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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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Station Meditation: VRS, Compassion and Sign Language Interpreters

Station Meditation: VRS, Compassion and Sign Language Interpreters

Through recognizing the humanity in ourselves and Deaf people, and working towards a goal, our work can become much less stressful.

I think as Video Relay Service interpreters we have done ourselves a disservice in the way we talk about ourselves, our callers and our work. Generally, when we describe working in a call center, we either underplay it (“I’m ‘just’ interpreting phone calls”), or grossly exaggerate (“We interpret sex calls! We interpret for drug deals!”). The truth of the matters lies somewhere in between and is infinitely more interesting and gratifying.

[Click to view post in ASL]

The Mechanics of VRS

First, a better visual description of the mechanics of VRS work. Imagine an old-fashioned Bingo blower machine. The balls are whirling around in the chamber, and then one is randomly pulled into the chute for the number to be called. This is each inbound call that is received. The only slight difference is that each time, the ball (caller) is returned to the chamber once it has been called (call completed). Over time, the same number will come up again. This means that while VRS calls appear randomly for the interpreters, we will sometimes see the same number (caller) again. Sometimes, in a single day we will see all distinct callers. A different person every single time. However, it does happen that over the course of a day, a week, a month, callers will be seen over and over again.

The Intimate Nature of VRS

A relationship (such as it is) is established with these callers, whom we may never meet in person. Having worked as a sign language interpreter in VRS for many years, I have been able to witness people’s lives in fits and starts. I am aware of people getting married, having children, seeing the children grow up, parents dying and all other aspects of life. It is a privilege I do not take lightly.

We are also physically seeing into people’s homes, places of work, and other spaces they occupy over time. This is very intimate knowledge we gain and is not often what a freelance/community interpreter would experience. Often, assignments out in the community have a more constructed environment. In those instances, Deaf people are seen in their doctor’s office, in their classroom, in their job site. Our callers are putting a lot of faith in us as interpreters, not only interpret their communication, but to also hold sacred all that we are privy to during the course of each phone call.

Business Owners and VRS

In addition to the intimate types of calls VRS interpreters experience, we interpret daily for Deaf callers who are doing their business, making their living, over the phone. As we see these callers repeatedly, we get into a rhythm of what those calls will be like. We learn the lingo/jargon of their various occupations, we get used to their way of interacting with their customers, and their idiosyncrasies. As this working relationship is established, we are able to make agreements about sign choices, ways of interacting with their customers, etc. Over time, it becomes easier and more comfortable to settle into the task at hand. I am sure this goes both ways. Hopefully the callers become comfortable with the interpreters over time. We become “colleagues” in a way. We want their businesses to succeed, and we do our best to make that happen!

Highlighting Human Interaction

All of this is a reminder to see each other as humans in an interaction. Of course there are rules and regulations for VRS, which we must follow, but I have found if we prioritize being human, all of that falls into place anyway. In some ways, the structure of the VRS system has pushed sign language interpreters back into the “machine model” of interpreting. It seems that we have allowed ourselves to backslide to this mindset. This is unfortunate, as it further separates us from our Deaf callers. This is where I believe some of the struggles and negative attitudes come into play with VRS work. The fact that we are doing this work through the internet, and are not in the same physical space as our Deaf customers, should not mean that there are additional barriers to our communication. I feel it’s important for video interpreters to actively seek that human connection. As Brandon Arthur stated in his StreetLeverage – Live 2015 recap, “a fundamental truth about the field of sign language interpreting…success is derived from first acknowledging the humanity of the people in front of you. Simple. Challenging. True.”

I believe that if we really see ourselves as humans first, and our Deaf callers as humans before anything else, our work will actually become almost effortless. This can be accomplished in a number of ways.

  1. Connecting with our callers as humans is done when we are not actively involved with interpreting the conversation. A warm smile, admiring a scarf, waving at cute babies, cooing over kittens. The more familiar and comfortable we are with callers over time, the more we can settle in and do the work with ease, and all involved can be satisfied by a job well done. Even if we are faced with a caller we have never seen before, if we could assume this attitude, that callers are human as we are, therefore comfortable and familiar, all our calls can be smoother.

  1. Using care when discussing the work with others is also critical in maintaining a focus on the humanity of those we work with. When I talk about my work to non-interpreters, I make sure to talk about working with humans, and the fact that working with humans is demanding.  Think of nursing, teaching, and other jobs where you are constantly interacting with people in all their joy and pain. When we as interpreters talk with each other, while protocol indicates that we refer to “callers”, I think this limits us as well. We need to recognize the humanity we encounter daily.

  1. Recognizing the shared experiences we have with callers also helps keep our focus on the human factor. When explaining VRS to others, I also try to explain that every type of phone call that a hearing person makes, a Deaf person also makes. Did you call your mother today? Was your conversation pleasant? Did it make you feel like a little kid again? Did you get mad and hang up? What about calls to set up doctor appointments or get test results? Telling the school your child will be out sick? Hanging out on the phone shooting the breeze with an old friend? Hours arguing with Comcast? This is what we do everyday!

In The End, Rise to the Challenge

Sure, we can talk about the stats and productivity rates of VRS work. We can talk about the anxiety that comes with not knowing what’s coming our way next. We can talk about compassion fatigue and vicarious trauma. I will admit there have been times when I have interpreted very difficult, painful conversations after which I have removed my headset and walked out of the call center. I knew I would be no good for any subsequent callers, therefore I took care of myself, and them. However, I know I have settled into all of that. I enjoy the thrill of the unknown. I feel I can rise to the challenge of whatever comes my way. Interpreting in VRS becomes easier the more I can approach my work with curiosity, compassion and a spirit of collaboration with my fellow humans.

Questions to Consider:

  1. What is a key phrase you can use to internally remind yourself that we are all human?
  2. By treating each other humanely, in what ways can your work product be improved?
  3. Suppose you’re not “feeling it”; what are some things you can do physically to make it seem like you are, or steer yourself towards a more positive outlook?

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Hearing Interpreters: The Danger of Being the Public Face of ASL

Hearing Interpreters the danger of being the public face of ASL

When ASL is seen publicly, it is often vis-à-vis hearing sign language interpreters. Aaron Brace examines the impact this has on public perceptions of ASL, and suggests strategies that create opportunities for Deaf interpreters to authentically represent their language and culture.

I’ve been asked a few times by family and friends to explain what was going on when a CDI/hearing team delivered the interpretation of NY City Mayor de Blasio’s press conference on Ebola. The very notion that Deaf people can work as professional sign language interpreters is new for most hearing people; indeed, if they see ASL at all, it’s usually hearing interpreters like me, or signed music videos of questionable value (also by hearing people) on social media.

[Click to view post in ASL]

One of the reasons I sometimes have a hard time explaining this service model is that feeling of an existential threat, which doesn’t necessarily disappear just because I know it to be false. But another reason, which I’d like to focus on here, is that I haven’t fully come to grips with the implications of hearing sign language interpreters like me being the public face of ASL. Rather than learning how to do it better, I’m learning how to let it go.

Navigating the Changing Dynamics in Interpreting

I first began thinking about hearing sign language interpreters as the public face of ASL a number of years ago. Like many who are reading this, I’ve been one of the go-to interpreters for public-facing work for most of my career. Although my focus has always been on serving the people relying on my work, I’ve found myself enjoying the opportunities to stand out, to be trusted in jobs where my work would be broadly seen. I’ve enjoyed the positive feedback afterward, the status it has given me among my colleagues, and the chance to share what I’ve learned about ASL and the Deaf community. For a large part of my career, that was simply the water I swam in. I didn’t consider that there was anything else. After a while, as painful as it is to admit this, I began to think it was my right.

I have also regularly worked at conferences for national and international organizations. I have typically been on stage at their conferences, handling keynote presentations as well as presentations by other prominent speakers.  There came a time, though, when several of these organizations, with Deaf people in decision-making roles, decided that Deaf interpreters were to be on stage at all plenary sessions. I was relegated to small breakout sessions and working into English through a closed loop; I wasn’t on stage any more. It took me longer than I like to admit to get over losing the opportunity to do the plenary work, but I had the presence of mind to observe the work being done by the Deaf interpreters. Sure, the quality varied, but so much of the work that I saw was exemplary, and qualitatively superior to what I, or other hearing colleagues, typically produce.

More importantly, that model of service was chosen for high-profile work due to the involvement and leadership of knowledgeable Deaf people. Not only did they consider what would best serve the participants, but, surely, they were also influenced by the desire to authentically represent Deaf people’s language and culture to a broader audience.

Positioning My Ability

Like others, I began calling my work ‘bilingual/bicultural mediation’ soon after that terminology entered our professional discourse. Of course, that’s how the researchers in our field began describing what effective interpreting should be. It never crossed my mind that I was lacking the ASL fluency and cultural competency needed to actually do that kind of work. A Deaf friend recently told me that applicants to Gallaudet’s MA Program in Teaching ASL have to pass the ASL Proficiency Interview at a level 4 or higher…before beginning their studies. It took him three tries. Not only would I have failed to meet that bar before I began training, I’m quite confident I couldn’t meet it now.

I’m not qualified to go on about theories of bilingualism. I mention it only because it has become clear to me that the general public is primed to impute to me, to all hearing interpreters, a level of linguistic and cultural mastery that I simply don’t possess. Even if I’m relatively aware of the limits of what I have to offer, I don’t quite know how to articulate them to hearing people in a way that won’t undermine both their confidence in me as well as my own. Silence speaks volumes, as I already have the glamour of the words ‘professional’ and ‘interpreter’, and letters after my name. Oh, and I’m hearing. That’s probably the biggest factor in eliciting other hearing people’s high opinion of work they don’t understand.

This became painfully clear to me once, when I told one of my sisters that I’d be interpreting a play with a team that included a Deaf person as our Sign Master. She looked puzzled and said, “After all this time, Aaron, isn’t that what people ought to be calling you?” It was embarrassing to realize that I had never positioned my profession, myself, or, my ability to her in a way that she could have thought any differently. To her, I was the exemplar of ASL fluency. Who knows? Maybe I need to believe my own hype in order to have the nerve to do this kind of work at all.

Shifting The Focus

I realized recently that the more effort I put into preparing to interpret something like a play, the more I begin to worry. I worry not only that the hearing audience may think they’re seeing me produce a work of ASL literature, but that I might even start to believe it myself- all without anyone saying out loud that’s what we’re thinking. I worry that the Deaf poets, actors, storytellers, translators, teachers, and the friends I try to emulate in these instances will have far fewer chances than I, if any, to stand before a similar audience, with the same authority that’s imputed to me – but which I have only borrowed from them.

When I stand up at a public or televised event before a predominantly hearing crowd, on a real or virtual stage, under a real or virtual spotlight, I worry that some ASL student will decide to become a sign language interpreter in an effort to seek out the same kind of attention that I’ve realized I can be overly fond of.

But when a qualified, certified Deaf interpreter, like the one working at the Ebola press conference, gets asked questions about what interpreting is and how it serves the Deaf community, I don’t worry so much. Not only because his answers are likely to contain observations I couldn’t legitimately make, but also because it begins to shatter hearing people’s frequently-held stereotype of Deaf people as needy receivers of information. Deaf children also benefit from seeing qualified Deaf professionals modeling one way to represent their language and culture. If we quibble that not all CDIs are as experienced, or as able to give a good account of our profession, well…that’s never stopped the rest of us, has it?

Stepping out of the Spotlight

In her article, Are Hearing Interpreters Responsible to Pave the Way for Deaf Interpreters?, Anna Mindess listed some excellent, practical steps for us to take in expanding opportunities and visibility for CDIs.  In addition to hers, I’d like to add a few more. Some of these I’ve already implemented for myself, others are aspirational. Some may be more practical in some geographic areas than others:

  • work with Deaf colleagues and the local Deaf community to determine what an increased public presence of Deaf signers, including but not limited to CDIs, might look like and how to work towards making that presence a reality;
  • enlist as allies any hearing hiring agents who understand the value of CDIs;
  • consider working, on occasion, for reduced rates or pro bono in order to get more hiring entities to try using Deaf/hearing interpreting teams. This may be a controversial idea, but I believe that, used judiciously, it can be an effective tactic in getting more native ASL out where hearing people will see it;
  • share exceptional Deaf- or Coda-made videos on social media, along with a description to hearing friends of what makes them exceptional.
  • And finally, develop the reflex to step aside and team with a qualified Deaf colleague at every opportunity that comports with your own community’s values. Deaf people, even CDIs, may disagree strongly about when it’s necessary or even just preferred to have a Deaf face as the public face of ASL. It’s a process. I choose not to hinder that process, but to foster it.
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VRS Sign Language Interpreters: An Appropriate Legal Tool?

VRS Sign Language Interpreters - An Appropriate Legal Tool

As municipalities increasingly deal with budget constraints, many are turning to VRI or VRS for interpreting services in legal settings. Tara Potterveld and Nichola Horrell Schmitz explore the cost and efficacy of this approach.

More cities, counties and states deal with budget cuts and economic shortfalls, money designated for courts, District Attorney’s and Public Attorney’s Offices is being reduced. Unintended and often overlooked victims of these financial cutbacks include Deaf persons. Best practice to protect Deaf people’s right to due process in legal interactions is to have Certified Deaf Interpreters (CDIs) work as a team with legally certified hearing interpreters (SC:L).[1] Yet, the expense of providing sign language interpreters to Deaf persons in legal settings clashes with the need of jurisdictions to significantly reduce spending.

[Click to view post in ASL]

Denying communication services to qualified individuals is both illegal and counter-productive. As municipalities look for ways to cut costs, one area they are exploring is reducing interpreting service budgets by resorting to technology. The two predominant technologies are Video Remote Interpreting (VRI), a fee-based interpreting service that usually charges by the minute and Video Relay Services (VRS) provided by the Federal Communication Commission at no cost to users.

Video Remote Interpreting (VRI) is used more often in courts as budget concerns increase. The courts are seeing that they can save money by not paying interpreters to travel to the courthouse. Many court hearings only last 15 minutes so the courts save money by not paying the standard two-hour minimum for a team of two or more interpreters. The court pays the VRI company only for the minutes that the interpreter team is utilized. VRI can be successful if certain parameters are met such as: using a full team of interpreters (CDI and SC:L) for legal work; obtaining preparation materials before a hearing; and establishing communication with the Deaf person involved in the case before commencing. Nikki and Tara (the authors) have tried this system as a team and experienced both positives and negatives.

Video Relay Services (VRS) differ from Video Remote Interpreting (VRI). Using VRS to access interpreters is an attractive option for cash-starved entities because VRS is free of charge for courts or attorneys communicating with a Deaf person. Given this trend we must ask if VRS interactions help or harm Deaf people in legal situations. Many VRS interpreters are competent, but rarely possess legal certification.[2] Some VRS interpreters do not possess any certification[3] and thus there is no way to assess the quality and competency of their interpretations.[4] No large VRS agencies, that we are aware of, have CDIs on staff ready to handle legal calls.

The Federal Communications Commission (FCC) oversees all VRS companies. The FCC mandates that: “Preferential treatment of calls is prohibited. VRS providers must handle calls in the order in which they are received.” Consequently, a sign language interpreter answering the call may have little or no experience with legal issues. A VRS interpreter can call for a team to witness and assist a legal call, but there is no guarantee that either interpreter will have the skills and knowledge necessary to interpret the call accurately. From informal polling, we found that many VRS call centers do not have any legally certified and trained interpreters on staff. Granted, the FCC does not allow VRS interpreters to swear an oath of accuracy and impartiality for court proceedings, yet courts and attorneys use VRS interpreters to handle a variety of hearings and client-attorney discussions without checking into the skills and qualifications of the interpreters.

Even very good interpreters make mistakes due to a number of uncontrollable factors, including technical difficulties like video transmission problems and poor audio. VRS interpreters have no preparation time before accepting a call. VRS interpreters are not privy to documents related to the case and might not be aware of the nature of the charges. VRS interpreters cannot see the courtroom or evidence presented. The interpreters cannot see people in the court and probably will not be able to distinguish the role or context of the speakers. They only see the Deaf person involved in the case who is in a different location. (FCC rules prohibit Deaf and hearing callers from being in the same room during a call). VRS interpreters often get calls from other states and unlike local sign language interpreters, may not be familiar with the location of the crime or regional signs used by the Deaf person. According to the FCC, VRS interpreters must continually process a call between a Deaf and non-Deaf person for a minimum of 10 minutes before transferring the call to another (possibly more skilled or possibly less skilled) interpreter unless the Deaf consumer asks for a transfer.

It is troubling that VRS providers do not hire CDIs to assist in all legal calls. The FCC allows hiring CDIs, but VRS companies find it costly to have CDIs on site for legal calls. Yet, we know from research how valuable CDIs are to providing a fair and just linguistic experience for Deaf people in the legal system. Carla Mathers eloquently writes: “Undoubtedly, the legal system presents a linguistic minefield and imposes substantial barriers to understanding for most deaf individuals and many court interpreters. Even with a highly skilled legal interpreter, a deaf person may not have the framework to understand the proceedings in a manner sufficient to advise and receive advice from counsel. Deaf interpreters have rich ways of communicating that are generally unavailable even to the most skilled interpreter who can hear.”[5]

We know that legal situations have high stake implications for Deaf people’s lives. It is questionable if VRS interpreters should be allowed to handle legal calls without legal certification and access to a CDI. Balancing a Deaf person’s right to due process and a municipality’s need to reduce costs is a difficult dilemma. We as Deaf persons and sign language interpreters need to work on guidelines and laws that will protect Deaf persons. It is time for a national dialogue on issues of legal justice regarding Deaf people and whether justice is compromised by using VRS without proper safeguards.



Nichola Horrell Schmitz, MA, CDI, CLIP-R, a freelance interpreter, is fluent in ASL, Mexican and Pakistan Sign Languages and various signed dialects.


[1] The Mid-America Regional Interpreter Education (MARIE) Center has current research on this topic on their website,

[2] Registry of Interpreters for the Deaf published demographics in 2011 showing of 15,617 members, only 263 held a Special Certificate:Legal (SC:L) and only 124 members held Certified Deaf Interpreter (CDI) certification.

[3] See Brandon Arthur’s article Will Sign Language Interpreters Remain Silent on FCC VRS Reform? (Dec.21, 2011) for a discussion on the pressure for VRS providers “to seek interpreters who command a lower hourly rate.  Logically, these will be interpreters who have yet to obtain their national certification, have fewer years of experience, don’t have the skill-set to effectively do the work…”

[4] The FCC does not mandate that VRS interpreters are certified. Although some VRS providers do intake assessments, the criteria and qualifications for competency are not public information.

[5] Mathers, C, “Deaf Interpreters in Court: An accommodation that is more than reasonable,” Publication of the National Consortium of Interpreter Education Centers, (2009), 20.

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Sign Language Interpreters: The Unintended Victims of VRS Regulation Change

Distraught Sign Language Interpreter

Regulation changes from the FCC have impacted the VRS industry, providers, consumers, and sign language interpreters. Karen Kozlowski Graham questions the efficacy of these regulations in light of some of the unintented results.

About a year ago the Federal Communication Commission (FCC) implemented new rules regarding the structure and practices of Video Relay Services (VRS).  A year later we ask: Is the VRS industry a better place for having implemented the new regulations?

What Did it Achieve?

The intent of the rule was to root out fraud and make VRS a more manageable industry for the federal government. Did their action lessen the probability of VRS companies acting in a fraudulent manner? Most importantly, are Deaf people receiving better service now than they were a year ago? How did the great VRS shake-up shake out?

My VRS Story

I co-owned a company that rode on the VRS train virtually since its inception, SignOn: A Sign Language Interpreter Resource, based in Seattle.  We started out, as many things do in Seattle, with lots of collaboration, good intentions, and smudging with sage.

VRS played an important part in companies like ours because the volume of income gave us the opportunity to become a traditional workplace.

Our early endeavor with a VRS center and our community interpreting program allowed our sign language interpreters to work alternatively in the community or on a video platform; they’d get full- or part-time status complete with benefits, paid time off, and a 401K option. All that without having to track down payments from customers, find and schedule jobs for themselves, or worry about vacation time.

As are most sign language interpreters, we were intensely loyal to both our professional ethics and our consumers. It took us years to learn all the business “how-to’s”—figure out how to do the financial aspects of a business correctly and generally become a well-functioning company. Really, we just wanted to do good work and be happy.

I believe we were onto something, just something that is difficult to attain and then sustain—delivering quality services while simplifying the life of the interpreter.

Interpreters First

For nine years SignOn subcontracted with various certified VRS companies. We were considered a “white label” provider, which means we answered calls as if we were the certified provider. We rigorously upheld FCC rules and the usual high-level interpreter standards; we considered ourselves service providers–interpreting was our business. When the new regulations came down, we needed to make a decision as to whether we should try to attain certification to continue providing VRS or move away from the traditional workplace model that VRS had afforded.

To attain certification, we realized would require us to be in the business of dealing with complicated and expensive technology, wrangling with the federal government, and generally entering a faction of our industry that wasn’t in our wheelhouse. We were strong interpreters, not computer platform developers, or lawyers. That self-knowledge of our core competency led us to the decision to bow out of VRS. As a result, one of the larger VRS companies took over our call center. The community interpreting and VRI functions of our company was subsumed by a local non-profit.

The music ended and the ride was over.

Has More Regulation Helped?

So where have we all settled in? There have been numerous stakeholders in this drama: white-label providers, VRS providers who went on to certification, VRS interpreters, and most importantly the Deaf Community.

White-Label Providers

SignOn doesn’t exist in its original form any longer. In my case, I lost a livelihood. I’ve moved into a different field altogether and the days of monitoring the FCC announcements are a thing of the past. I would love to have traveled further down the road with our vision of an integrated workplace for sign language interpreters – a good place to work and a great place to grow the next batch of kick-ass practitioners. But some actors in this drama, like myself, were plumb out of luck – and out of work.

VRS Providers

One VRS provider who proceeded with certification suggested that the strictness of the rules was a challenge and perhaps limiting to efficient business operations. Requiring interpreters to be staff is often difficult in a freelance-oriented industry. Trying to discern the meaning of regulations, the increase in costs, and the impact on cash flow were some other concerns.

Sign Language Interpreters

The FCC changes definitely shuffled the interpreter deck. Their directive that more interpreters become “staff” forced a change in the composition of the VRS interpreting pool. Those sign language interpreters who wanted or needed the stability of employment took jobs at VRS companies.

Some interpreters, not liking elements of work with the bigger VRS companies (e.g. scheduling, strictness in operations) have left VRS altogether. Some of the interpreters, who had no intention of becoming freelance-only interpreters, were propelled into the freelance world by necessity. Others just needed this push to move on to full-time freelance work, something they had been considering anyway.

In my view, interpreters felt that they followed the FCC guidelines prior to the rule change and that they were no more conscientious and ethical than they were before the change. Then there was the question of home-based VRS interpreters. I don’t know what they’ve done and how they’ve compensated for losing that work.

Deaf Community

The FCC rule definitely forced a lot of hands (pun intended). How has this reshuffling affected the quality and quantity of interpreting work available to the Deaf community?  It appears as if the shift in balance moved some of the more experienced interpreters back to community freelance work as their primary source of income.  If so, how has that changed the quality of interpreting both in the community and in VRS? And then, of course, the ultimate question: Is VRS a better product for Deaf consumers now that it can be more tightly monitored?  Is there less opportunity for fraud and more control over the quality of services under the new regulations?

The Bottom Line

In my VRS story, most of our staff landed in the non-profit (providing community interpreting) or as staff at one of the remaining VRS companies – an outcome critical for SignOn’s founding owners. We didn’t want the FCC rule change and the disbanding of our company to leave anyone out of a job, and fortunately most everyone landed on their feet.  There were another 40 or so companies that scrambled to find their footing in the new world order sans VRS. Some were purchased by VRS companies pursuing certification, some dissolved, and some moved forward without a VRS complement.

My own little corner of the VRS universe went dark. I hear the groans of change and the opinions of a few interpreter survivors. I see some interpreters pining for the earlier days of VRS, while some are finding their niche in the new scheme of things. Some great interpreters have abandoned VRS altogether while others have made it their bread and butter. In the end, I’m wondering if all that hoopla was a real gain for either Deaf consumers or the sign language interpreters providing the service. It opens interesting questions and hopefully further thoughtful discussion.

My Opinion

In my opinion the changes haven’t necessarily helped. A few interpreters I spoke with said that they felt the VRS companies left in the pool would remain – and that having such job stability felt good. A few interpreters genuinely like the call center they work at – the staff and the atmosphere are good. Otherwise it seems as if the FCC changes have created more bureaucracy, without necessarily more quality. Perhaps the rule has eliminated fraud (has it?), which was its original intent, but many exemplary, law-abiding stakeholders became unintended victims.

Well, I guess you’d expect me to say all that since I lost my company. Okay, fair enough. But what about you? How have the FCC changes affected your work and your participation in VRS? Are we all better off now for the stricter regulation of VRS? Most of you have opinions. Share them.

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Sign Language Interpreting: The Danger of the Idea That Transformed the Profession

How has the push for the professionalization of sign language interpreters affected our influence on larger systems, and on our related stakeholders? Brandon Arthur asks us to reflect on how we got to where we are, and how to redirect our engagement to the industry.

Decades have seen the sign language interpreting profession quietly transformed by a single, powerful idea—sign language interpreters are professionals.  This single idea has created the momentum necessary to move the field from a hand written list of volunteers to a vast web of public and private entities, interest groups and regulation—an industry.

Is it possible that the power of this ideal has left us, the sign language interpreter, with a dangerous blind spot when engaging with the broader industry? Meaning, has the dogged determination to qualify as a profession prevented us from seeing what is necessary to effectively govern one?

What follows are a few things that gave me pause as I considered this possibility.


It occurs to me that the opportunities and threats faced by our profession is no longer the result of industry stakeholders (consumers, sign language interpreters, associations, businesses, service providers, educational institutions) being divided, but rather as a result of them being connected.  One might consider the sweeping impact FCC VRS reform has had, and will yet have, on the sign language industry as an example.  If this interconnectivity is real, and I believe we have examples to demonstrate that it is, we could logically conclude that the industry has evolved into an integrated system of stakeholders; where each is directly or indirectly impacted by the action of another.

If the industry is in fact integrated, wouldn’t the very basis of our engagement with other stakeholders need to change? Might this suggest that we are attempting to address current issues with an antiquated approach.

If yes, have we, the profession, stumbled over our own feet?

Weak Engagement

In seeking the specialized knowledge and skills to qualify as a profession and as professionals, it occurs to me that we appear to be failing to prioritize an important aspect of our long-term viability—expert knowledge of the broader industry.  One might consider state licensure laws passing in the face of outraged interpreters as an example of why this is gives me pause.

Is late or weak engagement by sign language interpreters on broader industry issues because we are indifferent to what occurs around us or is it that we are simply unaware that the issues even exist?  Or, is it because we don’t have the know-how to obtain the information needed to form an opinion? Worse yet is it our view that, “there is no industry without the interpreter” and it will work itself out?

If we are unable to effectively form an opinion and engage on industry related issues ourselves, is it possible to collaborate with industry stakeholders on broader issues?

In my view, for the profession to be effective long-term, ignorance can’t possibly be bliss in this instance.

Sparse Information

In an environment where the stakes are high and the pace of change quick, it seems important that sign language interpreters are able to quickly equip themselves with information.  Do we have the channels necessary to effectively deliver information across the profession and industry?  Can these channels effectively mobilize interpreters if necessary?  If no, does that suggest our infrastructure is insufficient to effectively administer the profession?

If we don’t have an infrastructure of size, does it mean we have information siloes and expensive duplications of effort brewing?

What I do know is that if people don’t have sufficient information to form an opinion regarding the system they are part of, they will feel overwhelmed by it, homogenized by it, and/or unwilling to invest in it.

I don’t believe interpreters are any different.

A Refocus

As a profession, we have made great strides over the past 40+ years.  Again, the early momentum of the sign language interpreting profession was possible because of our dogged determination to be recognized as a profession.

In my view, we need to refocus this determination on a few things.

How to:

-Leverage our interconnectivity to other industry stakeholders

-Remain aware of industry threats and opportunities in real-time

-Effectively distribute information across the profession and industry

-Extend our passion for skill development to the acquisition of broader knowledge

A focus on these items will assist us in effectively navigating the challenges of administering the profession long-term, which I believe is necessary if we are to maintain our position and success within the industry.

Is there other action we should consider?

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FCC VRS Reform Part II – Sign Language Interpreters File Public Comment

Censored Sign Language Interpreter Working in Video Relay

When there is an opportunity for sign language interpreters and stakeholders to participate in creating the direction of the VRS industry, participation is critical. Brandon Arthur suggests that even more importantly, that participation should be well-informed, well-framed, and professionally presented. 

The charge of emotion sign language interpreters received at the hand of VRS Reform, while important in prompting us to action, can be detrimental if not checked when filing comment with the FCC. Though appreciative of the sign language interpreter who overcame the inertia of apathy and filed this comment with the FCC, I believe their filing would be taken more seriously were they to have checked their emotion and considered what follows prior to submitting comment.

When Filing FCC Comment

First Things First

When filing comment with the FCC, remember you are submitting comment in a public forum. To dispense with formalities is poor form and a demonstration of one’s lack of competency related to public proceedings. Consequently, please be sure to address your comment to:

Ms. Marlene H. Dortch
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Further, it is important to reference the docket number for which you are filing comment. The FCC and the general public need to be able to quickly reference the matter upon which you are responding. Yes, this should be a given. In this instance the docket number for the Structure and Practices of the Video Relay Service Program is:

CG Docket No. 1051

Be Specific

When crafting your comment, please be cognizant that the readers of your submission will not have the reference points found in your head (crazy I know). Therefore, be specific in your comments and recommendations. Comment without sufficient context and specificity are of no use to FCC when considering the impact and development of their proposed rule-making.

The No-No

It is critical to remember when filing a comment that to villainize the FCC, VRS providers, your employer or any organizations is inappropriate and frankly misguided. While we may feel justified in doing so due to the negative impact a proposed rule may have on sign language interpreters, it is important that we refrain.

Callout the Benefits

It works to the merit of your comment to specifically point out the public and stakeholder benefits—which includes the FCC—in all recommendations offered. Further, it is important to consider that recommendations must work on a broad scale, which means any recommendation will inherently work to the exclusion of some.

How to File Comment

To file a formal comment via letter, you need to use the ECFS Expert Form.

The following is required:

  1. Proceeding Number (already entered if you click on the link above, if not enter 10-51)
  2. Name of Filer (your name if filing personal comments)
  3. Type of filing (‘Comment’ should already be selected)
  4. Address
  5. Upload document
  6. Review & Confirm your submission

FCC tips on how to file can be found by clicking here.

Will You Join Me?

In most grassroots attempts to persuade a public entity to adopt a certain perspective, people talk a tough game, but fail to support the effort with their time and/or resources. Well, here goes less talk and more walk.

I have drafted a both a comment to file with the FCC and talking points (at the end) that you can freely incorporate into your own FCC filing.  You can find them both here.

I am hopeful that you will join with me in filing comment on this important issue.  Remember, we only have approximately 35 days to get our comments in.

Let’s not let our careers be victimized by our own apathy.


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Sign Language Interpreting, Leadership, and Messy Relationships; What They Have in Common

Leadership and relationships for sign language interpreters

Sign language interpreters regularly perform complex interpersonal tasks which require presence and energy. Amy Seiberlich suggests self-awareness and openness are required to achieve personal and professional success.

Sign language interpreting and Leading are alike – the success of each is largely dependent on one’s quality of character and ability to navigate complex interpersonal dynamics. Yet when we talk about either we generally focus our attention on the technical skills required to accomplish the task ahead. Technical skills aside, there is much to learn about improving the quality of our interpreting if we simply turn our attention towards matters of leadership.


Leadership involves managing people, and people are messy. Each person is a system of individual experiences, memories, belief systems and values that form a viewing window for the world. No two people combine these elements in the same manner. Even siblings who grew up in the same family of origin and who share these elements have formed different windows. We are each a unique expression of how our journey has unfolded and that impacts our work as sign language interpreters. At its core then, leadership is about managing complicated and messy relationships – with others, and with self.

Developing a Relationship with Self

A teacher once told me that you must first be able to lead self before you can lead others. I later realized what he meant was that I needed to understand and develop a strong relationship with myself before I could expect to do the same with others. So the authentic leadership journey begins at our own front door!

Starting with these simple tips is a first step towards deepening your relationship with, and successfully leading self.

  • Attend to matters of the heart. The heart is where we carry our wounds, and our joy. Identify, work through and clear your being of emotional wounds, then consciously choose to fill the space with joy. Bring this joy into every sign language interpreting event and observe the quality of your interactions and work improve!
  • Spend time in reflection. Take time during the day to reflect upon how you are feeling about the life you have created, and how you participate in that life. Do your daily activities generate or deplete your energy? Be honest about how living in a depleted state affects your ability to be present in sign language interpreting interactions. Then take measures to eliminate or restructure activities that deplete your life force.
  • Tap into your inner five year old. View the world around you with childlike curiosity and wonder. Enter interpreting situations with an “I wonder why I have been placed here today, in this situation…what am I here to learn?” mindset.

Cultivating the ability to successfully lead self gently flows into becoming fully present in each moment, and a clearer channel of communication for others.

Do for Yourself

If you neglect self, you will neglect others – you cannot do for others what you refuse to do for yourself. Leadership efforts may result in some work being done, but the process will be painful rather than joyful. Interpreting assignments will be the same. We must own the quality of our character, and be self and other aware, in order to develop into the leader or sign language interpreter we aspire to be, and the Deaf community expects us to be.

Now is the time to stop focusing our attention outside of self to learn to be a better leader or interpreter…to be either, take an honest look inside.

Your journey begins within, start today.