sa translators’ institute (sati) professional editors...

Joint submission on SALPC Bill by

SA Translators’ Institute (SATI)

Professional Editors’ Group (PEG)

Prof Anne-Marie BeukesVice-Chairperson: SATI

[email protected]

Structure of presentation

• Watershed for language-practice professionIntroduction

• Language-practice profession in Africa & South AfricaContextualisation

• SALPC an instrument of transformationResponse to SALPC

Bill

• Functions & composition of Board

• Accreditation, registration, code of conduct

Main points of comment

Conclusion

2

Important role: Language practitioners

3

Increased scope for translation &

interpreting industry

Fast growing sector

US Bureau of Labor Statistics

• one of 10 fastest growing occupations

Employment of interpreters & translators (2008 – 2018)

• projected to increase 22%

• much faster than average for all occupations

Global market for outsourced language

services (2012)

• Worth more than US$33 billion

• Translation occupies the largest segment, followed by

• on-site interpreting

• software localization4US News (2010) Kelly 2012

Translation in Africa

‘The Need for Translation in Africa. Addressing information inequality so that Africa may prosper’

(Kelly 2012)

• Prepared on behalf of Translators without Borders

• Africa’s share of language services market is disproportionate even when considering its share of global GDP (±3,5%)

• only about a quarter of 1% of the world’s total translation revenue

5

Projected Language Services Market & African Share

Region Market share 2012

US$ M

2013

US$ M

North America 49.25% 16,631 17,864

Western Europe 21.13% 7,137 7,666

Northern Europe 12.71% 4,292 4,610

Asia 7.43% 2,509 2,695

Southern Europe 5.39% 1,820 1,955

Eastern Europe 2.84% 960 1,031

Oceania 0.66% 222 238

Latin America 0.32% 110 118

Africa 0.26% 89 96

Growth totals 100.00% 33,768 36,271

Source: Kelly et al. (2012) 6

Africa: Language Planning &

Language-Practice Profession

Translation/interpreting a developmental & intel-lectualisation tool

Translation/interpreting creates discursive space

• developing new lexical items, registers & genres

• crucial vehicle for ‘increasing the social domains’ of languages

• Millán-Varela (2003)7

Translation & interpreting resources important language planning goal

• maximizing ability of a population to acquire knowledge

• increasing education levels & productivity

Governments should invest more in translation

• Kaplan (2012)

Places of Residence of African Language Translators

Source: Kelly et al (2012)

“(t)he translation trade is one of the least

organized of all trades in Africa” – Kelly (2012)

SATI

SA at forefront of organised translation activities on African continent

Benefit of organised representation since late 1950s when SATI was established

• From 1980s SATI’s focus addressed needs of its African language membership

• Member of International Federation of Translators (FIT) since 1993

SATI still only comprehensive non-profit professional organisation for

language practitioners

• 800 members across spectrum of language practice

• translators, interpreters, text editors, terminologists & lexicographers

• members representative of all official African languages & SA Sign Language, & 50 other languages, (e.g. French, Portuguese, German, Dutch, Spanish, Arabic & Mandarin)

9

PEG

Founded in 1993

Grown substantially

• current membership of over 570

Primarily an interest & support group for editors in educational, academic & general publishing

• Now includes editors working in magazines & the corporate & other fields as editors, writers, re-writers, proofreaders, indexers, book-designers & book DTP specialists

10

Bill: Main points of comment

Composition of SALPC’s

Board

Matter of a code of conduct

Matter of SALPC’s funding

11

Objectives allocated to

SALPC

Functions of SALPC

Matter of accreditation & registration

Terminology - Section 1

Inconsistency in use of terms language industry

& language profession(s)

• better term language profession

• underlines professional nature of our work

More specific term?

• We propose language practice

profession

Term text editor

• Accepted practice in SA

• We propose term text editor

rather than language editor

Definitions for both text editor & text

editing

• To be included

12

Submission

pp. 3 & 4

Terminology – Section 1

Definition of interpreter

(interpreting)

• Bring in line with definition of translator (translation)

Define both language

practice & language

practitioner

Definition of language profession

• very wide

Propose language practice

profession

• relevant to SALPC

Propose definition be amended to:

• “work related to translation, interpreting, text editing, terminology & lexicography”

13

Submission

pp. 3 & 4

Objects – Section 3

“provide efficient and effective language service to members of the public who seek the services of the Council” - s. 3(h)

• Will Council itself be providing translation, interpreting & similar services to general public?

We argue Council should not be providing ‘language service’

• Not core business

We propose: “provide efficient and effective service to

members of the public who seek the services of the Council”

• Thus to eliminate possible ambiguity

14

Submission

p. 4

Functions – Section 4

“promote and regulate professional liaison among registered professionals” –

s. 4(1)(d)

• We fully support idea of promoting professional liaison among language practitioners (e.g. LAMP)

• We propose that liaison should not be regulated

We in full agreement that SALPC “make recommendations on the provision of … education and training” – s. 4(1)(f)

• curricula to be in line with ‘multi-dimensional’ nature of translation & interpreting markets

Wish to emphasise that regulations in this regard set only minimum requirements

• tertiary institutions should have freedom to determine own curricula within framework of minimumprescribed requirements 15

Submission

p. 5


Provision for broad consultation & liaison

– s. 4(1)(c)

• SAQA

• DAC

• CHE

• National Skills Authority

Important omission

• No provision for consultation & liaison with relevant professional bodies

We wish to propose –

• Council also consult & liaise with relevant professional

bodies

• represent substantial numbers of language practitioners

16

Submission

p. 4 & 5


“develop and implement a framework for the accreditation of language practitioners at all levels” –s. 4(1)(q)

We in full support

• Core business of Council

• Will elevate Cinderella profession

• Ensure consistent service orientation

We propose accreditation must –

• include at least 2 levels of accreditation

• be linked to system of continuing professional development (CPD)

We propose practitioners must be involved in determining various categories of accreditation

17

Submission

p. 5


“develop, implement, enforce and revise the professional code of

ethics governing the conduct of all registered language practitioners” –

s. 4(1)(r)

• We fully support enforceable code of ethics

We are concerned

• single code will not be able to cover all the branches of language practice

We propose

• a generic code

• supplemented by rules to provide for specific requirements

• e.g. Sign Language interpreters' unique dress code

18

Submission

p. 5


“The Council may advise the Minister on … accreditation and competency levels in the language profession to improve the provision and the quality of services rendered by language practitioners, through adequate education and training” – s. 4(2)(a)

We propose augmenting as follows:

• “The Council may advise the Minister on … accreditation and competency levels in the language profession to improve the provision and the quality of services rendered by language practitioners, through adequate education and training (both in-service/ experiential training and by way of continuing professional development through short courses, workshops, seminars, etc.)"

19

Submission

p. 5


“The Council may enter into agreements with any person with expert knowledge in a particular field so as to assist or advise the Council in connection with any matter relating to its objects, powers, duties and functions in terms of this Act.” – s. 4(4)

SATI & PEG wish to offer their expert assistance

in relation to -

• codes of conduct

• accreditation matters

20

Submission

p. 6

Composition of SALPC Board

We propose that branches of industry

to be specified

• translation,

• interpreting,

• text editing,

• terminology, and

• lexicography

21

Submission

p. 6

“The members must be fit and proper persons … collectively possessing … appropriate knowledge, experience and skills in the language industry” –s. 5(2)(a)

• Too broad


“In appointing the members contemplated in subsection (1), the Minister must ensure … (b) that a balance of interests is maintained between persons representing—

• (i) the Department;

• (ii) the Department of Basic Education;

• (iii) the Department of Communications;

• (v) the council for higher education;

• (iv) the Department of Justice and Constitutional Development;

• (v) the Pan South African Language Board;

• (vi) the South African Qualifications Authority;

• (vii) tertiary institutions; and

• (viii) stakeholders in the language industry” –s. 5(3)(b)

We are concerned that –

• section is too heavily weighted towards representation by government structures

We propose that -

• professional associations should have permanent representation on SALPC Board

• because of large membership base a separate seat be rotated between or allocated to a representative of each of the two largest professional associations, SATI & PEG

22

Submission

p. 6


We propose that –

• chairperson & deputy chairperson be chosen by Board members (widely accepted convention that a board’s members do that themselves)

• liaison between Board & Minister should be responsibility of Board‘s chairperson

The independence & integrity of SALPC’s Board must not be at risk

23

Submission

p. 6

We are concerned that -

• s. 5(4) & 5(5) allow too much control by Minister of Arts & Culture

• Minister to appoint chair-person & deputy chairperson

• liaison between Board & Minister to happen via DAC representative

• independence & integrity of Board will be jeopardised


Appointment of a “selection panel consisting of senior departmental officials to review all the nominations [to the Board] and make recommendations to the Minister on the nominees” – s. 5(8) 5(8)

We propose that -

• representatives of language practitioners also be involved in selection panel

• not only departmental officials must be responsible for this

24

Accreditation – Section 20


• core business of SALPC, i.e. framework for accreditation,is dealt with very superficially

There is no reference to

• competence (only capacity)

• standards being met

• public accountability

We propose that following aspects be considered –

• categories of language practitioners to be accredited

• languages & language

combinations that SALPC will accredit

• different levels of accreditation that should be offered

• nature of qualification(s)

required for accreditation

25

Categories of language practitioners to

be accredited

From definitions it seems that government is thinking only of translators, interpreters, language (text) editors, lexicographers & terminologists

• If so, this should be specified

26

Submission

Para. 9.3

on p. 8

What about other categories such as –

• proofreaders (a separate category of practitioner)?

• language planners or language managers?

• lexicographers & terminologists?

• See next slide

• indexers & bibliographers?


be accredited

LexiEditors' Forum

• Represents 11 NLUs

Request to include the following:

• “As practising lexicographers, however, we would like to briefly address the point made in para. 9.3 of the SATI/PEG submission:

‘Have [the compilers of the Bill] considered whether …lexicographers and terminologists really need to be accredited – is there any possibility of untrained/incompetent persons passing themselves off as experts and putting the public at risk in the same way as a translator or interpreter might do?’

As the definition of lexicographer in the Bill rightly states lexicographers compile dictionaries and do not render a service to the public. If accreditation is really deemed necessary, we would like to play a role in the determination of standards for accreditation or the accreditation itself.

27


be accredited

We are concerned about position of sworn

translators - not clear?

• Bill seems to indicate that sworn translators will not be recognised as language practitioners after transitional period of 2 years - s. 41(1)(a)

We propose that the position of sworn translators be clarified

• Registered and/or accredited?

• Knowledge of legality of documents important

Bill could introduce category of permanently sworn interpreter

28

Submission

Para. 9.5

on p. 8

Levels of accreditation: Examples

Level 3

Conference interpreting

Level 2

Liaison interpreting

Level 1

Community interpreting (Recognition of prior

learning)

Level 4

Sworn translation

Level 3

Published translation

Level 2

Translation for info

Level 1

Community translation (Recognition of prior learning)

29

High

Low

Submission

Para. 9.4

on p. 8

Accreditation & registration

“Any qualification contemplated in subsection (1), obtained separately or conjointly with any other qualification, entitles a holder thereof to registration in terms of this Act if he or she has before or in connection with or after the acquisition of the qualification in question, complied with the prescribed conditions or requirements” – s. 32(2)

We are concerned that -

• accreditation could be granted on basis of an academic qualification alone

• considerable practical experience is generally needed to reach a level of competence required for accreditation

30

Submission

Para. 9.8

on p. 9

Accreditation & registration

We are concerned–

• that extent to which accreditation to be required is not specified

• whether practitioners need to be both registered & accredited in order to work in any language combination

• whether this will be limited to practitioners working in the official languages only

• Or: official languages plus major world languages

We propose

• distinction must be made between languages in which accreditation will be required

• how practitioners working in otherlanguages are to prove their credentials

31

Recognition of SATI accreditation

Bill silent on recognition of SATI’s accreditation

• Council must “recognise accreditation of voluntary associations that are in language profession” (leaving the Council no choice in the matter, with no limit on the period of recognition) – s. 4(1)(g)

• transitional provisions specify that for a period of two years after the legislation comes into operation the Council may recognise “accreditation granted by voluntary or other associations prior to the establishment of the Council provided that the Council may conduct a competency test whenever it deems this necessary” – s. 41(1)(b

32

We wish to propose that

• “grandfather clause” be included

• to grant permanent recognition to specified accreditation in force when legislation comes into operation

• SATI & PEG be specified since only bodies currently offering accreditation

SATI introduced accreditation in early 1990s

Continued professional development

We propose that –

• s. 4(1)(q) “develop and implement a framework for the accreditation of language practitioners at all levels” be augmented to read:

• “develop and implement a framework for the accreditation and related continuing professional development of language practitioners, providing for a minimum of two levels of accreditation”

33

We are concerned

• no provision for CPD

• practitioners would need to be re-accredited at regular intervals if no requirement for CPD

We propose that CPD must

• be required to maintain accreditation

• form an integral part of objectives of the SALPC

Submission

Para. 9.6

on p. 8

Continued professional development

We propose that -

• SATI & PEG are ideal partners in this exercise

• E.g.: PEG & ASAIB offer short courses that could be recognised in a CPD system

• mechanism for approving such courses could be included in a CPD system

34

CPD established in number of professions in SA

• could serve as examples in setting up system for language practitioners

Standard practice for statutory councils

• Enter into relationship with relevant professional bodies or individuals to present update or CPD training

Submission

Para. 9.6

on p. 8

Council’s funding

35

We are concerned that

• Bill does not indicate proportion of funding of Council that -

• should be appropriated by government

• will be obtained through accreditation & registration fees


• no minimum or recommended rates for work in field indicated

• this is customary for statutory bodies

Conclusion

Sincere appreciation for the opportunity to comment on this important piece of legislation!

SATI & PEG look forward to being involved in its further development

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