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What a BSL Workplace Assessment Involves, and Why an Interpreter Is Part of It

/ Employment, Hearing loss, Professionals / By

By Daniel Morgan-Williams, Founding Director, Visualise Training and Consultancy Ltd.

A woman sits at a desk typing on a laptop while a man in glasses stands beside her holding a clipboard, in an office with white shelving, plants and a mug and pot of pens on the desk.
Photo by Vitaly Gariev on Unsplash

A referral arrives for a Deaf employee who uses British Sign Language (BSL). The reason for referral says “communication difficulties”. Email has been tried, and the employee has been getting through team meetings on lipreading and the goodwill of colleagues. The referrer needs to know what an assessment would actually look at.

This article explains how a BSL workplace assessment works, why an interpreter is part of the assessment itself, and what a useful report contains. It is written for occupational health, HR, equality and diversity leads, income protection and insurer claims teams, vocational rehabilitation professionals and case managers, and for Deaf BSL users. This article is general information rather than legal advice.

Why a BSL workplace assessment needs an interpreter

BSL is a language in its own right, with its own grammar. RNID describes it as structured in a completely different way from English, and notes that it was recognised as a language in its own right in 2003. It is not English produced with the hands.

That matters because, for many Deaf BSL users, English is a second language. The British Deaf Association (BDA) describes BSL as the preferred language of over 87,000 Deaf people in the UK for whom English may be a second or third language. That figure rests on the 2011 Scottish Census, so it is old and approximate, and no more recent UK count was found. The practical point holds regardless: written English cannot be assumed to be an equal substitute for BSL.

For an assessment, the consequence is straightforward. Asking a BSL user to explain their working day in written English, or in spoken English through lipreading, gives a thinner picture than a conversation in their own language, and puts a communication barrier inside the process meant to find barriers. Visualise Training and Consultancy Ltd therefore arranges a BSL interpreter for the assessment where one is needed, so the employee describes their experience in their preferred language and the assessor hears it accurately.

The interpreter’s role is narrow and deliberate. NRCPD describes sign language interpreters as professionals who interpret between a signed language and spoken English and who facilitate communication neutrally. The interpreter does not give an opinion on the employee’s needs or speak for the employer. A manager, family member or signing colleague is not a substitute, because they have their own role and interests and the employee may not want everything shared. No UK rule specific to this was found, so the point rests on professional practice.

What a BSL workplace assessment looks at

The assessment follows the working day rather than the job title. The employee explains how a typical week runs, and the assessor asks where communication works and where it breaks down. Seven areas usually need attention, and the table shows the kind of adjustment that may follow. Recommendations depend on the person and the role, and none is assumed in advance.

AreaSuggested adjustmentWhy it helps
MeetingsInterpreter arranged for the meetings that matter, with agendas shared earlyContent reaches the employee in their own language, at the same time as colleagues
Telephone and videoAgreed routes such as video relay, text based contact or interpreted calls, depending on the rolePhone based tasks can be organised or supported rather than left to workarounds
Alarms and safety informationVisual or vibrating alerts, and a clear plan for how announcements reach the employeeSafety information is only useful if it arrives in a form the person can receive
TrainingInterpreter and written materials arranged before the session, not after itTraining delivered in spoken English alone may not be accessible
Informal communicationWays to include the employee in day to day exchanges, such as team messaging and shared notesMuch workplace information travels in corridors and over lunch
Interpreter use across the weekA realistic pattern of when interpreting is needed and when other support worksAvoids booking for everything, or relying on ad hoc arrangements
Colleague awarenessPractical guidance for the team on working with a BSL user and an interpreterAdjustments work better when colleagues understand why they matter

The assessment makes no judgement about the employee’s capability or fitness for work. The employee is the expert on how communication works for them, which is why the language of the assessment matters.

Booking an interpreter: what referrers should know

Good bookings are made early. EHRC guidance says BSL interpreters need to be booked well ahead. That guidance is undated, and no single lead time appears in the sources checked, so ask the agency or interpreter what is realistic.

ASLI, the professional association for sign language interpreters and translators, advises that a booking request says when, where, why, who and what. It also says a team of two or more interpreters may be needed for longer bookings or more complex assignments regardless of length, and that interpreters can advise on this before a booking is confirmed. No universal threshold was found, so the advice is to ask rather than assume. The BDA suggests consulting the Deaf person about their communication needs, including the choice of interpreter.

Registration is the usual quality check. NRCPD, the National Registers of Communication Professionals working with Deaf and Deafblind People, describes itself as the national regulator of over 1,600 language service professionals, including BSL/English interpreters. Registrants have completed an approved course, follow a code of conduct, hold a standard DBS disclosure and carry professional indemnity insurance. ASLI describes the register as voluntary, and RNID also points to the Scottish Register of Language Professionals with the Deaf Community. ASLI adds that trainee interpreters carry restrictions on the assignments they should be booked for.

What This Means for Occupational Health, HR and Case Managers

The first step sits with the referrer. State on the referral that the employee uses BSL, and ask which interpreter arrangements they prefer, rather than describing the issue only as hearing loss or communication difficulty. That one line makes a booking possible.

A useful report would be expected to do the following.

  • Describe how communication works across the employee’s actual working week.
  • Tie each recommendation to a specific barrier, so it can be acted on, or declined with a reason.
  • Separate what needs an interpreter from what other measures can solve.
  • Cover safety information such as alarms, not only meetings.
  • Stay within workplace adjustments, leaving medical and capability questions to others.

The report is advice, and the employer decides what is reasonable in the circumstances. It is a workplace adjustments report and not expert witness evidence. For income protection and insurer teams, its value is a clear picture of the barriers and the adjustments that could address them, without any conclusion about fitness for work.

Legal rights and support

The British Sign Language Act 2022 recognises BSL as a language of England, Wales and Scotland. Its other provisions are narrower than many people expect. Section 2 requires the Secretary of State to report on what UK ministerial government departments have done to promote or facilitate BSL in their communications with the public. Section 3 requires guidance, although legislation.gov.uk showed that section as not yet in force when checked. On its wording, the Act does not place new duties on employers. Employer obligations come mainly from the Equality Act 2010.

Under section 20 of the Equality Act 2010, an employer must take reasonable steps where a provision, criterion or practice, a physical feature or the absence of an auxiliary aid puts a disabled person at a substantial disadvantage. An auxiliary aid includes an auxiliary service, and an employer generally cannot require the disabled person to pay the costs of complying. Acas lists a sign language interpreter as an example of specialist support. Whether an employee meets the definition of disability, and whether a particular adjustment is reasonable, depends on the circumstances.

Access to Work covers England, Scotland and Wales. GOV.UK lists support workers such as a BSL interpreter among the things a grant can help to pay for. A grant does not have to be repaid, and some costs may need to be paid up front and claimed back. Access to Work does not pay for reasonable adjustments, which remain the employer’s responsibility. Northern Ireland has a different system, and civil servants receive support from their employer instead. Check the GOV.UK pages at the time of any application. This article is general information rather than legal advice.

Summary

BSL is a language and not a form of English, and written English is not an equal substitute for many Deaf BSL users, so an interpreter is part of the assessment. A useful report ties each recommendation to a barrier and leaves decisions about what is reasonable with the employer. The British Sign Language Act 2022 does not, on its wording, place duties on employers, while the Equality Act 2010 and, for eligible employees, Access to Work are the relevant frameworks. A hearing loss workplace assessment that includes a BSL interpreter is a practical way to bring these together.

Next step

If you or someone in your team is deaf or has hearing loss and would like expert, tailored support to stay productive and comfortable at work, visit https://visualisetrainingandconsultancy.com/workplace-assessments/hearing-loss-workplace-assessment/ to arrange a hearing loss workplace assessment.

Frequently asked questions

Is a BSL workplace assessment different from a hearing loss workplace assessment?

Visualise offers BSL workplace assessments for Deaf BSL users as part of its hearing loss workplace assessment service. The purpose is the same, which is to identify barriers and practical adjustments. The difference is that the assessment is held with a BSL interpreter where one is needed.

Can written communication replace a BSL interpreter?

Not reliably. For many Deaf BSL users English is a second language, and comfort with written English varies. Ask the employee what works for which situation.

Does the British Sign Language Act 2022 require employers to provide interpreters?

On its wording, no. The Act places reporting and guidance duties on the Secretary of State in relation to ministerial government departments. An employer’s duty to make reasonable adjustments comes from the Equality Act 2010, and whether an interpreter is one depends on the circumstances.

Can Access to Work pay for a BSL interpreter at work?

For eligible people working in England, Scotland or Wales, GOV.UK lists support workers such as a BSL interpreter among the support a grant can help to pay for. A grant does not have to be repaid, and it does not replace the employer’s duty to make reasonable adjustments.

Sources

Note on sources: the BDA population figure rests on 2011 census data and the BDA page is undated. The EHRC guidance is undated in the copy found. Section 3 of the British Sign Language Act 2022 was shown as not yet in force on legislation.gov.uk when checked in November 2026. This article is general information and is not legal advice.