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Can Clarity Return Discretion to VRS Interpreters’ Repertoire?

Can Clarity Return Discretion to VRS?

The FCC’s “10-minute rule” and their stance on information gathering to contextualize calls in VRS have been widely misunderstood. Understanding the intent of these regulations can help return discretion to VRS interpreters.


A great American journalist, Margaret Fuller, once said, “If you have knowledge, let others light their candles in it.” Sign language interpreters often work in isolation and have limited opportunities to interact and, therefore, limited opportunities to share knowledge. Fortunately, with technological advancements, we have platforms such as Street Leverage to disperse information throughout the community.

[Click to view post in ASL]

My inspiration to write this comes from my discovery of information when I was preparing for a lesson on the Video Relay Service industry for my interpreting students. In addition to being a video relay interpreter for the past six years, I am also a lecturer at one of the largest interpreter training programs in the country at the National Technical Institute for the Deaf. As a colleague of mine, Brian Morrison, once said, “It takes a village to raise a sign language interpreter,” so I take my job as a lecturer very seriously and work hard to ensure the information I share in my classroom is accurate. Due to the size of our program, I realize the impact I have as an educator on both the Deaf and interpreting communities.  

Revisiting FCC Regulations

While searching through some of the FCC regulations to prepare for my lecture, I came across the FCC’s 2006 revision to the “10-minute rule”. It had been my understanding that unless a switch was requested by the caller (either hearing or Deaf), an interpreter or Communication Assistant (CA), must remain in the call for at least 10 minutes before transferring the call to another interpreter. My understanding was incorrect. On June 16, 2006, the FCC released an order on two VRS issues: the FCC’s 10-minute rule and the interpreter’s role regarding asking questions to callers.

Understanding the “10-Minute Rule”

The first issue deals with the FCC’s 10-minute rule, which requires CAs to remain with a TRS user for at least 10 minutes before transferring the call to another CA. In the 2006 order, the FCC clarifies that in the event a video interpreter handling a VRS call in sign language finds that effective communication is not taking place, the interpreter may change to another interpreter before the initial 10 minutes have passed. The FCC explained that

“there may be VRS calls during which the party using sign language, the CA, or both, find that they are unable to communicate effectively because of regional dialect differences, lack of knowledge about a particular subject matter (e.g., a technical or complex subject matter), or other reason. In these circumstances, when effective communication is not occurring, we conclude that the 10-minute in-call replacement rule is not violated if the VRS provider has another CA take over the call.”

This discovery was new information to me. After reading Richard Peterson’s article “Profession in pentimento”, I had been under the impression that one of our most important values as sign language interpreters, our use of discretion, is in direct conflict with the FCC regulations found in Title 47 of the Code of Federal Regulations. The regulation found on page 266 of the Mandatory Minimum Standards states:“Consistent with the obligations of telecommunications carrier operators, CAs are prohibited from refusing single or sequential calls…”

Can VRS Interpreters Exercise Discretion?

According to Peterson, this rule is widely interpreted to mean that interpreters working as communication assistants must – without exception – accept any and all calls; in other words, they cannot exercise discretion, stating,

“From the frame of reference of the FCC, everything professional interpreters believe about the bedrock value of exercising discretion in our work is misprised, rendered inoperative.”

On their Video Relay Consumer Facts page 7, the FCC states it a little differently:

“Preferential treatment of calls is prohibited. VRS … providers must handle calls in the order in which they are received. They cannot selectively answer calls from certain consumers or certain locations.”

Here the caveat from RID on the applicability of our Code seems almost prescient: 

“Federal, state or other statutes or regulations may supersede this Code of Professional Conduct. When there is a conflict between this code and local, state, or federal laws and regulations, the interpreter obeys the rule of law.” (RID/NAD Code of Professional Conduct 2005: 2)

If you look back to the revision of the FCC’s regulation made in 2006, you can see that Peterson’s argument is not necessarily true if the interpreter is aware of the revision and their ability to use discretion.

Lack of Understanding or Lack of Information?

I decided to see whether this 2006 revision was widely known to video relay interpreters by talking to several interpreters representing various VRS companies across the country. I found that we all had the same misunderstanding. We were all under the impression that the FCC’s 10-minute rule prohibits interpreters from using their discretion. So, in essence, Peterson’s argument has some validity if we are not even aware that we CAN, in fact, exercise our right to discretion and still follow the FCC regulation. As you can see, it is not the FCC’s regulation that is holding us back from adhering to that bedrock value of exercising discretion, but it is our lack of full understanding of our options as professional and ethical interpreters.

As I stated, knowledge truly is powerful. A recent case study on VRS interpreters’ decision making revealed that one common theme interpreters cited was the focus on rules (Holcombe, 2014). One interpreter reported that she was thwarted in her intention to provide effective service in part due to her understanding of a federal regulation. When responding to a request to team, she was unable to immediately replace a struggling interpreter because of the “10-minute rule,” which she believed mandated that an interpreter must remain in a call for a minimum of ten minutes. Her decision making was an example of deontological thinking with a focus on rules (Holcombe, 2014).

Stress and Sign Language Interpreters

Another theme that came up during the case study was the incidence of stress. In Holcombe’s findings the same interpreter stated she experienced stress due to the constraints of the “10-minute rule”. The data and literature review from the study shows that the FCC’s orders are not clearly understood by VRS interpreters, which can be an additional cause of stress. This added stress is a huge concern given that in a self-report study, the VRS industry had been found to be one of the top settings of occupational risk for interpreters (Dean; Pollard; & Samar, 2010). More recently the issue of occupational stress and resulting injury in the VRS setting has been addressed in a survey conducted by the by the Video Interpreter Member Section (VIMS) of the RID (Kroeger, J., 2014).

Hetherington (2011) performed a phenomenological analysis to study occupational stress in the signed language interpreting profession. Analysis of the research identified three themes related to significant causes of interpreter’s stress—real and/or perceived constraints on their role by other professionals, their own understanding of the responsibilities coupled with complexities of the role, and the feeling of powerlessness when the goal to ensure effective communication is hindered by the constraints (Hetherington, 2011).

Industry Standards and FCC Regulations Can Align

RID and industry standards suggest that it is best practice for interpreters to obtain information in advance in order to be most successful (RID Standard Practice Paper, 2007). In its second ruling, the FCC clarified that a VRS interpreter may ask a VRS caller questions during call set-up when this is needed to ensure that the interpreter can effectively handle the call. The FCC explained that “in some circumstances the complexity of sign language may make it difficult for the CA to effectively relay the call if the CA does not understand the subject matter or context of the call.” In addition, the Commission noted that “it is universal practice in the interpreting profession to ask customers questions prior to an assignment in order to better facilitate effective communication. As the Commission has noted, one sign can have different meanings depending on the context.” However, according to the RID standard practice paper about VRS, gathering information from callers prior to phone calls being placed is not a common policy among VRS providers (RID SPP, 2007).        

Knowledge Sharing and Reflective Practice

Now you may ask yourself, who is responsible for ensuring that the interpreters possess this knowledge? Is it up to the individual interpreters or is it up to the companies to ensure that the interpreters are given this information? How can interpreters share their candlelight of knowledge if they are not even certain about the origin of the rules and guidelines that govern the VRS industry (Alley, 2013)? Also, how can we expect interpreters to share their knowledge with others if they lack understanding of the delineation of authority between FCC regulations and corporate practices and policies (Alley, 2013)?

One solution I propose to reduce misunderstandings and ensure information sharing is the opportunity for interpreters to talk with one another and engage in a form reflective practice with colleagues. Reflective practice has been a common theme that has been discussed in previous Street Leverage articles.  We are fortunate to have such notable supporters of this effort who share their positive experience of engaging in reflective practices. Please see Anna-Witter Merrithew’s article, Sign Language Interpreters: Breaking Down Silos Through Reflective Practice,  Kendra Keller’s Case Discussion: Sign Language Interpreters Contain Their Inner “What the…!!!?” , Robyn Dean’s article Ethical Development: A Sign of the Times for Sign Language Interpreters and Kate Block’s piece,  Horizontal Violence: Can Sign Language Interpreters Break the Cycle? for more in-depth explanations of what reflective practice is and the benefits it has to the interpreting community. I have been both a participant and facilitator of reflective practice groups known as “supervision groups”. The experiences I have had as a reflective practitioner have enhanced my critical thinking skills as an interpreter. If you have not participated in one of these groups,  I highly recommend you do.  For information on future groups and what reflective practice is, please visit this site

Questions to Consider

  1. What do you do to help ensure the light of knowledge gets passed on throughout the interpreting community?
  2. Who is ultimately responsible for ensuring the FCC rules and company policies are understood?  Is it the interpreters, the VRS companies, or both?
  3. How do consumer expectations impact FCC regulations, company policies and interpreter behavior?

Related Articles

Station Meditation: VRS, Compassion and Sign Language Interpreters by Judith Webb

VRS Sign Language Interpreters: An Appropriate Legal Tool? by Tara Potterveld and Nichola Schmitz



Alley, E. (2013). Video Relay Service: The path from student to professional? International Journal of Interpreter Education, 5(2), 96-110.

Dean, R. K., Pollard, R. Q., & Samar, V. J. (2010). RID Reseach Grant Underscores Occupational Health Risks: VRS and K-12 Settings Most Concerning. VIEWS, 41-43.

Federal Communications Commission. In the Matter of Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Order, CG Docket No.03-123, FCC 06-81,released June 16, 2006.                    

Hetherington, A. (2011). A magical profession? Causes and management of occupational stress in the signed language interpreting profession. In L. Leeson, S. Wurm, & M. Vermeerbergen (Eds.), The sign language translator and interpreter: Preparation, practice and performance. Manchester, UK: St Jerome.

Holcombe, Kathleen C., “Video Relay Service Interpreting: Interpreters’ Authority,

Agency, and Autonomy in the Process of Ethical Decision Making” (2014). Master’s of Arts in Interpreting Studies (MAIS) Theses. Paper 16.

Kroeger, J. (2014). Findings from the video interpreter member section survey on injuries. VIEWS, 31(1), 42-43.

Peterson, R. (2011). Profession in pentimento: A narrative inquiry into interpreting in video settings. In L. Swabey, & B. Nicodemus (Eds.), Advances in interpreting research (pp. 199-223). Amsterdam, Netherlands: John Benjamins.

Registry of Interpreters for the Deaf. (2005). NAD-RID Code of Professional Conduct. From Registry of the Interpreters for Deaf (RID). http:///

Registry of Interpreters for the Deaf. (2007). Standard practice paper Video Relay Service interpreting. From Registry of the Interpreters for the Deaf: 06/VRS-

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Replenishing Sign Language Interpreting: Extraction Exchange

Sandra Maloney - StreetLeverage - X

Sandra Maloney presented Replenishing Sign Language Interpreting: Extraction Exchange at StreetLeverage – X | RID Conference 2015.  Her presentation explores the concept of the “extraction mindset,” applications to the field of sign language interpreting, and how to combat this thinking.

You can find the PPT deck for her presentation here.

[Note from StreetLeverage: What follows is an English rendition of Sandra’s talk from StreetLeverage – X | RID Conference 2015.  We would encourage each of you to watch the video and access Sandra’s talk directly.]

Replenishing Sign Language Interpreting: Extraction Exchange

Good morning.

It’s amazing to see so many of you here.

When Brandon Arthur asked me to participate in this morning’s event, I was honored to be asked, particularly in light of previous StreetLeverage presenters. Then I thought, “What will I talk about?” I’m interested and passionate about any number of subjects. I could talk about RID but since this morning comes towards the end of the conference, I decided I didn’t want to focus on RID. I could talk about my graduate research, but that didn’t feel right. Then someone sent me a link to a blog by a person who is not an interpreter nor a member of the Deaf Community. The blog is written by a man named Seth Godin. As I read, I realized I had found my topic – I knew I had to talk about this today. Seth’s post topic was the “Extraction Mindset.” I read the post- I’ll explain more about the blog later on, but first, I want to talk about this idea. As I read, I wondered about the meaning of the term “extraction mindset,” and, being a graduate student, I did my research to gather more information.

Defining the “Extraction Mindset”

The concept of extraction mindset can be applied to various circumstances. For example, consider the rainforest. A person identifies the need for wood and proceeds to clearcut an area, extract all the useful wood, and burns the ground, leaving nothing behind. All resources have been depleted, leaving a barren, useless landscape. Another version of this mindset can be illustrated in sign language interpreters’ addiction to their smartphones, for example, the iPhone. Whenever a new version is released, everyone rushes to buy the latest device in an effort to be the first to have it.The length of the line demonstrates the drive, the hurry to get the latest version. So that idea, that mindset that is “I must get it before others can” is a part of the “extraction mindset.”

Now, I’ll show you a paragraph taken from Seth’s blog and how I envision how it applies to our field.

When I read that, I got goosebumps and my mind started racing with the many potential applications to our field. There are so many ways we can apply this theory. And the results of this “take it now before someone else gets it” mindset…the results are depleted resources. So I started thinking about applications to the field of interpreting – perhaps your minds are working on the possibilities, as well.

Applications to the Field of Sign Language Interpreting

For me, one area that immediately came to mind was freelance interpreting. Wouldn’t you agree? Freelance Interpreting has no set schedule. We don’t know when the next job will come. What that means is that when an assignment is presented to us, we have to decide whether to accept or decline. In the ideal world, before we accept a job, we would consider things like, “Am I the right person for this assignment? Is this assignment at the right time? What is my next assignment after this one?” There numerous other considerations. But often, in the real world, we think about the medical appointment we have the following week, that our child’s schedule is also busy, so we go ahead and accept the job. Often, I see my colleagues accept assignments. They know that they have an 8:00 am meeting to interpret the next morning. When they get a last minute emergency call to the hospital that may mean working through the night, they still accept the job even knowing they will have to interpret in the morning. That’s a prime example of that “take it now” mindset without considering the repercussions. Because we don’t know what is coming next, we focus on immediate things like our income, our bills. There’s nothing wrong with those things, but what is the ultimate impact?

I had another thought about this on an organizational level. Often, we find a good volunteer. Once we find out that they are willing to serve, we get very excited about giving them multiple jobs because it benefits our organization, but what about the benefits to the volunteer? They started out wanting to give back, but how are they benefiting in the long run? As organizations, we need to consider the benefits to volunteers as well as ways to train future generations of volunteers. I think we’ve lost the concept of “training behind” a bit. So now, when we task someone with a project, we don’t provide the necessary resources. We don’t have individuals who can support that next generation person in taking over. That concept has been lost.

Results of the Extraction Mindset

We see this at work in the Deaf community, as well. We want language models; we want people to participate and get involved. We take advantage of their resources.  The Deaf community does want to help interpreters, to help improve the community, to work in partnership with interpreters. But often, people say things like, “I’m done. Let someone else take that on. Let them do it. I’m done.” That response is really a result of the extraction mindset. That type of thinking results in burnout.

results mindset pic

So the result of the extraction mindset is burnout. I’ve noticed recently on several Facebook pages – I’ve joined a number of pages as a participant. I don’t often comment, but I do watch the discussions. I’ve noticed we have a problem in that interpreters are leaving the field to pursue other careers. They no longer work as interpreters. They get tired and become social workers, psychologists, nurses, something other than interpreters. They aren’t continuing to work as full-time interpreters. My thought is that this is due to the “take it all now” mentality and the depletion of our resources. There’s nothing left for them, and we aren’t providing appropriate supports.

On an organizational level…. I often work with affiliate chapters (of RID) who talk about the apathy of the members. “They don’t want to be involved. They aren’t volunteering.” Okay, but what are we providing for them? “They” are tired. “They” don’t know the benefits of volunteering. This has to be a partnership. It has to be. If not, this is what happens – we have problems. We aren’t able to do what is needed. We feel paralyzed because there is no partnership.

The Path Forward: Extraction Exchange

So, how can we succeed? If we are stuck in this short-sighted mentality and solely focused on looking out for ourselves without considering how our decisions impact future outcomes, the problems will only persist, and our successes will be few and far between.

If you’ve focused on that extraction mindset, if you’ve focused on your own gains, don’t be discouraged or disheartened. There is still hope. Any time we identify a problem, it is important that we come up with ideas to create solutions or alternative ways to approach an issue.

the path forward pic

As I researched “extraction mindset,”I also found a concept called “extraction exchange”. That business model requires interaction. Extraction exchange always considers the future – not only for the self, but for the organization and the community. Thinking about the future allows us to examine decisions and their effects on the present and the future and all parties involved.

Preparing the Soil

This week, I’ve gone into numerous workshops where people have said, “You must plant the seed.” Plant the seed. My challenge to you is to go back even further and prepare the soil. That means each of us looking at ourselves and asking, “What can I contribute? What can I give back…to my community? to my local affiliate chapter? to my organization?” We can’t opt out and expect that “they” will fix it. We can’t. We have to act. I’ve seen some examples this week [at the 2015 RID Conference]. For example, at the Business Meeting, someone mentioned that we have to take action on our own and partner with organizations to determine how we can work together. We can’t just set our expectations and hand them off to our organizations and say, “You do it.” We have to figure out how to work together to succeed. We can work together with trust, with information, by determining where the value is and by exchanging ideas.

So, what will your contribution be? I ask you to think about how you can contribute on an individual level, a community level and on a systemic level. How will you contribute?

Thank you.

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Trends Report: Aligning Interpreter Education & Tomorrow’s Challenges

Dennis Cokely and Cathy Cogen

Dennis Cokely and Cathy Cogen

StreetLeverage had a great time providing coverage of the 2015 RID Conference in New Orleans, LA August 8-12, 2015. If you attended or watched the conference live-stream feed, you’ll remember that on Saturday, August 8, 2015, Dennis Cokely and Cathy Cogen presented, “Preparing Interpreters for Tomorrow: Report on a Study of Emerging Trends in Interpreting and Implications for Interpreter Education.” It was one of the standout presentations at the conference to be sure.

Greater Insight on the State of Interpreting

To our good fortune, both Dennis and Cathy were willing to sit down with Brandon Arthur, StreetLeverage founder and curator, to discuss their findings and their visions for the future of sign language interpreting and sign language interpreter education.

* To view the conversation with Dennis Cokely or read the English transcript, click here.

* To view the conversation with Cathy Cogen or read the English transcript, click here.

RID Trends Presentation Summary

If you missed the presentation, you can find the PPT deck used by Dennis and Cathy here.  

Their presentation focused on three main areas:

  1. Trends impacting current and future interpreting services
  2. Current Issues in Interpreter Education and the dynamics at play within the field which may impede or facilitate efforts to address interpreter education and professional development needs
  3. Recommendations for aligning Interpreter Education with the challenges of tomorrow, including some significant departures from the status quo in interpreter education.

Finally, they issued a call to action for conference participants to commit to partnerships, practices and policies which will support the creation of a better future.


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