involved in fraudulent claims, not doing any favours to the Deaf community they purport to serve. There will be a future post on this topic.