HomeMy WebLinkAbout41P-Dealing with Deaf and Hard of Hearing Persons 2019
Policy & Procedure Page 1 of 7
Lexington Police
Department
Subject: Dealing with Deaf and Hard
of Hearing Persons
Policy Number:
41P Accreditation Standards:
Reference: Effective Date:
11/1/10
New
Revised
Revision
Dates:
1/24/19
By Order of: Mark J. Corr, Chief of Police
The Municipal Police Institute, Inc. (MPI) is a private, nonprofit charitable affiliate of the
Massachusetts Chiefs of Police Association. MPI provides training and model policies and
procedures for police agencies. This policy is an edited version of MPI Policy 2.19, “Dealing
with the Hearing Impaired.”
GENERAL CONSIDERATIONS AND GUIDELINES
Employees encountering people they believe are deaf or hard of hearing should never
assume that the person understands what is being communicated and should make
sure that [s]he understands. This caution applies to all forms of communication,
whether sign language, speech, writing, or reading.
Communication problems in police-public encounters provide the basis for
misunderstandings and potential problems, frustration, and embarrassment.
Therefore, it is important that employees are able to recognize persons with hearing
and communication handicaps, differentiate their actions and symptoms from other
causes, and take measures to facilitate communication.
Some persons with hearing difficulties also suffer from inner ear impairments that can
affect their balance, and speech may be slurred or otherwise difficult to understand.
It is the policy of the Lexington Police Department that:
Persons who are deaf or hard of hearing - whether they be victims, witnesses,
or suspects – shall be treated with respect, and in any encounters with such
individuals, an officer’s conduct shall conform to applicable provisions of
federal and state law and conditions articulated within this policy.
This department shall make available access to speech language interpreters
as coordinated by the Office of Deafness. i
All calls from persons who are deaf or have hearing loss or speech impairments
must be accepted through the department’s enhanced 9-1-1-communication
center.
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PROCEDURES
A. Definitions
1. Auxiliary aids and services: Communication aids that assist people
who are deaf or who have hearing loss. They include, for example,
hearing aids; cochlear implants; the exchange of written notes;
telecommunications devices for the deaf (TDDs), also called text
telephones (TTs) or teletype - writers (TTYs); telephone handset
amplifiers; assistive listening systems; videotext displays; and other
devices as well as hearing assistance dogs.
2. Lip-reading: (also referred to as speech reading): The ability to use
information gained from movements of the lips, face, and body to
increase understanding.
3. Qualified Interpreter: A person skilled in sign language or oral
interpretation and transliteration, has the ability to communicate
accurately with a deaf or hard of hearing person and is able to translate
information to and from such hard of hearing person. The
Massachusetts Commission for the Deaf and Hard of Hearing
(MCDHH) is the agency within Massachusetts that determines who is
qualified as an interpreter.
4. Sign language: Communication through the use of standardized hand
or finger signs or gestures. American Sign Language (ASL) is the form
of sign language most often used in the United States. Signs convey
concepts or ideas, even though a sign may stand for a separate English
word. Signing individual letters by finger spelling can supplement sign
language. Just as there are regional variations (dialects) in spoken
English, there are regional differences in sign language.
B. Emergency Call Takers and Dispatchers
1. The dispatch center is equipped to receive E9-1-1 calls from TDD and
computer modem users. All certified E9-1-1 call takers are trained to
communicate with callers using the systems TTY and TDD equipment.
Upon receiving an E9-1-1 TTY call, dispatchers shall communicate using
TTY communications procedures.
2. Dispatchers should place a high priority on response to emergency calls
for service from persons who are deaf or who are hard of hearing.
3. The deaf and hard of hearing shall be provided with direct, equal access
to all emergency services provided by this Department.
C. Communicating Encounters with Deaf or Hard of Hearing
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1. Encountering Deaf or Hard of Hearing Persons
a. Deaf persons may attempt to gain the attention of an employee by
touching the officer when the officer is not facing them.
b. This is how hard of hearing persons commonly gain the attention
of others, so that [s]he can see the other person’s face and
attempt to communicate.
c. Employees should not interpret this touching as offensive or
possibly threatening behavior.
2. Communicating Generally
a. Employees should never assume that the person understands
verbal communications until this can be confirmed by appropriate
responses to questions or directives.
b. Once someone is identified as a deaf or hard of hearing person,
employees should attempt to determine (by written or other forms
of communication) the person's preferred means of
communication (e.g., sign language, lip-reading, reading and note
writing, or speech).
c. Deaf or hard of hearing persons may require additional time to
understand and respond to commands, instructions, and
questions. Employees must be alert to indications that a person
may be deaf or have a hearing impairment. Such indications may
include, but are not limited to the following:
i. The appearance of bumper stickers, rear window decals,
or visor notices/symbols indicating the disability;
ii. Failure of persons to respond to spoken commands or signals;
iii. Use of signs, hand signals, or gestures in an attempt to
communicate;
iv. Display of cards by the person noting his or her hearing
disability;
v. Inability or difficulty of a person to follow verbal instruction or
requests for information;
vi. A need to see the officer's face directly, suggesting that the
person is attempting to lip-read;
vii. Evidence of assistive devices such as hearing aids, cochlear
implants, or picture symbols; and
viii. Evidence of behaviors such as increased agitation or
irritability, low frustration levels, withdrawal, poor attention, or
impaired equilibrium.
3. Lip Reading
a. Employees attempting to communicate with a person who can lip-
read should:
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i. Select a location that minimizes interference and
distractions;
ii. Face the person so that eyes and mouth are clearly
visible;
iii. Stand about three to six feet from the person;
iv. Avoid excessive body movement;
v. Speak only after getting the person's full attention;
vi. Make questions and instructions short and simple;
vii. Speak clearly and slightly slower than usual; and
viii. Be prepared to repeat one-self using different words to
rephrase any question.
b. The deaf person who lip-reads is visually oriented. Their
interacting with and understanding of another person are
determined primarily by their ability to see the officer.
c. Employees should address all questions and directives to persons
who lip-reads by facing them directly and speaking in a
moderately paced conversational tone.
i. Shouting or using exaggerated mouth movements
interferes with the ability to lip-read.
ii. Understanding can be further degraded by the presence
of facial hair, chewing gum, cigarettes, and so on.
4. Sign Language
a. A companion may interpret under emergency conditions or in
minor situations, when an interpreter is not available or required
by law.
b. In all other situations, officers should not rely on family members
or friends for sign language interpretation, due to their potential
emotional involvement, conflict of interest, and legal
requirements.ii
5. Hearing Aids
a. Employees cannot assume that persons who wear hearing aids
can hear and fully understand what is being said.
i. Some people use hearing aids to provide sound awareness
rather than to increase speech understanding.
ii. Highly stressful situations, background noise, multiple
speakers, and complex information and instructions can
compromise the limited effectiveness of hearing aids.
b. Employees can test comprehension by seeking appropriate
responses to simple questions or directives.
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D. Interpreter Requirements
1. Statutory Requirements
a. General Law Ch. 221 §92A requires the arresting officer to procure
and arrange payment for the services of a qualified interpreter for
a deaf or hard of hearing person whenever such person is
arrested for an allegation of criminal law, including a local
ordinance.
b. No answer, statement, or admission, written or oral, made by a
deaf or hard of hearing person in response to any question by a
law enforcement officer (or prosecutor), operating in an official
capacity, in any criminal proceeding, may be used unless such a
statement was made or elicited through a qualified interpreter.
c. Officers should be certain that when any deaf or hard of hearing
person executes a waiver, such person does so knowingly,
intelligently and voluntarily. In fact, in the case of a waiver of an
interpreter, the court must make a special finding that any
statement made by such deaf or hard of hearing person was made
knowingly, voluntarily and intelligently.
d. Generally, a waiver of rights will not be obtained and an interpreter
will be contacted consistent with the guidelines in this policy.
2. Communicating without an Interpreter
a. The need for use of a sign language interpreter is governed
generally by the length, importance, and complexity of the
communication.
b. In simple enforcement situations, such as traffic stops, driver's
license checks, or consensual police-public encounters, a
notepad and pencil may provide effective communication.
c. During questioning or interrogation, a sign language interpreter is
almost always required. iii
E. Arrest Situations
1. Arrest
a. Deaf and hard of hearing people are subject to arrest like any
other person in those situations where an officer has the right to
make an arrest. See the Department policy #41A –Arrest (with
or without a warrant).
b. A sign language interpreter need not be available in order for an
officer to make an arrest of a subject where probable cause is
established independent of interrogating the deaf or hard of
hearing suspect. iv
c. If probable cause to make an arrest must be established through
questioning or interrogation of a deaf or hearing-impaired person,
a sign language interpreter will be required.v
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2. Communication
a. Some deaf and hard of hearing persons have limited written
language skills, particularly involving difficult matters such as legal
warnings and admonitions. Therefore, officers should not assume
the effectiveness of this form of communication and should gain
confirmation of a person's understanding whenever possible.
b. All essential communication with the suspect should be completed
prior to the application of handcuffs, if possible.
c. If communication is necessary, officers may consider temporarily
removing the handcuffs from a suspect, unless doing so would
unnecessarily endanger the officer, the suspect, or others.
3. Field Sobriety Testing
a. Some deaf or hard of hearing persons have reduced verbal
communication skills, speech that may be incoherent or otherwise
resemble intoxication. They may have difficulty with equilibrium.
b. When administering standardized field sobriety tests officers
should consider:
i. Avoid using balance tests when equilibrium is an issue.
ii. Factor in speech impediments when evaluating a suspect’s
speech.
iii. Use the horizontal gaze Nystagmus test, if trained.
iv. Breathalyzer and/or blood alcohol measurements (PBTs)
should be employed as alternative tests when and if
available.
c. Officers must avoid any evidentiary questions during field sobriety
testing, as such questions require an interpreter.vi
4. Booking
a. When booking a deaf or hard of hearing person, officers may
communicate with the person being booked through:
i. Written communications;
ii. Verbal communications (if possible);
iii. A companion of the suspect acting as an interpreter;
iv. A non-certified interpreter; or
v. A certified interpreter.
b. Some deaf and hard of hearing persons have limited written
language skills, particularly involving difficult matters such as legal
warnings and admonitions.
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5. Rights: An officer must advise a deaf or hard of hearing person of his or
her Miranda and other rights through a qualified interpreter in order for a
waiver of those rights to be valid.vii
6. Questioning: Officers must be aware that any statements made by a deaf
or hard of hearing person, which are elicited without the use of a qualified
interpreter, may not be admissible as evidence against the defendant.
See Statutory Requirements in this Department policy.
F. Interpreter Contact Information
1. In situations involving the need for an interpreter, the Massachusetts
Commission for the Deaf and Hard of Hearing (MCDHH) shall be
contacted for an interpreter. Their contact information is listed below:
MCDHH-Executive Office MCDHH-Executive Office
150 Mount Vernon Street, Fifth Floor 600 Washington Street
Dorchester, MA 02125 Boston, MA 02111
Phone-617-740-1600
Fax- 617-740-1810
TTY- 617-740-1700
Emergency/afterhours - 1-800-249-9949
Toll Free Voice 1-800-882-1155
Toll Free Voice 1-800-530-7570
i M.G.L. c. 221, §92A.
ii M.G.L. c. 221, §92A.
iii Com. v. Kelley, 404 Mass. 459, 535 N.E.2d 1251 (1989): Defendant was entitled to an
interpreter despite the diligent and good faith efforts of the Saugus Police Department.
iv M.G.L. c. 221, §92A.
v M.G.L. c. 221, §92A.
vi M.G.L. c. 221, § 92A.
vii Com. v. Kelley, 404 Mass. 459, 535 N.E.2d 1251 (1989).