NRCPD have this week announced that they have become a “separate and independent” company and registered charity which is also a “subsidiary of Signature”. We are told that this paradox is a step along a “transition” towards “full independence”; nonetheless, the adjective “independent” appears five times. The entity was born on 1 January 2017; NRCPD’s director attended a local workshop on 2 February and updated them on this new status, a full week before registrants themselves or the outside world were informed, nearly six weeks after the fact. The Strategic Plan was also revealed, in all its vague and unsubstantiated glory. Elsewhere, in an advert for an Honorary Treasurer, we can confirm that the new NRCPD is a “wholly owned subsidiary” of Signature (the trading name for CACDP, the actual legal entity: as we’re discussing legal entities, I’ll only use CACDP hereon). So what does “separate and independent” mean, exactly?
You have to wonder whether those interpreters and agency owners enthusing about the Uber/Airbnb/Etsy model of commerce – “disrupting the market” with a “digital revolution” – have actually ever experienced life as an Uber driver themselves.
“Character-forming” is a euphemism
It was at about this time last year – early summer 2015 – that the full extent of my failure was finally confirmed. For five months, a suspicion had been growing that the Signature unit I had been persuaded to run, BSI423 “Introduction to Interpreting”, was not only prescriptive and very narrow in scope when it should have been a light and sweeping tour, but was quite literally unassessable as well. Like a painting by numbers kit with all the numbers missing and an unexpected last minute bill for fifty gallons of battleship grey.
Five months went by during which I played voice-mail table tennis, wrote many increasingly strident e-mails and did a lot of rocking back and forth in the corner of the shower crooning “Gov’mint come’n took mah baby” in order to establish that absolutely no-one involved in delivering this brand new course – myself, the centre, the awarding body – had much more than the faintest inkling of how it was actually supposed to be completed. Collectively, we all failed a small group of colleagues who were honestly trying to develop as new interpreters. (Fortunately all of them have great potential and I expect amazing things from them, regardless.)
The final deal-breaker was a suggestion, made to me by a member of staff at the awarding body, that if an assessment wasn’t working out then I might have to “make it up” a bit by asking leading questions. That’s really when I started walking away. I’m still walking.
Why is this kind of thing happening in the first place? First, we should explore what “standards” actually are. At this point you might want to supply your own Bagpuss-like wibbly-wobbly dissolve with a surreal harp scale, indicating that we are phasing into the recall of events from earlier in time or some kind of reverie.
I was quite lucky. I was introduced to the “Deaf world” and British Sign Language (BSL) by a talented teacher with a lived deaf experience and a knack for bringing a bone dry syllabus to life. The cost to me for that first life-changing intervention was five of your Earth pounds. But the giddy days of 2004, when Further Education subsidies were scattered like petals, are now just nostalgia. We could ask:
- With the public sector repeatedly “salami-sliced” since 2010, are people now signing up for beginner BSL classes as much as they did in the past? (Spoiler: no – new learners have been halved since then.)
- What is the BSL training market worth to Signature? (Spoiler: recently, a fairly consistent £1.35 million per year or so, despite the continuous loss of learners.)
- How much does it cost Signature to “regulate” BSL/English interpreters? (Spoiler: pick a number, any number.)
I sent my mechanical goblins hunting. They brought back electric bacon.
I was unable to attend Signature’s statutory regulation meeting in January due to being unexpectedly hospitalised (I’m fine now). While waiting for my belly-button to resume normal service, I did a little bit of reading and uncovered a range of interesting and depressing responses to the statutory regulation struggle in the annals of several other professions. Many of these are the kind of practitioner-focused issues that have so far (to my knowledge) been absent from dialogue. This is a long post so let’s start with the main shakedown and then move on to the sources.
Key issues raised
- Statutory regulation encourages “medical model” approaches to practice which even healthcare professionals may find oppressive, let alone those in occupations which are patently not healthcare.
- Excessive regulation – increased inspection regimes, measurements and managerialism – can lead to increased “reactivity”, a term which describes practitioners feeling a pressure to select “easy wins”, reject more difficult work, abandon more difficult clients and “cover their backs” instead of acting from best professional judgement.
- Campaigns to promote statutory regulation above self-regulation have historically resulted in schisms and increased disunity within various professions. Almost all the campaigns resulted in failure and wasted resources, even for professions between thirty and two hundred times the size of BSL/English interpreting.
- A political will is required to take up the cause of state regulation, which brings with it political scrutiny, which entails unpredictable effects such as sudden reversals of support or unexpected spotlights on bad training/practice. Statutory regulation can stop being statutory at any time should political will or public support be withdrawn: the fight to keep your status may be even more effort than that expended to attain it. The current political will is opposed to statutory regulation even for highly specialist and expert clinical professions taught over and above postgraduate level, let alone social/linguist ones with a mixed bag of vocational qualifications that verify skills instead of teaching them.
- Meta-regulators such as the Professional Standards Authority (PSA) and its predecessor the Council for Healthcare Regulatory Excellence (CHRE) have long asserted that regulation must be based on empirical assessment of “actual harm” and not “possible risk”, i.e. regulation must be proportionate to the problem it is trying to solve. A regulator that creates sledgehammer/nut issues is incompetent.
- Given that absolutely none of above is even acknowledged, let alone addressed, by Signature’s meandering rationale for pursuing statutory regulation, it becomes necessary to ask whether the current governance of their “NRCPD service” is fit for purpose and their personnel are qualified to decide our profession’s future. Who watches the watchers?
- Finally, the concept of principled non-compliance may offer some solutions, or at least traction, to those with doubts and fears about the path ahead, while those who favour statutory regulation have a paradox to resolve.
(With acknowledgements and apologies to Ben Braithwaite, co-author of the fascinating Language Blag, and Dylan Kerrigan of the University of the West Indies, for setting me off on this train of thought. My views probably don’t reflect theirs etc.)
1. Open questions
What is power? What does it look like? Are we participating in it?
What is learning? Who decides what should be learned, how it is learned?
What is class? Where is the class analysis in Deaf studies, interpreting studies?
Happy New Year to all the diligent interpreting robots out there accessing T9000 via their cranial hypernet implants. I hope you are all managing to “adhere strictly” to the rules (they are sticky, which helps with the adhering) and are continuously “raising standards” in a small way every day. If you ever feel like this is a futile task, don’t worry: in the alternative future dystopia that T9000 originates from, the world energy crisis has been solved by hooking up a generator to a perpetual motion machine made entirely from crystallised standards. [Read more…]
I was a bit blown away by the interest in my Great Flounce – in just five days, it had double the total traffic of the last ten months – a little nerve-wracking. Some very fair criticisms were made: I agree completely with those who pointed out that it isn’t especially helpful to dismantle things without offering any kind of solution. This post is an attempt to redress that, pulling together bits and pieces I’ve rambled about here over the last year.
Here’s what would bring me back into the loving arms of my comrades, if a register (or equivalent) could manage it. It’s not a shopping list: they are my terms, which sounds super-butch but has that faint implication of compromise. Most of them (except possibly the first) have been talked through by others for decades, and they all overlap to some extent. If you don’t like longform (essay-length) blogs, here’s a quick list with soundbites.
- A twenty-first century register: the register as a “really useful” public-facing database interface, emphasising specific competencies
- Certification to work in critical domains: the death of the “pancake profession”, the birth of structure and progression
- Pupillage/internships: mandatory hours of supervised work experience for full registration status, post-qualification
- An end to deontology: no more stone tablets which contradict contemporary research and cripple us with dissonance
- Evidence-based decisions and practice: a permanent ban on blind faith and “off-the-shelf professionalism”
Following our last adventure in statistics, my mechanical goblins found more treasure: a cache of CACDP/IRP data. I’m sharing it with you because sharing is caring.
(If you don’t know much about what was going on in the UK sign language interpreting world prior to 2009 and have never heard of the Independent Registration Panel, I recommend Jemina Napier’s 2004 paper comparing UK, US and Australian interpreter training and accreditation leading up to and just after the turn of the millennium.)
|IRP (2004-2008)||NRCPD (2009-2014)|
|Qualified interpreters|| +58.7 terps/year,
R² = 98.5%
| +83.5 terps/year,
R² = 97.9%
|Trainee interpreters|| +19.3 terps/year,
R² = 64.8% (?)
| +6.5 terps/year,
R² = 21.8% (!)
The main bullet point to take home from this is that the overall numbers of qualified interpreters are growing faster under NRCPD than they were under IRP, speculation about attrition remaining. As for registered trainees, there was growth under IRP (it was wobbly, and most of it happened in a surge in the 18 months from mid-2006) but there is no clear trend of registered trainee growth under NRCPD. You can eyeball all that on the graph anyway – these are just the numbers describing it.
Sources of data
- 2009-2014: NRCPD seasonal updates, found on the NRCPD website.
- 2004-2008: CACDP/IRP archives, found in an open directory on the old CACDP website.
- As before, I have lumped all pre-2012 trainees together regardless of registration category.
- The 2008-2009 hole in the data is because no IRP newsletters could be found for the 8 months leading up to their dissolution and NRCPD did not begin reporting until 11 months into their watch.
- The IRP was formed on 1 April 2002 but apparently did not start releasing statistics on registration until 2005, when they created the first newsletter which gave figures from 2004 (see Sources above). It is not clear whether these updates were intended for public release or not; the website hosting them has since been (inexpertly) taken down but the documents were left in place. I take the view that anything left lying around on the World Wide Web unsecured is in the public domain.
- In the early IRP era, registered professionals were referred to as HACs (“Human Aids to Communication”) which was very catchy and I’m surprised it never caught on.
- The IRP register was a subscription-only service for commissioners/consumers to begin with – you had to pay a yearly fee of £25 to receive access to an online directory and this might explain the lack of public archives for the 2002-2004 period (source: Wayback Machine archive of CACDP site).
- You could also pay separately for a paper copy of the IRP registers (source: Wayback Machine archive of CACDP site). In the 1980s and 1990s, the register and code of ethics were carved onto granite tablets which were delivered to your cave by brontosaurus.
- Almost no data for the pre-IRP era of CACDP administration of the registers (1982-2002) could be found (no previous internet archive for UK registers exists; WHOIS records indicate that the CACDP domain name was first registered in March 2002) except for two data points for 1982-1987 given in NRCPD’s “History of Registration” page. This states that the founding 121 interpreters on the very first CACDP register in 1982 (112 of whom were Deaf Welfare Examining Board qualification holders) were reduced to just 62 interpreters by 1987, apparently because of a requirement to pass a CACDP qualification within 5 years; “since then numbers of registered professionals have grown steadily” (well, -ish). We are missing data for 2002-2004 but given that the IRP updates begin with 166 qualified interpreters on 1 April 2004, we can use our fairly reliable trend of growth during IRP’s remit to extrapolate backwards just a little. We probably did not re-achieve 121 qualified interpreters until 2003, ie. it took 16 years to recover from that initial
massacrenecessary step in the evolution of professionalised interpreters. This really does put the 21st century Deaf Industry into context: the same increase in registered and qualified interpreters is currently turned around in 7 months.