Please support us in informing the U. S. Department of Labor to consider alternatives to the proposed rules as it would limit Language Access for everyone.

In 2020 California interpreters and translators, with the help of our friends across the United States, succeeded in obtaining a partial exemption for interpreters and a full exemption for translators from AB5 through AB2257. The author acknowledged that the type of work we do is highly specialized and did not fit the general description of many workers' categories or professions that were being included in the bill where employment was the preferred model.

On October 13, 2022, the U.S. Department of Labor published the 6-factor rule in lieu of the ABC test, and this requires more clarity since the rules are too vague and broad as they pertain to employee classification.* 

Our service to the consumer (the end-user) works best when translators and interpreters are classified as freelancers because we are called upon in the private sector to serve the medical, judicial, education, and business communities, to name a few. Language access is at risk when limiting the availability of professionals who can be called upon at any time.

We urge caution in the rule-making process as we are self-employed and/or micro-businesses, and the consumer relies on the availability of highly skilled professionals to bridge language and cultural barriers. Not every contractor can be labeled with a one-size fits all model. 

The deadline to comment is the end of November. Please support our signature drive by signing today! 

Sincerely,

The American Alliance of Professional Translators and Interpreters (AAPTI)
aapticonnect.org

* https://www.regulations.gov/document/WHD-2022-0003-0001
For these 6 factors please read A. Introductory Statement (Proposed § 795.100)