FCC Comment: Interpreters ≠ Dial Tone

I posted the following comment to the FCC regarding Telecommunications Relay Service (TRS) – Docket 03-123.

I have been told that the FCC considers sign language interpreters to be “equivalent to a dial tone,” and that we are not mandated reporters of abuse. The problem with this is that we are human beings, and unlike text relay operators, we video interpreters actually witness the the sign language users with our eyes. In the dreaded event that a video interpreter were to witness something like a person having a heart attack or stroke, or see a person beaten, raped, or even shot dead before our very eyes, it would cause us irreparable psychological damage if we were forbidden to report it. Granted, a Communications Assistant who performs text relay services may hear something terrible on the voice line, but they can never know for sure what they heard. Video Interpreters (VI’s) are unlike Communications Assistants (CA’s) in that we are eye witnesses to whatever goes on in front of the sign language user’s camera. We should be considered mandated reporters both for the sake of our clients and ourselves. It is a human being’s natural desire, nay, need to “do something about it” when we are witness to abuse. I could not live with myself if I witness such atrocities and did not report it. It doesn’t do our clients any good either for us to remain silent in such dreadful circumstances.

You will notice that I use the term “Video Interpreter (VI)” in my letter to you. This is the term that has gained universal acceptance among the profession of sign language interpreting. Our work differs from that of CA’s in so many ways that we feel the term CA should not be used to identify us.

Last, I want to note—with all due respect to CA’s—that VI’s are professionals who have highly specialized skills in linguistic and cultural mediation. In many states, we are required to be licensed. Many of us have, at the very least, associate’s degrees in ASL Interpreting, and quite a number of us have bachelor’s degrees, master’s degrees, and even doctorates. Those of us who are certified—and most who perform video relay interpreting are—must regularly attend workshops to earn Continuing Education Units (CEU’s) in order to maintain our certified status. We are professionals who are bound by a code of ethics. We share a common language, culture, education, and fund of information. The task of interpreting between any two languages is extremely complex and specialized, and cannot be mastered without considerable time and study. In all these ways, we differ from CA’s. I’m sure there are probably CA’s with advanced degrees, and I do not for a moment doubt their dedication to providing equal access for their consumers; I am just pointing out some crucial differences between the qualifications required of CA’s and the qualifications required for VI’s.

It is my sincere hope that the FCC recognize the character of the work we perform and undertake a way of governing us and our work in ways that acknowledge the realities of video relay interpreting.

Thank you for receiving my feedback.





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