Senedd Cymru | Welsh Parliament
Bil Aelod Arfaethedig – Mark Isherwood AS | Proposed Member Bill - Mark Isherwood MS
Datblygu'r Bil Iaith Arwyddion Prydain (BSL) (Cymru) | Development of the British Sign Language (BSL) (Wales) Bill
Ymateb gan: Ymddiriedolaeth Prifysgol GIG Gwasanaethau Ambiwlans Cymru | Evidence from: Welsh Ambulance Services University NHS Trust
The British Sign Language Act 2022 requires the UK Government to issue guidance about the promotion and facilitation of the use of British Sign Language (BSL). This however only applies in England and not to the Welsh Government or public bodies in Wales such as councils or the NHS. The British Sign Language (BSL) (Wales) Bill aims to place equivalent specific duties on the Welsh Government and public bodies in Wales.
Yes. The introduction of a BSL Bill in Wales will help to create a fair and consistent approach to healthcare provision for BSL service users across the whole of the UK.
Whereas we agree with the goals that the Bill seeks to achieve, we have concerns over public sector organisations’ current capacity and resource to facilitate the achievement of the goals. Many public sector organisations within Wales are already operating under extreme pressures with growing demands upon public services, while recruiting and retaining suitably skilled individuals to support this work can be challenging.
Yes
Don’t know.
In principle, we agree. However, given the shortage of BSL interpreters across the UK, it may be unrealistic to expect interpretation support to be readily available for regional dialects. Achieving the aims of the Bill for standard UK BSL may be more achievable with a view to creating more support for regional dialects in the longer term. This will need to be coupled with a greater focus on training BSL interpreters in order to ensure sufficient long-term supply of suitably qualified professionals.
Don’t know.
The term BSL users is already more commonly known within the public sector. Both deaf and hearing signers would be referred to as ‘BSL service users’ within the healthcare sector. Replacing the term ‘user’ with ‘signer’ may add unnecessary confusion. However, the views and preferences of people who fall into this category should be the key influencing factors when making this decision.
Don’t know.
See above response in terms of our view on the terms ‘user’ and ‘signer’. However, as above, the decision should be informed by persons who are medically or audiologically deaf.
Agree.
NHS Wales organisations continue to build relationships with our deaf communities and are keen to hear their views when designing our services and we welcome feedback. Within the Welsh Ambulance Service, our Patient Experience and Community Involvement Team has established links with our deaf communities and works with them to seek their views and address any concerns. We acknowledge that we need to improve inclusivity of our deaf communities in our engagement and consultation procedures but mechanisms to include deaf communities in our consultation processes are already in place.
Agree.
It is important that deaf communities have the opportunity to voice their opinions when public services are being designed and delivered. However, expectations in terms of what can be achieved need to be realistic given the current systematic pressures in which public sector organisations are operating. Having an opportunity to voice opinions will help to influence decision-making processes but may not always lead to the outcomes that people desire.
InterpreterNow – a service that enables a BSL interpreter to relay conversations between the deaf person and Trust staff is currently used within WAST. Deaf users can access InterpreterNow through a Smartphone App or through a PC with a webcam. This seems to be a common communication method used by deaf service users.
However, accessibility is an issue and deaf users accessing a service using InterpreterNow would expect a continuation of their assessment in BSL when referred on to out-of-hours GP or Emergency Department where an interpreter would be available for their appointment
Health.
§ Insufficient internal operational procedures for booking interpretation support.
§ Lack of awareness and BSL skills amongst current public sector workforce.
§ Shortage of available BSL interpreters to provide interpretation support at short notice during emergency care incidents.
§ Lack of financial resources to cover the rising costs of interpretation services. There is currently no additional funding for any interpretation or language support and costs fall to individual organisations. These costs are often unpredictable. NHS Wales organisations expenditure continues to grow significantly each year to cover the costs of interpretation and translation costs.
The Bill proposes to establish a BSL Commissioner who would promote and facilitate the use of BSL, and would have the same powers as other minority language Commissioners such as in the Welsh Language (Wales) Measure 2011.
Don’t’ know.
Guidance and support from the Commissioner would be welcome to public sector organisations. However, it would be important that no further administrative burden is placed on organisations as a result.
BSL Standards would need to be realistic and not unachievable. They should also be designed with due consideration of the significant challenges facing health and social care. Standards that are too ambitious and onerous will act as a deterrent for organisations rather than encouragement to improve.
Reporting structures should be simplified for all involved. NHS Wales has already raised concerns with Welsh Government about complex and repetitive reporting templates for matters relating to equity, diversity and inclusion that result in duplication. A single reporting template designed for NHS Wales organisations isn’t always suitable given the different nature of services provided by each organisation. The Welsh Ambulance Service would support producing a progress report once every five years as outlined in the proposals. The consultation document also refers to reporting procedures via the Wellbeing of Future Generations Act reporting structures. cycle. It is unclear if this is in addition to the proposal to produce a statutory progress report once every five years for the Commissioner. The Welsh Ambulance Service would welcome further clarification on the reporting requirements for the BSL Bill.
No.
This may prevent the inclusion of necessary expertise in public sector areas which could be essential for the BSL Advisory Panel.
Enabling deaf users/signers to lead the development of policies and implementation of services for BSL users/signers; Early years language support for deaf children and their families; Improving BSL provision in education; Access to interpreters in public services.
We would expect the BSL Commissioner to work with relevant public sector organisations to prioritise the above.
Don’t know.
See response to question 11 which details our concerns over multiple reporting structures. If Welsh Government were asked to produce an annual report, this could also mean a requirement for individual organisations to provide information to inform this report. The Welsh Ambulance Service would ask the Senedd to consider the frequency of reporting whilst considering realistic timescales for making improvements. Whereas improving service provision for deaf communities is paramount, notable progress is likely to be made over a longer period of time, meaning that a report every 2 or 3 years may be more favourable.
Having read the consultation document and carried out some research into the UK BSL Bill and the arrangements in Scotland, the Welsh Ambulance Service would welcome the introduction of the proposed BSL Bill for Wales to ensure that BSL users in Wales are not disadvantaged and face widening inequalities with BSL users across the rest of the UK.
The Welsh Ambulance Service recognises the need to improve our communication and service delivery with deaf communities and service users and build upon the existing mechanisms we already have in place. Whereas we support the principles of the draft Bill, we trust that you will consider and review the proposed Bill to take account of the concerns which we have raised around the following:
§ Lack of capacity and resources within the public sector to implement the requirements of any proposed BSL standards.
§ Shortage of BSL interpreters across Wales and the wider UK.
§ Managing the expectations of BSL users in the provision of support within emergency healthcare.
Another point the Welsh Ambulance Service would like to raise relates to the Welsh Government’s review of the All Wales Accessible Information and Communications Standards which is currently underway. These Standards also extend to BSL users and are expected to be re-introduced early in 2025. Any BSL Standards introduced as part of the BSL Bill (Wales) would need to be consistent with these Standards. The Welsh Ambulance Service would not wish to produce separate reports against two different sets of Standards which both ask for progress updates on improving services for BSL users. This would not be useful or productive in terms of the administrative resource required for the reporting procedures. Duplication with these existing standards should be avoided and discussions held with Welsh Government prior to establishing a single set of standards.
The Welsh Ambulance Service would welcome the opportunity to be involved in further consultation and the development stages of the plans to ensure that there is representation from the emergency healthcare sector within Wales. We would recommend that representatives from other NHS Wales Organisations also be involved in the development stages.