64 032111 04...mcbeth, eva olovsson, robert phillips, ginny redish and nad rosenberg among others....

ClarityNumber 64 November 2010

Journal of theinternational associationpromoting plain legal language

Editor in chief:Julie Clement

Guest editor for this issue:Neil James

Guest editor for Clarity 65:Sandra Fisher-Martins andJames Fisher

In this issueDr Annetta Cheek1. Defining plain language 5

Lynda Harris, Susan Kleimann andChristine Mowat2. Setting plain language standards 16

Helena Englund Hjalmarsson andKarine Nicolay3. Training for plain language 26

Dr Karen Schriver and Frances Gordon4. Grounding plain language in research 33

Carlos Valdovinos5. Advocating plain language 40

Sandra Fisher-Martins6. Certifying plain language 46

Dr Neil James and Eamonn Moran7. Strengthening plain language institutions 54

Clarity and general newsThis issue 3Contributing to the journal 32Member and other news and events 53How to join Clarity 61Message from the Presidents 62

Strengthening plain language:public benefit and professionalpractice

2 Clarity 63 May 2010

Country representatives

Slovak RepublicIng. Ján [email protected]

South AfricaCandice [email protected]

SpainCristina [email protected]

SwedenHelena Englundhelena.englund@

sprakkonsulterna.se

UKSarah [email protected]

USAProf Joseph [email protected]

ZimbabweWalter [email protected]

Other European countries:Catherine [email protected]

All other countries:Please contact the USArepresentative

Patrons The Rt Hon Sir Christopher Staughton, The Honorable Michael Kirby, andH E Judge Kenneth Keith

Founder John Walton

CommitteePresident: Christopher Balmford ([email protected])Members: Country Representatives plus Simon Adamyk, Mark Adler, Michèle Asprey, Peter Butt,

Sir Edward Caldwell, Richard Castle, Annetta Cheek, Julie Clement, Robert Eagleson,Jenny Gracie, Philip Knight, Robert Lowe, John Pare, Daphne Perry, John Walton,Richard Woof.

ArgentinaMaximiliano Marzettimaximiliano.marzetti@

erasmusmundus-alumni.eu

AustraliaChristopher [email protected]

BangladeshA.K. Mohammad [email protected]

CanadaNicole [email protected]

ChileClaudia Poblete [email protected]

FinlandHeikki [email protected]

GermanySiegfried [email protected]

Hong KongEamonn [email protected]

IndiaDr. K.R. [email protected]

IsraelMyla [email protected]

ItalyChristopher [email protected]

JapanKyal [email protected]

LesothoRetsepile Gladwin [email protected]

MalaysiaJuprin [email protected]

MexicoSalomé Flores Sierra [email protected]

The NetherlandsHélène [email protected]

New ZealandLynda [email protected]

NigeriaDr. Tunde [email protected]

PeruRicardo Leó[email protected]

PhilippinesVictor [email protected]

PortugalSandra [email protected]

Honor roll of donors to Clarity

Clarity is managed entirely by volunteers and is funded through membership fees and donations.We gratefully acknowledge those financial supporters who have contributed to Clarity’s success:

$2,500+ Plain English Foundation, one anonymous donor, Christopher Balmford

$1,000+ Joseph Kimble, Julie Clement

$500+ Nicole Fernbach

$100+ None

Clarity 63 May 2010 3

Clarity … the journalPublished in May and November

An international associationpromoting plain legal languagewww.clarity-international.net

create some kind of institute to do so? Is plainlanguage still a movement focused on its publicbenefits, or should we drive it towards a pro-fession?

The only thing resolved that day was the needto explore these questions further, and a votefrom the floor heartily endorsed setting up aworking group. The following year, PLAIN,Clarity and the Center for Plain Languagenominated two members each to form whatwe prosaically called the International PlainLanguage Working Group. They were joinedby a further six members from a wide rangeof countries and languages. Together, the grouphas represented the United States, the UnitedKingdom, New Zealand, Canada, Sweden,Portugal, South Africa, Mexico, Hong Kong,Belgium and Australia.

Early on, we realised that there would be norapid consensus. So we set out to write anoptions paper exploring the most prominentquestions relating to:

defining plain language

setting international standards

training practitioners

grounding plain language in research

advocating for plain language

certifying practitioners

strengthening our institutional structure.

Two years later, Strengthening plain language isthe result. It has been a long and challengingprocess. We debated the issues at conferencesin Mexico, Sydney and Lisbon. We released apreliminary draft at the 2009 PLAIN confer-ence and received some robust feedback thatthis version has taken into account.

No doubt, many will find much to disagreewith. For others, the paper will not go farenough. Despite the time it has taken, we re-main at the stage of identifying the questionsto ask and the options to consider.

Welcome from Clarity’s editor in chief

I’m pleased to bring you this important issue ofthe Clarity journal. We are sending this issue notonly to Clarity members, but also to members ofPLAIN and the Center for Plain Language.These three organizations came together to formthe International Plain Language WorkingGroup. The group has worked for several yearsto bring you the options paper, Strengtheningplain language: public benefit and professionalpractice, that forms this issue.

If you are not already a member of Clarity, wewelcome you to learn more about our organi-zation and to join—you need not be a lawyerto be interested in plain legal language and tojoin. You’ll find information about joining onpage 61. Meanwhile, I hope the options paperhelps you to form your views on the future ofour plain language world and that it encour-ages you to contribute to the discussion.

Julie Clement, editor in chief

This issue

Strengthening plain language: publicbenefit and professional practice

Neil JamesChair, International Plain Language Working Group

The journey towards this options paper beganearly one October morning at the 2007 PLAINconference in Amsterdam. In the historic Beursvan Berlage building, three plain language organ-isations were putting forward position papers onsome of the thorniest questions facing our field.

Should we establish international standardsfor plain language and how would that work?Can we certify plain language practitioners and

4 Clarity 64 November 2010

When it comes to standards and certification,for example, the working group has not yetendorsed any of the options we discuss. Whenconsidering training and research, we haveidentified such large gaps in our knowledgethat our work will have to focus on filling thembefore we can do anything concrete. Fortunately,we have identified at least one major fundingsource that might help us along the way.

We have been a little more concrete in profferinga standard definition of plain language, but onlyafter surveying a wide range of definitions andcombining two approaches. No doubt the finalwording will be the subject of considerabledebate.

The question of advocacy is closely bound withthat of the institutional structure. Do we attemptto set up an ambitious new international organi-sation or work with what we have? The optionspaper recommends a middle path that goesjust one step beyond the existing informalcooperative action of the working group.

None of the questions we began with havechanged much since the plenary in Amsterdam.But the options paper at least provides a morestructured account to help us answer them inthe most constructive way. We may only getone opportunity to do this, so it is better thatwe get it right rather than do it fast.

Underlying all of the chapters is the tension thatwas with us at the start: should our field remaina movement, become a profession, or achievesome other combination? Should we emphasisethe public benefits of plain language or focus onprofessionalisation as the best means to do so?This remains a core question.

The options paper answers other questions muchmore clearly. At times, plain language has at-tracted criticism that it is too narrowly focusedon expression, without enough emphasis onaudience, structure, design or testing. The paperconfirms that plain language practitioners willcontinue to bring a broad focus to improvingpublic communications.

That focus is increasingly being recognised bygovernments around the world, such as with thepassing of plain language laws in South Africa,and the Plain Writing Act in the United States.In some ways, the influence of plain languageis growing more quickly than its institutionalbase. This paper can help us catch up.

Strengthening plain language will be essentialreading for anyone affected by public commu-

nication, whether as a specialist languagepractitioner, a professional services provider,or an interested consumer of public language.We suggest you set aside some time to read it care-fully, think about the questions it poses and con-tribute where you can. All feedback is welcome [email protected].

I know we will continue to receive a diversityof views passionately held. But as the poetWilliam Blake once put it: ‘without contraries,there is no progression’. It is only by workingthough our ‘contraries’ that we will emergewith a more concrete model. I am sure we willcontinue to see the kind of constructive andcommitted comments that people have con-tributed to date.

On that note, I would like to acknowledgesome of the people and organisations thathave got us this far.

Firstly, the individual members of the workinggroup, who have drafted their chapters on topof already overfull workloads. The boards of thethree member organisations have also givenvery generously of their time, along with space intheir conferences for us to progress these issues.The Plain English Foundation has provided boththe time of the chair and some administrativeresources.

Secondly, thanks go to the many individualsoutside the current working group who havecontributed text and feedback: Mark Adler,Christopher Balmford, Sarah Carr, MartinCutts, Robert Eagleson, Brian Hannington,Anne Marie Hasselrot, Joe Kimble, LauraMurto Linden, Bill Lutz, Joanne Locke, SallyMcBeth, Eva Olovsson, Robert Phillips, GinnyRedish and Nad Rosenberg among others.

But I must reserve special thanks to Clarity, itsmembers and subscribers. Getting this optionspaper to print has delayed publication of yourjournal twice in recent years, understandablyraising concern. I hope you will forgive thoseof us involved given the nature and importanceof the enterprise.

Our next steps include distributing this paperas widely as possible to garner feedback. The2011 PLAIN conference in Stockholm thenpresents the opportunity to begin selecting amore concrete model for strengthening plainlanguage and its public benefits.

[email protected]

Clarity 64 November 2010 5

Dr Annetta CheekCenter for Plain Language, United States

Overview

The first task of the working group is to putforward a standard definition of plain lan-guage. We have looked at many definitions ofplain language and plain English fromaround the world. We include guidelines forplain writing as implicit definitions.

Many definitions are similar to each other,and some of those are probably derivative, sowe have restricted our selection to avoid te-dious and pointless repetition. Additionalsamples are in section 1.5 Appendix—Moredefinitions.

We have allocated each of the definitions toone or more of three categories. These optionsare similar to those identified in Neil James’spaper at the 2008 Clarity conference inMexico City (‘Defining the profession: plac-ing plain language in the field ofcommunication’, Clarity 61, May 2009).These are:

1. numerical or formula-based definitions

2. elements-focused definitions

3. outcomes-focused definitions.

These options represent ‘ideal’ definitiontypes. In practice, most definitions combinecharacteristics of two or even all three types.

Recommendation

We recognise that all three types of defini-tions play a role in determining whether aparticular communication is plain lan-guage, and all three help us achieve ourgoal of clear communication. However,for a basic definition, we recommend thatwe rely mainly on option 3. We propose:

A communication is in plain language if itmeets the needs of its audience—by usinglanguage, structure, and design so clearlyand effectively that the audience has thebest possible chance of readily findingwhat they need, understanding it, andusing it.

1.1 Three categories of definitions

Option 1: numerical or formula-based

This approach defines plain language prima-rily through specific elements of readability. Itflows from the earlier practitioners such asRudolph Flesch and modern followers suchas William DuBay. This approach counts ele-ments such as word and sentence length,number of syllables, length of paragraphs,font size, and so on, or uses formulas appliedmechanically to allocate documents points ona scale of plainness. They include the Flesch-Kincaid Index, the Coleman-Liau Index, andthe Gunning Fog index. Many of these resultin a measure of readability that purports toreflect the reading skill of people at a particu-lar level of education.

Strengths of this approach

• Formulas are relatively easy to apply (oftenby computer program).

• They do not require judgement or writingexpertise to administer.

• They offer an objective standard allowinganyone to decide as a matter of factwhether a document is readable.

• They can tell you if your document isdifficult to read.

Weaknesses of this approach

• Formulas are overly simplistic, looking atonly a few elements of language, especiallysentence and word length.

1. Defining plain language


• They don’t tell you definitively if yourdocument is easy to read.

• They can be misleading or even simplywrong.

• They provide no guidance on how toimprove writing, beyond ‘get a betterscore’.

• They recognise differences among readergroups only in gross ways, such as gradelevel.

Option 2: elements-focused

This approach is based on the techniquesused to write clearly, which may be classified,for example, under:

• structure (for instance, arranging theinformation in a reader-friendly order,logically subdivided and well signposted,and constructing readable sentences andparagraphs)

• design (for instance, using typeface,typesize, white space, colour, and othermethods to enhance readability)

• content (including helpful or entertaininginformation but omitting anything thereader doesn’t need)

• vocabulary (choosing words whichaccurately reflect the writer’s intention andwhich the intended audience willunderstand).


• It is much broader than the formula-baseddefinition.

• It is likely to more accurately reflect a text’sreadability.

• It provides guidance on how to improvewriting.

• It can be tailored to different reader groups.


• It is harder to use, and takes more time.

• It requires judgement and writing skill.

• It does not give a numerical measure ofsuccess.

• It can be difficult to achieve consensus onwhat specific techniques to consider, andwhich are the most important. This isespecially true for techniques that have notbeen examined by formal research efforts.

Option 3: outcomes-focused

This approach, adopted by organisationssuch as the Center for Plain Language, fo-cuses on how well readers are able tounderstand and use a document. The ap-proach generally includes consideration ofvisual elements making documents easy toread, not just linguistic characteristics. Evalu-ating the usability of a document with somesort of testing is strongly recommended byproponents of this definition.


• It is most likely to produce usabledocuments.

• It can give a statistical result of some sort,depending on the nature of the testing.

• It requires tailoring to differences amongreader groups.

• Testing can give very specific guidance onhow to improve a document.


• It is the most difficult approach to use.

• Outcomes can be difficult, or at least time-consuming and expensive, to measure.

• Testing is often impractical.

1.2 Examples from each category

Option 1: numerical or formula-based

The Flesch reading ease test

There are two tests devised by Rudolf Flesch.The formula for the Flesch Reading EaseScore (FRES) test is

A score of 60 or higher would be consideredplain language. Other scores are not labelled,

Score Notes

90.0–100.0 Easily understandable by anaverage 11-year-old student

60.0–70.0 Easily understandable by 13-to 15-year-old students

0.0–30.0 Best understood by collegegraduates

total syllables

total words( ))total words

total sentences(206.835 – 1.015 – 84.6


though a one-syllable sentence would scorethe maximum 121.

The test scores badly as plain mathematics,since the procedure is clearly not preciseenough to justify three (or any) places ofdecimals. You get the same score (or at worst,rounded to the next whole number) if youmultiply the average word length by 85, addthe average word length, and deduct bothfrom 207.

The other test developed by Flesch is theFlesch-Kincaid Grade Level test. It is alsocalled the Flesch-Kincaid Readability test.The formula for this test is:

The Coleman-Liau index

The Coleman-Liau index uses a different cal-culation. Its output approximates the UnitedStates ‘grade level’ necessary to comprehendthe text.

Unlike most of the other indices, Coleman-Liau relies on characters instead of syllablesper word. Although opinion varies on its ac-curacy as compared to the syllable/word andcomplex word indices, characters are morereadily and accurately counted by computerprograms than syllables.

The Gunning Fog index

Gunning, again relying on word- and sentence-length, suggests the ‘grade level‘—the numberof years of education—needed to understandthe text.

Dale-Chall readability formula

The Dale-Chall readability formula computesa raw score, called the Reading Grade Score(RGS), which rates text on a United Statesgrade-school level based on the average sen-tence length and the number of unfamiliarwords, using the list of 3000 words com-monly known by 4th grade students.

The formula for the Reading Grade Score is:

RGS = (0.1579 x DS) + (0.0496 x ASL) + 3.6365

This formula is not the most popular, althoughsome experts consider it the most accurate,since it’s based on a list of specific words.

Option 2: elements-focused

J G McKay, a 19th-century Scottish sheriffahead of his time, considered that:

Good drafting says in the plainestlanguage, with the simplest, fewest, andfittest words, precisely what it means.

Source: J G McKay, Law Quarterly Review 1887, p.326.

Richard Wydick characterises plain Englishas:

• economising with words

• avoiding archaic phrases, legalisms, andabstractions

• keeping subjects, verbs, and objects closetogether

• preferring simple verbs in active voice

• preferring one main thought in eachsentence

• varying sentence length, but allowing nosentence to be too long.

Source: Richard Wydick, Plain English for Lawyers,Carolina Academic Press, 5th edn.

The HRSA guidelines add more detail (andwe’ve excluded from this list criteria alreadymentioned):

Plain English:

• has a conversational style

• restricts the average sentence to about 15words

• avoids hyphens and compound words

• gives examples to explain ‘problem‘words

RGS

DS

ASL

Reading Grade Score

Dale Score, or % of words not onDale-Chall list of 3000 commonwords

average sentence length (thenumber of words divided by thenumber of sentences)

– 15.8score = ) number of sentences

number of words

number of characters

number of words( x 5.89 x 29.5– ( )

# of words of more than 3 syllables

# of wordsx 100

gradelevel = (( ) # of words

# of sentences+ )x 0.4

0.39 )total words

total sentences( total syllables

total words( ) – 15.59+ 11.8


• uses lower case rather than all capitalletters

• assesses readability

• gives the context first, before giving thenew information

• uses visuals that explain and clarify.Source: Health Resources and Services Administration,

USA, Plain Language Principles and Thesaurus forMaking HIPAA Privacy Notices More Readable.

More detailed elements-focused definitionsinclude the plain language standards used byorganisations such as the Plain LanguageCommission (United Kingdom), WordsmithAssociates (Canada), the Plain English Foun-dation (Australia) or the Write Group (nowWrite Limited, in New Zealand).

For example, the standard set of questionsused by the Plain Language Commission totest whether a document meets its Clear En-glish Standard include:

Purpose

• Is the purpose obvious or stated early andclearly?

Content

• Is the information accurate, relevant andcomplete, anticipating readers’ questionsand answering them?

• Are essential technical terms explained ordefined?

• Is a contact point stated for readers whowant to know more?

Structure

• Is the information well organised andeasy to navigate through, withappropriate headings and subheadings?

• Is there appropriate use of illustrations,diagrams and summary panels?

Style and grammar

• Is the style appropriate for the audience,with a good average sentence length (say15 to 20 words), plenty of active-voiceverbs, and reasonably short paragraphs?

• Is the document free of pomposity,verbosity and officialese (no aforesaids,notwithstandings, herebys, adumbrates,commencements and inter alias)?

• Is the text grammatically sound and wellpunctuated?

• Is capitalisation consistent in text andheadings?

• If there is a contents page, are itsheadings consistent with those in thetext?

Layout and design

• Does the document look good?

• Is the type easily readable and is thereenough space between lines of type?

• Is there a clear hierarchy of headings andspaces?

• Have emphasis devices, such as bold type,been used well?

While lists such as these are not primarilyused as definitions, they do serve to set out amore complete set of elements that plain lan-guage practitioners work with.

An even more detailed example of anelements-based definition is Joe Kimble’s 1992‘Charter for Clear Writing’, 9 COOLEY LREV 1 (1992), reprinted in three parts, 71MICH B J 1064, 1190, 1302 (1992). The 2002version is included in section 1.5 Appendix—More definitions.

Option 3: outcomes-focused

It is notable that two sources who providedetailed elements-based accounts of plainlanguage also offer us higher-level outcome-based definitions.

Ginny Redish

This definition, based on one by GinnyRedish, is widely used:

A communication is in plain language ifthe people who are the audience for thatcommunication can quickly and easily:

• find what they need

• understand what they find

• act appropriately on that understanding.

Ginny published the first two prongs of thisdefinition in 1985, in a chapter called ‘ThePlain English Movement’ in The English Lan-guage Today, edited by Sidney Greenbaum(Oxford: Pergamon Press). Since then, innumerous publications, she has added thethird prong. This is the definition used by theCenter for Plain Language.


Professor Joseph Kimble

In a resolution adopted in 1992 by the LegalWriting Institute, Joseph Kimble wrote:

Plain language means language that isclear and readily understandable to theintended readers.

He expanded on this in ‘Answering the Crit-ics of Plain Language’, Scribes Journal of LegalWriting (Vol 5 1994-95). Plain language is, hesays:

… the style of Abraham Lincoln, andMark Twain, and Justice Holmes, andGeorge Orwell, and Winston Churchill,and E. B. White. Plain words are eternallyfresh and fit. More than that, they arecapable of great power and dignity: ‘AndGod said, Let there be light: and therewas light. And God saw the light, that itwas good’.

Martin Cutts

Martin Cutts defines plain English as:

The writing and setting out of essentialinformation in a way that gives a co-operative, motivated person a goodchance of understanding the document atfirst reading, and in the same sense thatthe writer meant it to be understood.

Source: Martin Cutts, Oxford Guide to Plain English, OUP,1996, pp. 3-4.

He adds that plain English is not an absolutebut should be appropriate to the intended au-dience. Structure and layout should be usedto help.

The U.S. Federal Government’s Plain Lan-guage Network, in a definition derived fromGinny Redish, adds the concept of function:

Plain language is writing so your readerscan:

• find what they need

• understand what they read

• use it to fulfill their needs.Source: Federal Government Plain Language Network,

USA, Federal Plain Language Guidelines, http://www.plainlanguage.gov/howto/guidelines/reader-friendly.cfm

Many more examples of outcomes-based defi-nitions are in section 1.5 Appendix—Moredefinitions.

Not a definition

Make everything as simple as possible, butno simpler.

Source: Albert Einstein, widely quoted, but source nottraced.

1.3 Our recommendation

The purpose of language is to communicate.The purpose of plain language is to commu-nicate clearly and effectively. It places theneeds of the audience over any other consid-eration. So it seems to us that our definitionof plain language should be based primarilyon option 3—does the document work?

Options 1 and 2 are needed to support an ap-proach based primarily on option 3. Theguidelines in option 2 give us advice on howto achieve better communication. The read-ability tests of option 1 give us a rough guideas to whether we’ve succeeded.

We intend our definition to apply regardlessof language (not just to English) and regard-less of the medium by which it is promulgated(so including electronic documents andspeech, except that speech is not ‘designed’),but the advice on how to achieve it will varynot only with language and medium but alsowith the needs of each audience.

Recommendation

We recommend the following definitionof plain language:

A communication is in plain languageif it meets the needs of its audience—by using language, structure, anddesign so clearly and effectively thatthe audience has the best possiblechance of readily finding what theyneed, understanding it, and using it.

Some flexibility is essential here and we don’tthink we can usefully be more precise in for-mulating a definition. What is reasonable willalways depend on an infinite range of cir-cumstances, including the nature and purposeof the document and the abilities of the vari-ous readers. Some clarification should bepossible when standards are set.

One view is that if information is misleadingit cannot be plain and that honesty is there-fore an essential component of plain


language. This is a seductive idea, as a lie canbe expressed in plain language: I didn’t do it.And George Orwell argued for another, lessobvious, incompatibility: ‘The great enemy ofclear language is insincerity. When there is agap between one’s real and one’s declaredaims, one turns as it were instinctively to longwords and exhausted idioms, like a cuttlefishspurting out ink’ (Politics and the EnglishLanguage, 1946). So we believe we shoulddefine plain language without referring tohonesty but that the need for honesty shouldbe incorporated in the standards we set forplain language practitioners and documents.

1.4 Guidelines

As a starting-point for paper documentswritten in English for native English speakerswho have graduated from high school, weoffer the following guidelines because theyare designed with our recommended defini-tion in mind. They are no substitute forthought and should not be followed slavishlybut as a means to the end of serving theaudience’s needs—departing from themwhen the end can be achieved as well or bet-ter by other means. It is particularlyimportant that no institute or system of certi-fication to which these discussions gives riseshould become hidebound by form. As PhilKnight has said, ‘Writing is art, and art is bestwhen it is unbound.’

Structure

• Organise your points in chronologicalorder, logical order, order of importance, orsome other principle or combination ofprinciples that is likely to make sense to thereader.

• Get to the main point as soon as possible,with subsidiary points afterwards.

• Ensure that each paragraph deals with onetopic exclusively.

• Avoid paragraphs of more than about 150to 250 words.

• Avoid sentences of more than about 40words.

• Aim for an average sentence length ofbetween about 15 and 22 words.

• Avoid consecutive long sentences, even ifeach is less than 40 words.

• Keep subject, verb, and object as closetogether as possible, and generally in thatorder.

Design

• Use fonts and font sizes that are easy toread.

• Allow sufficient white space.

• Avoid large blocks of dense text.

• Use many meaningful headings (andcaptions for graphics).

• Use lists, tables, and other graphic elementswhere possible to express lengthy orcomplex material.

• Use design to illustrate structure andmeaning.

• Don’t sacrifice clarity to attractive design.

Content

• Don’t assume the reader knows something(unless you’re sure they do).

• Include the information the reader wants toknow—then think about what they mightask about next, and include that too.

• Omit superfluous material.

• Use words familiar to the readers wherethey would give the precise meaning.

• Where no such word exists, explain themore complex words.

• Give examples to explain difficult ideas.

• Always use the same word to mean thesame thing.

• Omit words and concepts the readerdoesn’t need (except those worth includingfor interest).

1.5 Appendix—More definitions

None of these examples are ‘pure’ examplesof one of our three types. Therefore, we havenot tried to put them into one of the catego-ries.

Connecticut consumer legislation

Connecticut’s consumer legislation requiresplain language contracts but offers businessesa choice between a formulaic (option 1) testand an elements (option 2) test. A contract isdeemed to be in plain language if it passes ei-


ther test, even if it fails the other. This seemsso arbitrary as to discredit both tests. On theother hand, it may strike a workable compro-mise between the need for certainty in lawand the need for fairness and flexibility. Toqualify under the first test, a contract mustfully meet all of the following criteria, usingthe counting procedures described in section42-158:

1. The average number of words persentence is less than 22.

2. No sentence in the contract exceeds 50words.

3. The average number of words perparagraph is less than 75.

4. No paragraph in the contract exceeds150 words.

5. The average number of syllables perword is less than 1.55.

6. It uses personal pronouns, the actual orshortened names of the parties to thecontract, or both, when referring tothose parties.

7. It uses no type face of less than eightpoints in size.

8. It allows at least three-sixteenths of aninch of blank space between eachparagraph and section.

9. It allows at least one-half of an inch ofblank space at all borders of each page.

10. If the contract is printed, each section iscaptioned in boldface type at least 10points in size. If the contract istypewritten, each section is captionedand the captions are underlined.

11. It uses an average length of line of nomore than 65 characters.

Connecticut’s second option deems a con-sumer contract to be in plain language if itsubstantially meets these criteria:

It uses short sentences and paragraphs.

It uses everyday words.

It uses personal pronouns, the actual orshortened names of the parties to thecontract, or both, when referring to thoseparties.

It uses simple and active verb forms.

It uses type of readable size.

It uses ink which contrasts with thepaper.

It heads sections and other subdivisionswith captions which are in boldface typeor which otherwise stand out significantlyfrom the text.

It uses layout and spacing which separatethe paragraphs and sections of thecontract from each other and from theborders of the paper.

It is written and organised in a clear andcoherent manner.

Source: Conn. Gen. Stat. S 42-152.

Michèle Asprey

Some people think that because plainlanguage is simple, it must be simplistic—a kind of baby talk. That is also wrong.Simple in this sense doesn’t meansimplistic. It means straightforward, clear,precise. It can be elegant and dramatic. Itcan even be beautiful ... Just ... clear,straightforward language, with the needsof the reader foremost in mind.

Source: Plain Language for Lawyers, Federation Press,3rd edn, 2003, pp 11-12.

Robert Eagleson

Clear, straightforward expression, usingonly as many words as are necessary. It islanguage that avoids obscurity, inflatedvocabulary and convoluted construction.It is not baby talk, nor is it a simplifiedversion of ... language.

Source: Writing in Plain English, Australian GovernmentPublishing Service, 1990, p. 4.

Bryan Garner

Plain English is robust and direct, theopposite of gaudy, pretentious language.It uses the simplest, most straightforwardway of expressing an idea. It useseveryday words. Generally speaking, [itis] the idiomatic and grammatical use oflanguage that most effectively presentsideas to the reader.

Source: Legal Writing in Plain English and Dictionary ofModern Legal Language, 1995, p. 662

Plain English Foundation

Plain language communication workswith and tests the content, structure,


expression and document design of a textso that its audience can readily find whatthey need, understand what they find,and act effectively on that understanding.

Source: Plain English Foundation, Australia,www.plainenglishfoundation.com

Business dictionary

Clear, direct, and ‘honest’ expression inspeech and writing. Plain language is freefrom jargon and rarely used words andterms, and comes straight to the pointbeing addressed.

Source: www.businessdictionary.com/definition/plain-language.html 15.2.09

Derived from the Social SecurityAdministration Notice Standards

[Plain English is:]

Logically sequenced

Pertinent

Sufficient for reader to take action

Clear and simple

Avoids jargon and legal terms

Grammatically correctSource: SSA Pub. No. 67-003.

Australian Commonwealth IndustrialRelations Commission on plain English:

Plain English is, in our view, clear andprecise language which is easy tounderstand and which communicates itsmessage effectively. It is not a simplifiedform of English. It puts the reader firstand avoids archaic words, jargon,unnecessary technical expressions andcomplex language. Plain English is notjust about words. It means using plainlanguage to express ideas so that theymake sense to the reader and designingdocuments so that information is easy tofind and understand ... Using plainEnglish does not mean sacrificingprecision.

Source: Award Simplification Decision (1997 75 IR , p.305), quoted by Peter Butt & Richard Castle:Modern Legal Drafting, 2nd edn, 2006, p. 124

[Derived from] Lee Clark Johns

Plain writing:

1. Is reader-friendly, focused on the readernot the writer.

2. Is organised logically with the main ideaup front.

3. Has a good balance of key points andsupporting evidence.

4. Uses appropriate words that are clear tothe reader.

5. Uses clear, grammatically correctsentences.

6. Has a predictable format.Source: The Writing Coach, 2004, Thomson Learning, Inc.

Office of Parliamentary Counsel,Australian Commonwealth

Plain language drafting refers to a rangeof techniques designed to createlegislation that is readable and easy to useby the relevant audience(s) for thatlegislation.

At the level of vocabulary, plain languagedrafters try to use words and expressionsthat are familiar to everyone. Althoughtechnical language is sometimes necessaryto achieve an acceptable level of precision,unnecessary jargon and gratuitousobscurity are eliminated.

At the level of syntax, plain languagedrafters try to create sentence patternsthat are easy for the average person toprocess. According to the experts, suchsentences tend to be short, avoidembedding, and branch to the right. Theyrely on verbs rather than nouns, theactive rather than the passive voice, andpositive rather than negative formulationsto state the intended law.

At the level of structure, plain languagedrafters try to organise statutes in a clearand meaningful way. The sequencing ofprovisions is based on chronologicalorder, logical order, order of importanceor some other principle or combination ofprinciples that is likely to make sense tothe reader. Equally important, thestructure of the statute is clearly revealedto the reader through use of headings andsubheadings, marginal notes, transitions,tables of contents, summaries and the like.


Plain language drafters also draw on theresearch and insights of experts indocument design. They pay as muchattention to fonts and white space as theydo to choice of words. They try to devisemethods of presenting material visuallythat will assist the reader to use thestatute book effectively, and withminimum effort.

Finally, plain language drafters try toprovide information that will help readersto interpret the text. Such informationtypically takes the form of purposestatements, explanatory notes, examples,summaries, overviews and the like.

Source: www.opc.gov.au/plain/index.htm 15.2.09

Law Reform Commission of Victoria onplain English

‘Plain English’ involves the use of plain,straightforward language which avoidsthese defects [listed earlier] and conveysits meaning as clearly and simply aspossible, without unnecessary pretensionor embellishment. It is to be contrastedwith convoluted, repetitive and prolixlanguage. The adoption of a plain Englishstyle demands simply that a document bewritten in a style which readily conveysits message to its audience. However,plain English is not concerned simplywith the forms of language. Because itstheme is communication, it calls forimprovements in the organisation of thematerial and the method by which it ispresented. It requires that material ispresented in a sequence the audiencewould expect and helps them to absorb it.It also requires that a document’s designbe as attractive as possible in order to helpreaders find their way through it.

Source: Plain English and the Law (Report, 1987, para 57)

Pennsylvania consumer legislation

Test of readability

(a) General rule: All consumer contractsexecuted after the effective date ofthis act shall be written, organisedand designed so that they are easy toread and understand.

(b) Language guidelines: In determiningwhether a contract meets the

requirements of subsection (a), acourt shall consider the followinglanguage guidelines:

(1) The contract should use shortwords, sentences andparagraphs.

(2) The contract should use activeverbs.

(3) The contract should not usetechnical legal terms, other thancommonly understood legalterms, such as ‘mortgage’,‘warranty’ and ‘securityinterest’.

(4) The contract should not useLatin and foreign words or anyother word whenever its userequires reliance upon anobsolete meaning.

(5) If the contract defines words,the words should be defined byusing commonly understoodmeanings.

(6) When the contract refers to theparties to the contract, thereference should use personalpronouns, the actual orshortened names of the parties,the terms ‘seller ‘ and ‘buyer’or the terms ‘lender’ and‘borrower’.

(7) The contract should not usesentences that contain morethan one condition.

(8) The contract should not usecross references, except crossreferences that briefly andclearly describe the substancesof the item to which reference ismade.

(9) The contract should not usesentences with double negativesor exceptions to exceptions.

(c) Visual guidelines: In determiningwhether a contract meets therequirements of subsection (a), acourt shall consider the followingguidelines:

(1) The contract should have typesize, line length, column width,


margins and spacing betweenlines and paragraphs that makethe contract easy to read.

(2) The contract should captionsections in boldface type.

(3) The contract should use ink thatcontrasts sharply with thepaper.

Source: Plain Language Consumer Contract Act, Pa.Stat. Ann. Tit. 73, §§ 2201,2205

Joe Kimble, ‘Elements of plain language’

A. In general

1. As the starting point and at every point,design and write the document in away that best serves the reader. Yourmain goal is to convey your ideas withthe greatest possible clarity.

2. Resist the urge to sound formal. Relaxand be natural (but not too informal).Try for the same unaffected tone youwould use if you were speaking to thereader in person.

3. Omit unnecessary detail. Boil down theinformation to what your reader needsto know.

4. Use examples as needed to help explainthe text.

5. Whenever possible, test consumerdocuments on a small group of typicalusers—and improve the documents asneed be.

B. Design

1. Make a table of contents for longdocuments.

2. Use at least 10- to 12-point type for text,and a readable serif typeface.

3. Try to use between 50 and 70 charactersa line.

4. Use ample white space in margins,between sections, and around headingsand other special items.

5. Use highlighting techniques such asboldface, italics, and bullet dots. Butdon’t overdo them, and be consistentthroughout the document.

6. Avoid using all-capital letters. Andavoid overusing initial capitals for

common nouns (this agreement, trust,common stock).

7. Use diagrams, tables, and charts asneeded to help explain the text.

C. Organisation

1. Use short sections, or subdivide longerones.

2. Put related material together.

3. Order the parts in a logical sequence.Normally, put the more importantbefore the less important, the generalbefore the specific, and the ordinarybefore the extraordinary.

4. Use informative headings for the maindivisions and subdivisions. In consumerdocuments, try putting the mainheadings in the form of a question.

5. Minimise cross-references.

6. Minimise definitions. If you have morethan a few, put them in a separateschedule or glossary at the end of thedocument.

(The next four items apply to analyticaldocuments, such as briefs and memos,and to most informational documents.)

7. Try to begin the document and the maindivisions with one or two paragraphsthat introduce and summarise whatfollows, including your answer.

8. Use a topic sentence to summarise themain idea of each paragraph or of aseries of paragraphs on the same topic.

9. Make sure that each paragraphdevelops the main idea through alogical sequence of sentences.

10. Use transitions to link your ideas and tointroduce new ideas.

D. Sentences

1. Prefer short and medium-lengthsentences. As a guideline, keep theaverage length to about 20 words.

2. Don’t pile up a series of conditions orqualifiers before the main clause.

3. In most sentences, put the subject nearthe beginning; keep it short andconcrete; make it something the readeralready knows about; and make it theagent of the action in the verb.


4. Put the central action in strong verbs,not in abstract nouns. (‘If the sellerdelivers the goods late, the buyer maycancel the contract.’ Not: ‘Late deliveryof the goods may result in cancellationof the contract.’)

5. Keep the subject near the verb, and theverb near the object (or complement).Avoid intrusive phrases and clauses.

6. Put the strongest point, your mostimportant information, at the end—where the emphasis falls.

7. Prefer the active voice. Use the passivevoice if the agent is unknown orunimportant. Or use it if, for continuity,you want to focus attention on theobject of the action instead of the agent.(‘No more legalese. It has been ridiculedlong enough.’)

8. Connect modifying words to what theymodify. Be especially careful with aseries: make clear whether the modifierapplies to one or more than one item.(Examples of ambiguity: ‘educationalinstitutions or corporations’; ‘a felony ormisdemeanor involving dishonesty’.)

9. Use parallel structure for parallel ideas.Consider using a list if the items are atall complicated, as when you havemultiple conditions, consequences, orrules. And put the list at the end of thesentence.

E. Words

1. Prefer familiar words—usually theshorter ones—that are simple and directand human.

2. Avoid legal jargon: stuffy oldformalisms (Now comes; In witnesswhereof); here-, there-, and where-words (hereby, therein, wherefore);unnecessary Latin (arguendo, inter alia,sub silentio); and all the rest (and/or,provided that, pursuant to, the instantcase).

3. Avoid doublets and triplets (any and all;give, devise, and bequeath).

4. In consumer documents, explaintechnical terms that you cannot avoidusing.

5. Omit unnecessary words.

6. Replace wordy phrases. Take specialaim at multiword prepositions (prior to,with regard to, in connection with).And treat the word ‘of’ as a goodindicator of possible flab (the duty ofthe landlord, an order of the court).

7. Banish shall; use must instead.

8. In consumer documents, considermaking the consumer ‘you’.

9. Avoid multiple negatives.

10. Be consistent; use the same term for thesame thing, without thinking twice.

Source: ‘The Elements of Plain Language’ in Lifting theFog of Legalese. Carolina Academic Press,Durham, NC. 2006.

© Anetta Cheek, [email protected]

Dr. Cheek is an anthropologistby training, earning a PhDfrom the University of Arizonain 1974. She worked for theUnited States federal govern-ment from 1980 until early2007. Most of her Federalcareer focused on writing andimplementing regulations. Shespent four years as the chiefplain language expert on VicePresident Gore’s NationalPartnership for Reinventing Government.

Annetta was the chair of the interagency plain languageadvocacy group, PLAIN, since it was founded in 1995until she retired from the government. She also admin-istered the group’s website, www.plainlanguage.gov. Sheserved for five years as an Executive Assistant to theAdministrator of the Federal Aviation Administration,focusing on plain language projects and serving on theWeb Council. She is the Chair of the board of the Centerfor Plain Language and the Director of Plain LanguagePrograms for NOVAD Consulting and R3I Consulting,DC-area consulting firms.


Lynda HarrisWrite Limited, New Zealand

Susan KleimannKleimann Communication Group, United States

Christine MowatWordsmith Associates, Canada

Overview

Perhaps the most challenging question thatthe plain language community faces is howto establish an international plain languagestandard. This chapter sets out the issues andoptions we will need to consider, but it doesnot yet define that standard or recommendwhat it should be.

Characteristics of a plain languagestandard

To begin, we felt it would be useful to identifythe characteristics of a ‘perfect’ plain lan-guage standard—one that would leave nodoubt that a text was truly in plain language.Based on our own experience, such a stan-dard would:

• acknowledge readers and their need tounderstand and use information

• place the responsibility on writers to clarifytheir thinking

• acknowledge the judgement required inwriting effective documents for readers

• prioritise ‘big picture’ concerns such aspurpose, structure, and navigation thatinfluence the success of a whole document

• include more detailed concerns such assentence length, word choice, andgrammar

• include some form of reader testing

• be applicable across all languages,documents, and audiences.

Elements versus outcomes—a false debate?

Historically, discussion about creating inter-national plain language standards has tendedto polarise practitioners into two camps:should standards be based on a checklist ofelements or on a test of user outcomes?

In this chapter, we use the term elements tomean the various writing techniques authorsuse to make a document more readable, suchas creating a clear structure, crafting infor-mative headings or using precise and familiarwords. By outcomes we mean the results oftesting document users (readers) to see if theycan understand the text and do what the writerintended and what they need.

There are strong arguments for both types ofstandards. But perhaps we have been en-gaged in a false debate. Rather than allowinga dichotomy to bar progress, this chapter looksat the merits of both and suggests a combina-tion of the two. This acknowledges that adocument using plain language techniqueswill be more readable and fit for purpose thanone that doesn’t. But it also argues that test-ing provides the ultimate proof.

Three approaches

To move ahead constructively in developing astandard, we have identified three approaches:

• elements only

• outcomes only

• a combination of these two.

In discussing these three approaches, wehave identified five options for a plain lan-guage standard and will discuss theadvantages and disadvantages of each.

2. Setting plain language standards


Recommendations

We put forward the following issues andtasks for the plain language communityto resolve as it works towards an interna-tional plain language standard:

Defining what we mean by ‘plainlanguage standards’

1. Agree on the nature of a plainlanguage standard and whether touse the ISO model or an alternativeframework.

2. Agree on the terminology used for thestandard—singular or plural.

Deciding how a standard would be used

3. Agree on who would use a plainlanguage standard and in whatcircumstances.

4. Agree on whether the standardshould initially apply to English textsand extend as quickly as possible toother languages, or accommodate alllanguages from the start.

Deciding on the form of a standard

5. Decide whether the standard shouldbe:

• Option 1: elements-based, detailedand specific to a single language.

• Option 2: elements-based, lessdetailed and not language-specific.

• Option 3: solely outcomes-based.

• Option 4: tiered, including elementsas mandatory and outcomes in asecond tier.

• Option 5: integrated, mandatingboth elements and outcomes.

Setting up a standards committee topursue this work

6. Form a committee, perhaps within theIPLWG, to progress this work by:

• gathering the views of theinternational community about whowill use the standard, how it will beused, and what form it should take

• producing a first carefullyresearched standard for plainlanguage

• setting up a revision process

• working with other committees or bodiescharged with related tasks in this optionspaper.

2.1 Defining the term ‘standards’

To discuss standards, we first need to clarifywhat we mean by the word. The words‘guidelines’ and ‘principles’ are often used in-terchangeably with ‘standards.’

The word ‘guidelines’ implies a set of leadingpractices or preferred ways of doing things.The word ‘principles’ is frequently associatedwith conduct, moral standards, or truth. Nei-ther word implies an authoritative set ofcriteria or individual elements that must bemet, which is a useful way to interpret theword standards in the context of plain lan-guage.

The Oxford Dictionary of English includestwo applicable definitions of a standard:

1. ‘a required or agreed level of quality orattainment’ (half of the beaches fail tocomply with European standards)

2. ‘something used as a measure, norm, ormodel in comparative evaluations’ (thesystem had become an industrystandard).

The following Wikipedia entry is also useful.

Standards are produced by manyorganisations, some for internal usageonly, others for use by groups of people,groups of companies, or a subsection ofan industry. A problem arises whendifferent groups come together, each witha large user base doing some well-established thing that between them ismutually incompatible.

There are many National Standards, butoverall the International Organization forStandardization, based in Geneva,Switzerland has established tens ofthousands of standards covering almostevery conceivable topic. Most of these arethen adopted worldwide replacing all theincompatible ‘homegrown’ standards.Many of these are naturally evolved fromthose designed in-house within anindustry, or by a particular country, while


others have been built from scratch bygroups of experts who sit on variousTechnical Committees.

We need to agree on the nature of a plainlanguage standard and whether to use theISO model or an alternative.

An additional problem is that plain languagepractitioners talk about both ‘standards’ and‘a standard’. We note that the ISO standardssystem uses the singular ‘Standard’ to em-body all the individual ‘requirements’.

Recommendations

That the plain language community agreeon:

1. the nature of a plain languagestandard and whether to use the ISOmodel or an alternative framework

2. the terminology used for thestandard—singular or plural.

2.2 Establishing the intended use for aplain language standard

To make sound decisions on the form of aplain language standard, we must next estab-lish who will use it and how it will be used.These fundamental decisions will drive manyof those that follow about the standards, in-cluding which option we choose. Followingare the main questions we need to answerearly on.

Who will use the standard?

Is the standard for plain language practitio-ners only? Is it for plain languagepractitioners who have been accredited to as-sess against the standard? Or is the standardto be published as a guide for all writers touse? Will the clients of plain language practi-tioners use it to determine whether workdone for them is indeed in plain language?

How will the standard be used?

Will the standard be represented by a logothat shows a document has met the stan-dard? Will plain language practitioners orsome other group assess that a document canuse the logo? Even without a logo, how willthe assessment of meeting the standard bemade? In short, who can make the statementthat ‘this document meets the plain languagestandard’?

Further, how will practitioners want to usethe standard? Will they use it to give credibil-ity to their work? Will they ‘sell’ clients on theidea that their documents meet the interna-tional standard?

Will organisations use the standard to showthat their documents are in plain languageand that they value clear, open communica-tion? Will they publicise that their documentsor some of their documents are in plain lan-guage? Who will then do the certification of acompany’s documents?

What documents will the standard apply to?

To what types of documents does the stan-dard apply? Are internal and externaldocuments treated differently? Will electronicmedia require a different standard? Wouldinteractive or dynamic media require a differ-ent standard?

How will the standard work internationally?

To be accepted internationally, a plain lan-guage standard will have to work acrosslanguages. Section 2.3 ‘Exploring an ele-ments-based standard’ discusses this topic inmore detail.

Given that many practitioners already usesome form of plain language standard, andmany more are interested in the concept, itshould be relatively quick to gather meaning-ful information on these questions. Perhaps aseries of short surveys over several monthscould be widely distributed to gather re-sponses from the international community.

Recommendations

That the plain language community agreeon:

3. who would use a plain languagestandard and in what circumstances

4. whether the standard should initiallyapply to only English texts and extendas quickly as possible to otherlanguages, or accommodate alllanguages from the start.


2.3 Exploring an elements-basedstandard—options 1 and 2

This section discusses:

• the general advantages of an elements-based standard

• current standards in use

• two options for what an elements-basedstandard could include

• some apparent disadvantages.

Whatever elements-based standard we mightcreate, we would have to apply it in the con-text of writers’ purposes and theirdocuments’ readers. In addition, all of the el-ements in a plain language standard shouldbe based on current research and be updatedas new research emerges.

What are the advantages of an elements-based standard?

An elements-based standard:

• addresses issues, known from research andexperience, that are most likely to affectreader comprehension

• offers the means to assess a document in arelatively quick, cost-effective way

• does not require any special set up orresources

• gives the writer or document ownerresearch-based feedback and a greaterappreciation of plain language techniques

• is easier for most people (practitioners andthose within an organisation) to graspbecause it tends to be more concrete

• may be used more widely than a standardthat includes testing.

Are there any elements-based standardsin use?

Several different elements-based standardsare currently used in various parts of theworld. Most of these will provide anassociated logo to indicate that a particulardocument has met a defined plain languagestandard.

Examples of plain language standardscurrently in use include:

• the Plain Language Commission’sdocument accreditation (Martin Cutts,United Kingdom)

• the PlainLanguage.gov’s ‘Federal PlainLanguage Guidelines’ (Amy Bunk andKathryn Catania, United States)

• Wordsmith Associates’ criteria for achievingWordmark Certification (Christine Mowat,Canada)

• the Center for Plain Language’s criteria forachieving a ClearMark Award (SusanKleimann and Annetta Cheek, UnitedStates)

• the Plain English Foundation’s‘verbumetric’ document evaluation systemand Plain English Standard (Neil James,Australia)

• Write Limited’s criteria for achieving theWriteMark Plain English Standard (LyndaHarris, New Zealand)

• the Plain English Campaign’s criteria forachieving a Crystal Mark (UnitedKingdom).

All of these examples are focused on theneeds of the audience and cover topics suchas purpose, content, structure, design, ex-pression, and style. However, they includedifferent levels of detail and emphasis.

Settling the definitive content for an ele-ments-based standard is outside the scope ofthis paper. Instead, we present two differentoptions:

• Option 1: an elements-based standard thatis detailed and specific to a single language.

• Option 2: an elements-based standard thatis less detailed and not language-specific.

Option 1: elements-based standard detailedand specific to one language

The type of detail a standard that is specificto a language may include (in this case theEnglish language) is illustrated in MartinCutts’ Oxford Guide to Plain English in his‘Summary of guidelines’. The key points ofthis summary are:

Style and grammar

• Make the average sentence length of 15-20words.

• Use words your reader is likely tounderstand.

• Use only as many words as you need.


• Prefer the active voice unless there’s a goodreason for using the passive.

• Use clear, lively verbs to express actions.

• Use vertical lists to break up text.

• Put your points positively when you can.

• Reduce cross references to a minimum.

• Avoid sexist usage.

• Use accurate punctuation.

Organisation

Organise your material in a way thathelps the reader to grasp the importantinformation early and to navigate throughthe document easily.

Layout

Use clear layout to present your words in aneasily accessible way.

Christine Mowat has written a much moredetailed set of elements, published in the pre-liminary draft of this paper distributed at the2009 PLAIN conference in Sydney. Spaceconstraints mean we cannot include themhere, but we suggest any close examinationof elements for an Option 1 standard shouldrefer to Christine’s work.

The specific disadvantage to Option 1 is thatmany of the elements will not travel acrosslanguages. This would mean creating differ-ent versions of the standard for differentlanguages. It also shares the generaladvantages and disadvantages of anelements-based standard discussed below.

Option 2: elements-based standard lessdetailed and not language-specific

In option 2, the standard would comprise aset of statements that would describe a plainlanguage document, regardless of which lan-guage it was written in. For example, astandard that identifies elements such as‘Structure and navigation are obvious andwell-marked so the audience can find the in-formation they need’ can potentially beshared across languages.

In this approach, we would not stipulatehow plain language specialists or anyone elsewill make detailed judgements about each el-ement. But the statements under thestandard could be supported by language-specific guidelines or checklists. In the sameway, this type of standard could be usefully

applied to many varied situations that re-quire slightly different guidelines orchecklists, such as in health information.

To illustrate, the ClearMark Awards criteriafrom the United States Center for Plain Lan-guage and the New Zealand Write Limited’sstandard are elements-based standards thatcould potentially cross languages. Both ofthese are supported by more detailed check-lists of elements that are specific to theEnglish language.

The ClearMark Criteria(amended for this paper)

The scoring criteria for the ClearMarkAwards cover the key characteristics of aplain language document. The topics wereintentionally phrased to capture characteris-tics of both paper and electronic documentsand with the idea that these criteria mightwork across languages. Testing is included asa requirement.

Category Criteria for document(or web page)

Purpose The purpose is clear andand considers who will use theapproach document, why they would

use it, and what tasks theywill do with it.

Design The design and layout rein-force meaning and make iteasy for the audience to see,process, and use the informa-tion.

Structure Structure and navigation areobvious and well-marked sothe audience can find the in-formation they need.

Hierarchy The hierarchy helps the audi-ence distinguish betweencritical and less important in-formation.

Language Plain language techniques(such as straightforward sen-tence structure, strong verbs,precise word choice) are usedto ensure the audience canread, understand, and use theinformation.


The Center has also developed a more de-tailed checklist that matches the topics of thecriteria. As an example, here is the Design el-ement with its checklist items added:

The Design reinforces meaning andmakes it easier for the audience to see,process, and use the information.Consider if the design:

• organises the information in a sequencethat’s logical for the audience

• uses layout to make information easy tofind, understand and use

• use principles of good design—includingappropriate typography, font size, linespacing, color, white space and so on

• uses visuals to make concepts,information and links easier to see andunderstand

• for online information, minimises thenumber of levels

• for online information, layers informationappropriately, avoiding too much on onepage.

The Write Limited Short Plain EnglishStandard

Write Limited in New Zealand uses the fol-lowing as its in-house standard that allcompany documents must meet. This samestandard is also used in various ways byWrite clients. It comprises a set of statementsthat describe a reader-focused document inEnglish.

The Standard is accompanied by a more de-tailed checklist (not included here) thatinterprets the standard and provides ques-

tions for a writer or reader to use to morefully understand what Write Limited means.

Big picture elements

1. The purpose of the document is clearat the start.

2. The content supports the purpose ofthe document.

3. The structure of the document is clearand logical to the reader.

Language elements

4. The paragraphs are mostly short andfocus on one topic.

5. The sentences are mostly short andstraightforward.

6. The words are precise and familiar.

7. The tone supports the purpose of thedocument.

Presentation elements

8. The layout and presentation help thereader absorb the messages quicklyand easily.

9. The document is error free.

The specific advantage to Option 2 is that asingle standard will work across languages.The specific disadvantages to Option 2 arethat it requires:

• a greater level of judgement

• an accompanying checklist with morelanguage-specific details.

What are the disadvantages of an elements-based standard?

Whatever decision we might make about spe-cific elements, an elements-based standardhas the following disadvantages:

• It will be difficult to agree on whatelements to include and the level of detailrequired for each element.

• Some elements require a high level ofjudgement, such as ‘Use clear layout topresent your words in an easily accessibleway’, and thus may be open to broadinterpretation.

• The broad accessibility of an elements-based standard can lead to uninformed orinappropriate use by non-practitioners.

Category Criteria for document(or web page)

Impact The writer or the organisationas the writer comes across asreliable and trustworthy.

Testing The testing uses an acceptablemethodology, appropriate forthe combined impact, impor-tance, and type and number ofpeople who will use this docu-ment.


• No matter how well a document scores onan elements-based assessment, withouttesting it cannot guarantee that it will workas intended for the reader.

2.4 Exploring an outcomes-basedstandard—option 3

The next option we discuss is to create an en-tirely outcomes-based plain languagestandard. This involves testing documentswith real users to discover how well they areunderstood and whether they fulfil their pur-pose.

What are the advantages of an outcomes-based standard?

Few would argue against the value of testinga document on a sample that reflects thepeople who will use it. The outcome—whether the document is understood by theintended readers, or not—is revealed by harddata.

An outcomes-based standard:

• reveals what readers understand andwhere a document has weaknesses

• picks up more subtle features such as theinferences readers take from a document

• provides data about how the document isworking that goes beyond author opinion

• reveals what intended readers think whenthey read the document and what they arelikely to do in response

• reveals the strengths and weaknesses of thewriter’s assumptions about the readers.

Are there any outcomes-based standardsin use?

In our reading and discussions, we have notfound any universally accepted standard fortesting documents with users. Nor does it ap-pear that any private practitioners have settheir own standard and termed it as such.

In part, this is because reader testing embod-ies a range of different tests, such as cognitiveinterviews, usability testing, timed testings, orparaphrase testing. Each has a specific pur-pose and outcome, and each has a range oftechniques to gather data. Both qualitativeand quantitative testing is grounded in a richand rigorous research tradition with specifictechniques and approaches. In any well-designed test, the type chosen depends on the

questions to be answered, the time available,the population targeted, and the potentialimpact of the document.

What unifies an outcomes-based standard isits focus on whether readers can understandthe document. This is the ultimate judgementof a document’s success. Without reader test-ing, any assessment of a document is ahypothesis of what will work.

Outcomes testing does not negate the use ofother standards, techniques, questions, orchecklists. But advocates of an outcomes-basedstandard argue that it is only by testing withreaders or end users that authors can ulti-mately identify whether the documentsucceeds.

What are the main objections to anoutcomes-based standard?

There are two objections to adopting anoutcomes-based standard alone as thestandard for plain language: the feasibility oftesting all types of documents and the timeand money it takes to test.

The feasibility of testing

At a pragmatic level, it is simply not possibleto test every document. For example, itwould be hard to justify formal usability test-ing of documents intended for a singlereader, such as is the case for many emails orinternal memos. There may be little point intesting the minutes of a meeting with ‘repre-sentative’ readers before sending themdirectly to participants. And it is highlyunlikely, for example, that executive readersor government ministers would take the timeto participate in a document test before read-ing a revised version.

So an outcomes-based standard may notmean that every document must be testedwith its intended readers. The difficult issueis how to define the point at which testingshould be mandatory. Testing is clearly morecrucial for documents that have high publicvisibility, provide critical information, arewidely distributed, or have potentially life-affecting consequences. But can we definethese precisely enough to cover all documenttypes, contexts and languages?

Resolving this first concern about an outcomes-based standard will follow in part from themore fundamental question of how a plainlanguage standard would be used. It may be,


for example, that the types of documents thatare not feasible for testing are less likely to beput forward as meeting a plain languagestandard. While this would get around theproblem, this assumption could be wrongand would need further debate.

The cost of testing

The second objection to establishing anoutcomes-based standard is the perceptionof cost—both in money and time. Let us beclear: reader-testing need not be an arduous,expensive, or time-consuming task. Testingcost is predominantly driven by the size ofthe sample and by the number of locationsthat the research design (and the client)stipulates. Some testing can be expensive, butin other cases it can be relatively inexpensive.

The characteristics of a document and its usewill drive the costs: the higher the visibility,criticality, distribution, and impact of a docu-ment, the more crucial testing becomes. Sotime and money will be relative to impact.Again, as we answer the questions about us-ing the plain language standard, we will seemore clearly whether this option is viable.

What form might an outcomes-basedstandard take?

Given the variety and complexity of testingtechniques, it would be challenging to write ahighly prescriptive outcomes-based standard.However, the goal of the standard should notbe how to conduct the testing, but more toprovide parameters about the intended out-comes.

A collection of guidelines or leading practicesfor an outcomes-based standard would needsome minimum criteria. There could beguidelines on the following aspects.

Form of criteria

We could:

• set a series of prescriptive testing regimeswith specified criteria

• establish a set of leading-practice guidelines

• recognise any type of user test as valid.

Skill of practitioner

We could agree that to achieve an outcomes-based standard, testing could be carried outby:

• accredited professionals

• any well-established professional ororganisation that includes user testing as acore service

• any person or organisation who devisesand carries out a test.

What are the disadvantages of an outcomes-based standard?

An outcomes-based standard is likely to havesome further disadvantages:

• Each document test plan depends on theresearch questions, the selection of thetechnique, the schedule, and the budget.This means it is difficult to identify preciseparameters across all tests.

• Each document test plan depends on theskill of the practitioner. A poorly framedreader test, with inadequate or flawedanalysis will have questionable results.

• The acceptance of testing by the clients ofpractitioners will vary depending on theirknowledge and the general acceptancewithin an industry.

• Some documents with low visibility, smallaudiences, low criticality, and lowdistribution do not warrant an investmentin testing and could never meet anoutcomes-based standard for plainlanguage. This may impair the universalacceptance of that approach.

2.5 Exploring a combination standard—options 4 and 5

A combination standard would combine ele-ments-based and outcomes-based assessment.Here we explore two options.

• Option 4 is a tiered approach in which thefirst tier does not include reader-testing andthe second tier does.

• Option 5 is an integrated approach thatmandates reader-testing as a part of thestandard.

A combined standard offers the following ad-vantages:

• it demonstrates that a documentincorporates plain language elements

• it demonstrates that a document achievesits outcomes for readers.

We believe that a combination standard mayprovide the solution to bridging the divide


between elements-based and outcomes-basedadvocates. But as with the previous options,our final decisions will be influenced by thefundamental questions raised earlier aboutwho will use the standard and under whatcircumstances.

Option 4: tiered standard

A tiered standard would include:

• a first tier in which a document would beassessed against its use of plain languageelements discussed in Option 2

• a second tier in which a document has adual assessment based on plain languageelements combined with reader testing(Options 2 and 3).

What are the advantages of option 4?

A tiered standard:

• acknowledges that many practitioners useelements-based assessment

• means that clients can meet a plainlanguage standard to a certain level evenwhere they will not invest in testing

• encourages testing by reserving the secondtier for documents that have been tested.

What are the disadvantages of option 4?

At the same time, a tiered standard meansthat:

• testing may be seen as ‘added-value’ ratherthan integral to a truly reader-focuseddocument.

• the elements-based standard could becomethe default standard if plain languagepractitioners (or their clients) do notembrace the second tier.

Option 5: integrated standard

An integrated standard requires an assess-ment with both an elements-based standardand an outcomes-based standard. In this op-tion, testing is a mandatory part of thestandard.

What are the advantages of option 5?

An integrated standard:

• incorporates an elements-based assessmentas an integral part of the standard

• incorporates the outcomes-basedassessment as an integral part of thestandard

• means that using only elements-based oronly outcomes-based standards areexceptions to the integrated standard.

What are the disadvantages of option 5?

An integrated standard:

• could limit the number of documents thatcan meet a plain language standard

• could limit the practitioners able to producedocuments meeting the standard

• increases the learning curve of practitionerswho are not currently testing

• means that documents that are not testedcannot meet a plain language standard

• accepts that the standard sets the highestbar.

Recommendation for sections 2.3, 2.4,and 2.5

5. The plain language community shoulddecide whether the standard should be:

• Option 1: elements-based, detailed andspecific to a single language.

• Option 2: elements-based, less detailedand not language-specific.

• Option 3: solely outcomes-based.

• Option 4: tiered, including elements asmandatory and outcomes in a second tier.

• Option 5: integrated, mandating bothelements and outcomes.

2.6 Setting up a working committee

The options and recommendations put for-ward in this chapter need to be thoroughlydebated throughout the international plainlanguage community to enable sounddecision-making. There is so much to workthrough that the International Plain Lan-guage Working Group or some similar bodywill need to establish a dedicated workingcommittee to foster constructive debate andmove toward more concrete decisions.

The early focus of this work will need to beon the intended use for a standard and itsform and content. Once the form of a plainlanguage standard is agreed, a committee orworking group should then be charged withexploring ways to maintain the integrity ofthe standard across countries and users. The


committee will need to devise, test, and agreeon moderation processes.

Any agreed plain language standard willthen need revising, particularly in the earlyyears of use. We will need to decide on an ef-fective process.

Recommendation

6. We recommend that the plain languagecommunity form a committee, perhapswithin the International Plain LanguageWorking Group, to progress this work by:

• gathering the views of the internationalcommunity about who will use thestandard, how it will be used, and whatform it should take

• producing a first carefully researchedstandard for plain language

• setting up a revision process

• working with other committees or bodiescharged with related tasks in this optionspaper.

© Lynda Harris, [email protected]

© Susan Kleimann, [email protected]

© Christine Mowat, [email protected]

Lynda Harris is founder anddirector of Write Limited(formerly Write GroupLimited), New Zealand’sleading plain English business-writing company.Wellington-based Write hasbeen well established in theprofessional services market forclose to 20 years and has abroad client base of public andprivate sector clients.

Lynda also established the WriteMark, New Zealand’sdocument quality mark, and is the founder of NewZealand’s annual plain English awards. Lynda is thecountry representative for Clarity and a member of theInternational Plain Language Working Group.

Dr Susan Kleimann, President of the KleimannCommunication Group, is an internationally recognisedplain language expert with over 30 years of experienceproviding thoughtful technicalcommunication expertise tonumerous organisations. DrKleimann has ledtransformative research, design,and organisational processprojects related to public policydocuments with a highvisibility and far-reachingimpact for multiple governmentagencies.

She is a frequent speaker on the wide range of plainlanguage issues, and has presented her views toaudiences in the Netherlands, New Zealand, Canada,Australia and Mexico. Dr Kleimann previously served asthe Director of the Document Design Center at theAmerican Institutes of Research and as the first ExecutiveDirector of the Center for Plain Language inWashington, DC.

Before starting WordsmithAssociates in 1980, ChristineMowat taught English toadults for 13 years in England,Kenya, and Canada. Since itsinception, Wordsmith hasconducted plain-languagewriting workshops for over30,000 participants withinstructors in Edmonton,Calgary, Regina, andVancouver.

Christine has authored over 30 articles, co-edited atextbook, Native Peoples in Canadian Literature, anddesigned and instructed eight Wordsmith programs,including Improving Legal Writing. Christine iscurrently preparing a revised edition of A PlainLanguage Handbook for Legal Writers, originallypublished by Carswell in 1999.

Christine was on the Executive Committee of PLAIN forseven years and served as President. She chaired theToronto and Amsterdam PLAIN conferences in 2002 and2007. PLAIN recognised her work with an award at its2009 conference in Sydney.


Helena Englund HjalmarssonESS, Sweden

Karine NicolayKatholieke Hogeschool Kempen, Belgium

Overview

This chapter sets out some issues and optionsfor future training of plain language practi-tioners. Its recommendations will help theplain language community to make some in-formed decisions about the next steps.

In researching this section of the options pa-per, we found ourselves continuallyconfronting gaps in the existing knowledgeabout:

• what constitutes plain language practice

• what a practitioner needs to know and do

• what training already exists

• what future training should be developed.

A great deal of research is needed to answerthese questions before we can develop theright training options. As this will take timeand money to achieve, we have looked at thefunding sources available, and suggest thatwe seek support such as through the Euro-pean Commission’s Lifelong Learningscheme, which offers financial support forcurriculum development.

Recommendations

We recommend as a first step conductinga survey of plain language practitionersworldwide to decide on the knowledge,skills and competence that a plain lan-guage practitioner needs so that this canbe reflected in any future plain languagetraining program.

We recommend using the EuropeanQualifications Framework as a model to

define the learning outcomes of a plainlanguage training program.

We recommend seeking European fund-ing to support further research andcurriculum development through the Eu-ropean Commission’s Lifelong Learningscheme. This could fund a foundationalproject with a number of university part-ners and the plain language communitythrough an organisation based in Europe.

3.1 What do plain language practitionersdo?

Before we can decide what training plainlanguage practitioners need, we have to mapwhat they actually do.

We conducted an informal survey and con-firmed that plain language practice is verydiverse, with practitioners working in a widerange of sectors and tasks. Some mainlyteach writing to non-communications profes-sionals, some work primarily as editors ordocument designers, and others work tochange an organisation’s overall communica-tions culture. While some work in-house aspart of the communications staff of their em-ployer, many operate their own consultancyservice, often as a single-person business.

Following are probably the most commonservices that plain language practitionersprovide:

• writing of clear, concise, well-organisedtexts

• substantive editing or plain languagerewriting

• copy or style editing

• proofreading documents

• assessing individual documents

• evaluating organisational communications

3. Training for plain language


• implementing organisation-wide plainlanguage programs

• developing in-house standards forcommunications

• training professionals in how to write plainlanguage

• training plain language trainers

• producing in-house style guides, writingguidelines or procedures

• developing templates and other documentsystems

• developing document design

• desktop publishing

• user testing of documents with theirintended audience.

This list isn’t complete, as there has neverbeen a comprehensive survey of plain lan-guage practitioners to confirm the range ofwork that they do. This is the first problemthat the plain language community mustconfront as it assesses its training require-ments.

3.2 What does a plain languagepractitioner need to know and do?

While mapping what practitioners do is afirst step, to develop effective training pro-grams we then need to assess the knowledge,skills and competencies needed to do thosetasks.

Knowledge

Knowledge = the body of facts, principles,theories and practices related to plainlanguage.

Our informal survey found that plain lan-guage practitioners need some or all of thefollowing knowledge, depending on theirspecific area of practice:

• general linguistics

• the structure and features of their nationallanguage

• text genres in different contexts anddisciplines

• user and task analysis

• editing theory and practice

• grammar, punctuation, style and wordusage

• readability and document assessment

• adult education

• the production process for online andpaper documents

• document design

• user testing

• current national language policies andissues.

As with the list of services above, this list isa starting point for discussion rather thana final account of the knowledge thatpractitioners take into their work.

Skills

Skills = the ability to apply knowledge,complete tasks and solve problems.

To perform their different roles, plain lan-guage practitioners should be able to:

• assess texts

• write copy

• edit or rewrite texts

• develop documentation such as style guides

• design document layouts

• develop communications strategies fororganisations

• work with subject matter experts

• work with graphic artists

• develop and conduct training

• design and conduct user testing.

Competence

Competence = the proven ability to useknowledge, skills and personal, social andtechnical abilities in work or studysituations and in professional andpersonal development

For professionals to be effective, they mustmove beyond acquiring knowledge and de-veloping skills to demonstrating they canapply that knowledge and skill. Our quicksurvey was not sufficient to map these com-petencies. Yet having a thoroughunderstanding of what competencies plainlanguage requires will be essential to developthe right kind of training.


We recommend the first step of a survey ofplain language practitioners worldwide tomake an inventory of the knowledge, skillsand competence a plain language practitio-ner needs. This can then be reflected in afuture plain language training program.

3.3 What plain language training alreadyexists?

The next gap to fill in our knowledge is whattraining already exists for plain languagepractitioners. Here, we discovered that theeducational backgrounds of practitioners isas diverse as the services they provide, andthat very few countries in the world yet offerextensive and dedicated training in plain lan-guage, particularly at a university level.

University training

There are only a few courses dedicated toplain language at any university throughoutthe world. The most comprehensive is cur-rently in Sweden.

Sweden

Stockholm University and Umeå Universityhave a three-year university diploma inSwedish Language Consultancy (http://tiny.cc/96q9w). It is a very thorough educa-tion and students are equipped with skills todiscuss linguistic issues at a theoretical level.The current list of courses and seminars are:

• Introductory courses in language,communication and society

• Text linguistics and discourse analysis

• The grammatical structure of the Swedishlanguage

• Language technology and digital texts

• Sociolinguistics and pragmatics

• Rhetoric

• Printing and graphic design

• Pedagogy

• The changing world of languages—Language history

• Psycholinguistics

• Swedish as a second language (Stockholm)

• Translation

• English grammar and vocabulary (Umeå)

• Writing courses

• Professional practice—internship

• Linguistics theories in the 19th and 20thcentury

• Independent essay project.

However, if a training program should pre-pare students for the roles discussed above,this education may overqualify them. TheSwedish degree also has the common aca-demic problem of being too theoretical toprepare students for immediate practice inthe workplace.

Växjö University also has a new shorter coursein plain language skills of one semester. Theprerequisite is a minimum two semesters ofSwedish linguistics, but according to thecourse’s superintendent, the applicants arefar more qualified, with masters degrees orother postgraduate qualifications.

The Swedish Association for Plain LanguageConsultants (ESS) briefly evaluated theshorter course graduates and found that theyare as well qualified as those with a diplomafrom Stockholm University in:

• proofreading

• writing clear, concise, straight-forwardtexts

• editing documents

• setting goals for clear communication

• producing in-house style guides andwriting guidelines.

But it also found the shorter course graduatesare not as well prepared for teaching profes-sionals how to write. It is too early to drawany conclusions, but it seems that thisshorter-course approach has better preparedstudents practically for the actual work.

Other countries

While we have not conducted a comprehen-sive survey, there is almost nothing as yet inother countries to match the Swedish train-ing program. More often, where plainlanguage is taught at university, it is part of adegree in communications, editing or infor-mation design. In some cases, such as inMexico, it is one subject as part of a law de-gree at one university. But where it has apresence in a university, it is generally onecomponent of a broader qualification rather


than a specific plain language qualificationaimed at preparing graduates to work asplain language practitioners.

One recent exception in the English-speakingworld is the interest expressed by SimonFraser University in Canada, which meansthat university-level education for plain lan-guage practitioners may be possible within acouple of years in that country.

However, growing interest in plain language,and the passing of laws such as the PlainWriting Act in the United States, mean thatthere may be growing demand for qualifica-tions in the field. Partnerships withrecognised tertiary institutions are certainlyone of the major options for the plain lan-guage community to pursue.

Government training

The second sector that is providing trainingin plain language is government. In Portugal,for example, a new Diploma in ‘Simplifica-tion of Administrative Language’ is beingestablished at the National Institute for PublicAdministration (INA). This six-month courseemerged from a partnership between INAand Português Claro, and aims to train pub-lic servants to develop plain languageinitiatives in their agencies.

In the United States, the first major govern-ment training program was at the VeteransBenefits Administration. Starting in the early1990s, VBA embarked on a program to train8000 employees in what they call ‘reader-focused writing’. The National Institutes ofHealth offers an on-line training module,required for many of its employees but avail-able free to anyone (http://plainlanguage.nih.gov/CBTs/PlainLanguage/login.asp).PLAIN, a group of federal language employ-ees advocating for plain language, hasoffered a free half-day training session inprinciples of plain language since about 1997,and has trained about 10,000 employeesacross the government. All of these programsfocus on techniques of plain language forwriters, with some minimal attention to de-sign concerns.

There are other examples of government-sector training in other countries, but theyare similar to those in the United States andPortugal in that they generally focus on thepractical needs of a public sector and do not

integrate with the university sector. At timesthey do not lead to a recognised qualification.

Private providers

Outside the government and university sec-tors, private providers are currently fillingsome gaps in plain language training.

In Australia, the Plain English Foundationhas trained almost 10,000 professionals,mostly in the government sector, throughshort courses of two or three days. InCanada, organisations such as Wordsmithhave trained thousands more. In the UnitedKingdom, the Plain Language Commissionalso runs training for both public and privatesectors. At most, these providers offer a cer-tificate for participation rather than formallyassessed qualifications.

Only one private organisation so far seems tooffer a qualification in plain language. ThePlain English Campaign in the United King-dom has a training program that leads to aplain English diploma. According to theCampaign’s website, the course lasts one yearand concludes with a qualification in writingin plain English.

The Plain English Campaign’s training raisespotential problems surrounding a privateeducator providing accreditation unless theyhave formal recognition from their nationaleducation systems to do so. Ideally, the edu-cator ought to have some kind of officialendorsement as a form of quality control.

We have asked both the Plain English Cam-paign and a former student to evaluate theskills and the course, but the results are yet tocome. This will also help us to evaluate thepotential for private bodies to provide train-ing for plain language practitioners.

3.4 What training model could plainlanguage adopt?

Even our brief survey reveals that there isconsiderable work to be done to assess the ac-tual work and the training needs of plainlanguage practitioners before we can developthe best curriculum and devise how to mountit.

To work through this process and to makeplain language training as international aspossible, we could consider using the Euro-pean Qualifications Framework for Lifelong


Learning (EQF) (http://ec.europa.eu/education/lifelong-learning-policy/doc44_en.htm).

All EU countries take part in the Bolognaprocess, which helps to coordinate highereducation in the EU member states. The EQFwas created to make different countries’higher education and degrees more under-standable and comparable across Europe. Ituses eight reference levels of qualifications,from ‘basic’ to ‘advanced’. The eight levelsare described through their ‘learning out-comes’, which state the knowledge, skills andcompetence a student has after a specificlearning process.

The EQF defines:

• ‘knowledge’ as the body of facts, principles,theories and practices related to a field ofwork or study

• ‘skills’ as the ability to apply knowledgeand use know-how to complete tasks andsolve problems

• ‘competence’ as the proven ability to useknowledge, skills and personal, social and/or methodological abilities, in work orstudy situations and in professional andpersonal development.

Using an established framework such as thiswould accelerate the development of plainlanguage training by providing a solid theo-retical and practical basis that is alreadyrecognised throughout Europe. This wouldalso make it easier to attract university part-nerships to offer courses in plain language.

Of course, the disadvantage is that the frame-work would not be as recognised innon-European countries, although it is likelythat any courses developed through thisframework can be adapted to other contexts.In the meantime, they will gain recognitionthroughout Europe and across many of themajor languages.

We recommend using the EQF as a model todefine learning outcomes of a future plainlanguage training program. The startingpoint of this process should be:

• the existing knowledge about what plainlanguage practitioners do

• the knowledge outlined for students inexisting plain language programs

• the skills identified by experienced plainlanguage practitioners.

3.5 How could we finance a trainingcurriculum?

There is a second major reason for proceed-ing with the EQF to establish the best trainingfor plain language: finance. Setting up aplain language training program requiresmoney. Adopting the EQF also opens up thepossibility of European funding.

In March 2010, Karine Nicolay and JanDekelver from K.H.Kempen (Belgium/Flanders) and Sandra Fisher-Martins fromPortuguês Claro (Portugal) visited StockholmUniversity, the Swedish Language Council(Språkrådet), Språkkonsult and the associa-tion for Swedish certified languageconsultants (ESS). This visit ended with theintention of applying for funding for plainlanguage curriculum development from theEuropean Erasmus Lifelong Learning pro-gram (LLP) (http://ec.europa.eu/education/lifelong-learning-programme/doc78_en.htm).

Partners

The organisations participating in this projectinclude:

• K.H. Kempen as the required coordinatinghigher education institution (Belgium)

• Stockholm University (Sweden)

• Sigmund Freud University (Austria)

• Instituto Superior de Educação e Ciências(Portugal)

• Institute of Estonian Language (Estonia)

• Simon Fraser University (Canada)

• Association for Swedish Certified LanguageConsultants (Sweden)

• International Plain Language WorkingGroup (international).

The course

The partners have opted to work on a one-year course on clear communication thateach partner can adapt to its own local needsand possibilities. This may be a postgraduatecourse, a masters course, a course given by aprivate or public body, and so on.

The course will be open to students with abachelor or masters degree (and in excep-tional circumstances also for students with‘externally earned competences’). It will ad-dress language, design, policy, usability and


project management, with a special focus onplain communication in European institutions.

After the course, students will receive a Euro-pean diploma in plain language and design.In the long run, this may also open a path tointernational professional certification.

Project method

The project could proceed by adopting thefollowing approach.

Before the application:

• analyse the need for a plain languagetraining program

• review the state-of-the-art in plainlanguage best practice

During the project:

• define the learning outcomes (knowledge,skills, competencies)

• establish admissions criteria, processes andtests

• develop teaching, working and deliverymethods

• develop learning materials

• develop ICT and blended learning

• prepare for the start of the course

• work on promotion, website, conferences,and so on

• study and establish recognition and awardssystem (following ECTS)

• provide quality control

• provide project management.

Working with plain language experts

The application will benefit considerably ifwe can demonstrate that the university part-ners are working with the recognisedindustry experts in the field—many of whomhave impeccable academic credentials—todevelop a ground-breaking curriculum forplain language. Without this, there is a dan-ger that the training will be weightedtowards theory more than practice and willnot take sufficient account of real-worldwork situations.

One way to bring the plain language commu-nity into this process would be to form somekind of organisation, such as an institutionthat represents major plain language bodies

internationally: PLAIN, Clarity and the Cen-ter for Plain Language.

To be a formal part of a European-fundedproject, the plain language community wouldneed to create a European-based legal entity.The major plain language organisationscould, for example, become the members ofthat entity for the purposes of securing fund-ing and providing a conduit between theuniversity sector and industry practitioners.The final chapter of this paper discussesoptions for the institutional structure in moredetail.

Including some kind of organisation repre-senting practitioners as part of the projectwould provide some quality control and aconduit for practitioners with expertise inparticular areas to contribute to the curricu-lum development without having to do itvoluntarily.

Above all, an LLP application is worth pur-suing because it provides an opportunity tosecure the resources needed to conduct theresearch and develop plain language courses.Without this funding, it is likely that trainingwill continue on a more ad hoc basis, or bedeveloped by universities without the inputthat industry practitioners should provide.

The application will be for €400,000, of whichat most €300,000 can be funded by the EU.This means there will be a €100,000 co-financing from the partners. The deadlinefor the application is 26 February 2011. Ifapproved, a two-year project can probablystart in September 2011, with the first coursesstarting in September 2013.

The project was the subject of a panel discus-sion at the Clarity Conference in October2010 in Lisbon and (if approved) there couldbe workshops on the training program at fu-ture plain language conferences in the nexttwo years.

3.6 How could we extend the training toother countries?

While an EU-funded project is a practicalway of developing plain language training atuniversity level, the next challenge will behow to extend the training to countries out-side Europe.

Here, there is a further advantage of workingwithin the EU in that the course will alreadybe developed for major languages and might


easily be adapted for other countries. The ad-dition of Simon Fraser University in Canadaas a partner will also help the project to assessits extension outside Europe.

Where universities in other countries do nottake on the training, students from thosecountries may be able to attend plain lan-guage courses through a European universityand perhaps seek supplementary training intheir national language in their own country.

Alternatively, a country may be able to estab-lish a professional association such as existsin Sweden to offer the training, or to workwith universities who plan to do so. Theemerging international institutional structurefor plain language could support individualcountries in establishing an association or infacilitating training.

High quality training resulting in a recognisedqualification will be essential if we are toachieve more uniform standards for plainlanguage practice and realise the benefitsthat it can bring to the community. This muststart with filling the gaps in our knowledgeand finding the finance to develop modelcourses for universities to offer. While the EUseems to offer the most immediate opportuni-ties for doing so, there is no reason thiscannot eventually extend throughout theworld.

© Helena Englund [email protected]

© Karine [email protected]

Helena EnglundHjalmarsson has a Bachelordegree in Swedish LanguageConsultancy and a universitydiploma in Human ResourcesAdministration for Pedagogues.She is the spokesperson ininternational issues for TheAssociation of SwedishLanguage Consultants. She is apartner and CEO at the PlainLanguage agencySpråkkonsulterna and works as a Plain Languageconsultant specialising in legible language and writingfor the web. She is the co-author of Klarspråk på nätet(Plain Language on the Web) and Tillgängligawebbplatser i praktiken (Accessible Websites inPractice), two books found in editorial offices acrossSweden.

Karine Nicolay is a lecturer on communication and softskills, and plain language project manager withKatholieke Hogeschool Kempen,a university college associatedwith Leuven University. Shehas been in the plain languagefield since the early nineties. Atfirst she was editor-in-chief ofthe Flemish easy-to-readnewspaper Wablieft. She thenestablished her universitycollege’s plain languagetraining and rewriting services(www.klaartje.eu). Together with her colleagues, sheparticipates in and coordinates several European-fundedprojects. Karine gets training and rewriting assignmentsfrom both private companies and public authorities. In2010, she became a member of the International PlainLanguage Working Group and is leading the clearcommunication training project.

Contributing to the journal

Clarity often focuses on a specific theme (like conferences or drafting or standards), butwe also publish articles on a variety of other plain language topics. Please submit yourarticles to the editor in chief for consideration.

Would you like to be a guest editor? Our guest editors gather articles, work with theauthors, make layout decisions, and edit and proofread a single issue. If you would liketo guest edit an issue of the Clarity journal, send an email to the editor in chief.

Finally, if you have ideas about improving the journal, the editor would like to hear fromyou, as well. Our editor in chief is Professor Julie Clement, with the Thomas M. CooleyLaw School. Email her at [email protected].


Dr Karen SchriverKSA Communication Design & Research, United States

Frances GordonSimplified, South Africa

Overview

Over the past few decades, plain languageadvocates and practitioners have become in-creasingly articulate about the principles ofplain language. It is now widely recognisedthat there are benefits to grounding plain lan-guage action in research. In fact, failing to doso poses a risk of the field losing credibility.This chapter explores the state of plain lan-guage research and outlines various optionsfor its future direction.

We characterise plain language researchbroadly by outlining the contributions of for-mal and informal research. We assume thatboth types of research are useful for plainlanguage advocates and practitioners.

Currently, there is limited research conductedspecifically with a plain language agenda inmind. However, there is a large corpus ofstudies from other disciplines that are rel-evant to plain language. This complex andmultidisciplinary research base suffers fromvarious problems, namely:

• being scattered and fragmented

• being biased to contexts of ‘English-only’and developed countries

• lacking specificity and applicability.

Largely because of these problems, we arenot yet in a position to identify the researchgaps.

Recommendations

We suggest that we gather and synthesiseresearch relevant to plain language,pointing to various options for doing so.Then we make this research available anduseful to those who can benefit from it.Plain language practitioners and advo-cates will then be better positioned toidentify those research questions that stillneed to be answered.

This, in turn, will allow the field to charta course to promote new research. Twofundamental issues for promoting re-search are:

• finding ways to fund studies that areuseful

• finding researchers interested in carryingout formal and informal studies.

We suggest that plain language advocatesand practitioners investigate ways to col-laborate with the academy. We concludethat a cooperative international bodycould play an important role in ground-ing plain language in research. Thiswould serve to raise the status of the fieldand the credibility of its arguments.

4.1 Research and its usefulness

In thinking about research that can help toguide and support plain language activities,it is useful to distinguish formal from infor-mal research.

Formal research

By ‘formal research’, we are referring to stud-ies that explore an issue or phenomenonusing either quantitative or qualitative meth-ods in a systematic way that could bereplicated by another researcher.

4. Grounding plain language in research


Formal research is distinguished by the carethe researcher takes in making sure the studyfollows accepted professional standards forexcellence in quantitative or qualitative in-quiry in the domain. As such, readers expectto see a clear explication of what was done,how it was done, how many people were in-volved, how it was analysed, and theimplications. How researchers explain theirgoals, methods, participant selection, alongwith the rigour they bring to the analysis andinterpretation, are important benchmarks fora good formal study.

Readers’ judgements of what constitutes‘good evidence ‘ in formal research are con-text-dependent, depending on their field.Because many in the field of plain languagecarry out our activities in technically and rhe-torically sophisticated communities (such aslaw, medicine, engineering, finance, govern-ment), we need to appreciate the kinds ofresearch that experts in those communitiesfind persuasive. Similarly, a person trained inthe humanities reading an article about writ-ing research would bring different criteria tobear in judging quality than a person trainedin human factors.

Key questions for most readers of research in-clude, ‘what have I learned?’, ‘howgeneralisable is the work?’ and ‘am I per-suaded by the work?’ If we want to useresearch to support our best case for plainlanguage, we must recognise the kinds of evi-dence our listeners will likely embrace.

Informal research

By ‘informal research’ we are referring tostudies that are much less stringent in howthey are set up. Informal studies are generallysmaller in scope (such as case studies) andmore focused on getting data quickly, with-out the constraint of explaining how thingswere done. Researchers typically carry outinformal studies opportunistically—seizing

on any opportunity to collect data that willbe meaningful to bear on the question theywant to answer. Most usability studies andassessments of documents and websites areinformal.

The goal of such studies is not to write aboutthe findings or to prove anything general, butto put the data to use, such as in revising adocument or a set of menu options. Ofcourse, informal does not mean unplanned orsloppy. Often, informal studies are used togenerate ideas and hypotheses for more for-mal studies.

Combining formal and informal research

Both formal and informal studies are usefulfor plain language advocates. Formal studiesallow us to make educated guesses aboutwhat works and why. They allow us to makeinferences about what may happen in similarcontexts. Informal studies can give us rapidinformation about, for example, what’s goodor bad about a text or a website. They allowus to make quick judgements about problemsof communication and serve as good startingpoints for a more rigorous inquiry.

Reflective practitioners in our field are eagerto consume both formal and informal studiesbecause they recognise the value of building aresearch basis for what they do. They wantto understand how research can make theirefforts in plain language more effective andcredible.

4.2 The nature of plain language research

Stakeholders and uses for research

Ideally, our research agenda would be in-formed by the needs of the stakeholders forempirical work on plain language, with a fo-cus on their likely uses for research. Thefollowing tables present some of the stake-holder groups and uses for plain languageresearch.

Uses for plain language research

Recognise the social benefits of plain language

Measure the commercial benefits of plain language

Examine the feasibility of plain language programs insmall and large organisations

Stakeholder groups

Advocates, practitioners

Academics, students

Citizens, readers, users

Consultants, trainers


The limited research base within plainlanguage

On the one hand, there is a limited corpus offormal or informal studies that were designedwith a plain language agenda in mind. In ad-dition, there are few literature reviews of theformal research that contributes to the field.For some examples, see the debate over theresearch on readability (Redish & Selzer,1985; Schriver, 2001; Dubay, 2004). See alsoFelker and his colleagues (1981), who reviewthe early research on document design, andthe US Department of Health (1984), whichreviews the early research on testing healthcommunications.

There are reviews of the informal researchthat can also help us to understand plain lan-guage. For some examples, see Kimble (1996)and Schriver (1993), who examine a numberof case studies that illustrate the financialbenefits of plain language.

A wider research base from relateddisciplines

On the other hand, there is a great deal ofexisting research from other fields that canprovide empirical evidence for decision mak-ing as we create content designed to be plain.There is general consensus in our communitythat the research we need to draw on mustcome from many fields—ranging from thearts, humanities, social sciences andcommunications-related areas, to business,law and finance.

Indeed, the study of plain language andinformation design is inherently interdiscipli-

nary and draws productively from a varietyof fields and subfields, as the table overleafshows.

The usefulness of formal and informalresearch from other disciplines

Current research from formal studies of lan-guage, reading, psycholinguistics, graphics,and typography, for example, can contributesignificantly to our understanding of both thenature of plain language and the visual/ver-bal text features that tend to be plain for mostpeople.

The existing body of informal studies can alsobe very helpful to plain language advocatesand practitioners. For example, usabilitystudies can help us to gain perspective onhow people engage with and use paper oronline texts. These types of studies can helpus choose among strategies for implementingplain language revisions and can help us iso-late the characteristics of particular genresthat make them plain for given populationsof readers.

Research from fields such as those listedabove can help us to understand plain lan-guage and test our assumptions about whatworks (see Felker et al., 1981, and Schriver,1989, 1997 for the multidisciplinary effortsthat helped define document design). KarenSchriver is also working on a synthesis of thecurrent empirical research on how writing,design, and typography influence howpeople read print and online texts (Schriver,in preparation).

Uses for plain language research

Assess the impact of plain language laws in promotingplain language and empowering citizens

Calculate the cost/benefit and return on investment ofplain language programs in business and government

Identify the visual and verbal features that tend to maketexts difficult and create confusion

Characterise the visual and verbal features that tend tomake texts easy to comprehend and use

Understand how good readers and poor readers engagewith texts and graphics

Inform a global a standard for plain language

Stakeholder groups

Gatekeepers, decisionmakers

Law-makers, regulators,legal drafters

Managers, finance officers

Journalists, bloggers,podcasters

Writers, translators, webdesigners, corporatecommunicators


Limits of what we know

Existing research will not answer all ourquestions about how to make written com-munications plain. There are manyunexplored and underexplored open ques-tions. But existing research can give usinsight into the evidence (or lack of it) for re-lying on our current repertoire of plainlanguage principles, techniques, tips, guide-lines, and best practices (Schriver, Cheek andMercer, 2010). With a deeper knowledge ofthe available formal research, practitionerswill be better positioned to move beyond in-tuition and to make claims based on data.

4.3 Issues with the existing research base

Some problems with the existing research

Scattered and fragmented

The main problem with the existing researchis that it is scattered across many fields over a

wide variety of publications—includingbooks, journal articles, technical reports,websites, and conference proceedings. More-over, because the standards for researchexcellence differ from field to field, and evenfrom publication type to publication type, it isdifficult to integrate what is known about atopic and feel confident about the inferencesone can draw across studies.

Put differently, it is hard to make reliable andvalid comparisons across studies when thestudies are driven by radically different as-sumptions and goals—and when few studiesare replicated.

English-only

Another quite different problem with the ex-isting research is that it has been conductedmainly in English with native English speak-ers. Basic and applied research needs to beconducted with populations across manylanguages and cultures. It may be that some

Arts, humanities andsocial sciences

Anthropology

Applied art

Cultural studies

Decision making

Graphic design

Discourse analysis

Instructional design

Gerontology studies

Applied linguistics

Philosophy and ethics

Cognitive and social psy-chology

Human factors

Psycholinguistics

Reading comprehension

Rhetoric & semiotics

Semantics

Sociolinguistics

Sociology

Typography

Writing & literacies

Communications

Advertising & branding

Content management

Content strategy

Customer service

Document design

Experience design

Information architecture

Information graphics

Interface design

Multi-media & animation

Marketing

Second language acquisi-tion

Translation

Localisation

Publishing and editing

User assistance

Usability

Web design

Writing

Writing for the web

Business, law and finance

Administration

Business strategy

Customer experience

Employee relations

Finance

Financial services

Information technology

Innovation

Legal writing

Public policy


issues of plain language are unique to par-ticular countries and/or particularlanguages.

Bias toward studying developed countries

Most of the studies that impinge on plain lan-guage have been conducted studyingpopulations in the United States, Canada,Australia or Europe. Countries in whichplain language is needed the most may havelittle research base to draw on, largely be-cause they do not have a history of fundedresearch in the social sciences. This puts de-veloping countries at a distinct disadvantage,especially throughout Africa, and illustrates alarge gap in current research.

Lack of specificity and applicability

A problem with some existing research is thatthe authors are vague in describing the workand narrow in their selection of participants.In addition, the participants are dispropor-tionately college-aged ‘good’ readers carryingout reading tasks because they were told to,rather than because they needed to.

As a consequence, we find few naturalisticstudies in the existing literature. For example,there are few studies of average readers, poorreaders, and non-readers engaging withdocuments for authentic purposes. Today’sresearchers more readily recognise problemsof bias and are working toward changing theparadigm of studying ‘convenience samples’.

4.4 Synthesising existing research

One of the results of the problems outlinedabove is that we cannot yet identify the gapsin the research. Synthesising the existing re-search would help us to identify importantresearch questions and the gaps betweenwhat we know and what we want to findout.

We do not yet have a synthesis of the existingresearch that integrates the findings relatedto issues that concern plain language practi-tioners and advocates. This is not a newproblem. There has not been a systematic re-view of the interdisciplinary literature thatcontributes to our field in over a decade. Infact, one could argue that it has never beendone with an eye toward providing ideas forplain language advocates and practitioners.That said, there have been reviews of docu-ment design and web design that can serveas useful starting points (Felker et al, 1981;

Koyani et al., 2004; Schriver, 1989, 1997;Redish, 2007).

Part of our future agenda should be to framethe crucial issues we seek answers to. Eventhough the task is hard (and a bit frustrat-ing), plain language practitioners andadvocates need to conduct original reviews ofthe interdisciplinary literature. We shouldtake advantage of the many excellent studiesthat already exist. If we do not, we run therisk of reinventing the wheel.

To integrate the existing research from theperspective of a domain expert (for example,psycholinguists working on the cognition ofsentences), we could take one or more of thefollowing options:

Option 1: identify researchers to conductliterature reviews

This option would involve the followingsteps:

1. Identify researchers (or researchorganisations) whose work is relevantto our concerns.

2. Fund those researchers to carry out aliterature review of their area(s), withan eye toward generating evidence-based guidelines.

3. Take that work (literature review,guidelines, and bibliography) and turnit into an easily searchable database forplain language advocates andpractitioners around the world.

It is important to recognise that not just any‘literature review’ will do. We need a reviewthat is broad and deep, but also explicit inimplications. To ensure the usability of the lit-erature reviews we fund, our Request forProposal needs to specify our requirements,such as a literature review, general findings,and evidence-based guidelines/principles.We should also set our goals on eventuallyfunding proposals to study particular issues,such as what causes people to stop reading.

Option 2: wait for research to be publishedand then build on it

Alternatively, we could wait for relevant re-search to be published, and then build onthat work ourselves. Although possible, thiswould be a difficult process. Clearly, we facea formidable challenge in integrating the ex-isting research relevant to plain language.


4.5 Making research accessible andpromoting new research

Making research accessible

We can make research more accessible bymaking it available and useful.

To make research more available, we can, forexample:

• offer literature reviews available fordownload on the Web

• make research easily searchable—contenttagging with keywords and synonyms

• enhance forums—get people who are not‘doing’ plain language to discuss it

• create Wiki formats—consider new ways todraw ‘everyday’ people to research results

• set up conferences and networks (virtualand real)—host the best speakers on plainlanguage to spread the word and writeabout plain language

• get into print publications—as often as wecan and in as diverse publications as wecan

• create newsletters, which could be global orlocal.

We can make research more useful to advo-cates and practitioners, many of whom donot have a background in research, by in-cluding ideas, case studies andrecommendations on how practitioners andadvocates can use the research in their work.

We would need a good website and a dedi-cated team prepared to make the researchusable for the variety of plain language con-stituents, and a team to test the site to see ifour intuitions about accessibility are on themark.

By drawing on the talents of the Plain Lan-guage Association InterNational (PLAIN)forum, the Center for Plain Language, andmembers of Clarity, we could pool our collec-tive talents to become a one-stop shop forplain language advocates and practitioners.

Accessible research would pave the way toidentifying research questions. Once wearchive the research that has been done, wecould identify the questions that practitionersstill need answers to and consider ways topromote new research.

Funding new research

We can also promote more good research byfunding it. Funding is a serious question thatneeds international collaboration. But onething we know is that if we could fund ourown studies, we would have answers tomany of the questions that concern us.

We can also try to promote new research bycollaborating with members of the academy.Although not many academics have been in-terested in carrying out plain languageresearch up to this point, it seems likely thatas government agencies put more plain lan-guage laws into effect, interest will percolate,especially if funding for plain languageprojects becomes available. We can be cau-tiously optimistic.

We could inspire interest in research by put-ting together a framework on how to sponsorstudents or offer scholarships or internshipsin return for doing plain language research.

4.6 Role of an international institution

An international organisation could play arole in putting in place many of the initiativesreferred to in this chapter. In a general sense,it could help educate its members about howempirical observation could be useful ineveryday acts of plain language. It could playa central role for many of the initiatives wehave described.

In synthesising existing research, an interna-tional institution could provide a cohesivevision of the plain language research that ex-ists. It could also offer a framework forconsidering the ‘big picture’ of research.When the institution is firmly established, itcould identify ‘needed research’, recommendresearch topics, make suggestions for replica-tion studies, and sponsor original studies.

In making research more accessible, an inter-national institution could serve as a clearinghouse for plain language issues from aroundthe globe, such as through an online databaseof plain language publications on researchand practice. It could also offer bite-size re-search capsules to release to the media.

In promoting more research, an internationalinstitution could initiate and organise fund-ing programs.

Overall, an international plain language insti-tution could be the catalyst for changing the


shape of the field around the globe. Bygrounding its activity in research, it couldboth raise the status of the field and the cred-ibility of its arguments.

© Dr Karen [email protected]

© Frances [email protected]

References

DuBay, W.H. (2004). The principles of read-ability. Costa Mesa, CA: Impact information.Available from http://www.impact-information.com/.

Kimble, J. (1996). Writing for dollars. TheScribes Journal of Legal Writing. 1996–1997.

Koyani, S. J., Bailey, R.W., Nall, J.R. (2004).Research-based web design & usability guide-lines. NJ: Computer Psychology.

Felker, D. B., Pickering, F., Charrow, V. R.,Holland, M., & Redish, J. C. (1981). Guidelinesfor document designers. Washington, DC:American Institutes for Research.

Redish, J. (2007). Letting go of the words: Writ-ing web content that works. San Francisco, CA:Morgan Kaufmann.

Redish, J. C., & Selzer, J. (1985). The place ofreadability formulas in technical communica-tion. Technical Communication, 32(4), 46–52.

Schriver, K. A. (1989). Document design from1980 to 1989: Challenges that remain. Techni-cal Communication, 36(4), 316–331.

Schriver, K. A. (1993). Quality in documentdesign: Issues and controversies. TechnicalCommunication, 40(2), 239–257.

Schriver, K. A. (1997). Dynamics in documentdesign: Creating texts for readers. New York:John Wiley & Sons.

Schriver, K. A. (2001). Readability formulas:What’s the use? ACM Journal of ComputerDocumentation, 24(3), 138-140.

Schriver, K. A. (in preparation). Readingonline: A review of research on the impact oftechnology, writing, graphics, and readercharacteristics (Technical Report No. 1). Pitts-burgh, PA: KSA Communication Design &Research.

Schriver, K. A., Cheek, A., & Mercer, M.(2010). The research basis for plain language

techniques: Implications for establishing stan-dards. Clarity 63, May 2010.

US Department of Health. (1984). Pretestingin health communications: Methods, examples,and resources for improving health messages andmaterials (NIH Publication No. 84-1493).Washington, DC: US Department of Healthand Human Services, Public Health Service,National Institutes of Health, National Can-cer Institute.

Karen Schriver, Ph.D. isPresident of KSACommunication Design andResearch, a consultancy locatedin Pittsburgh, Pennsylvania(USA). She is a former professorof rhetoric and informationdesign at Carnegie MellonUniversity, where she co-directed the graduate programsin professional writing. Herbook, Dynamics in Document Design: Creating Textsfor Readers—now in its 9th printing—is regarded as anessential work in the field. Karen redesigns websites,instruction guides, educational materials, technicalreports, marketing collateral, and forms. Winner of tennational awards for information design, her clientsinclude Apple, IBM, Mitsubishi, ATT, Sprint, Hoffman-LaRoche, Fujitsu, Microsoft, and Sony.

Frances Gordon’s careerstarted far from the corporateenvironment, travelling ruralSouth Africa to research andwrite educational materials foradult learning. This sparked aninterest in clear, simplecommunications, which shebegan to apply in the corporateworld in 1995.

Her career includes tenures atLogical, a division of Datatec,as a communications strategist, and at London-basedSiegel & Gale as a senior content strategist. Frances hasworked on documents and websites for a wide range ofblue-chip international companies.

Frances has written for various UK and South Africanpublications and has spoken at conferences about therelationship between brand strategy, technology andsimplification. In 2005, Frances and Candice Burtfounded Simplified, a training and consultancy firmspecialising in plain language.


Carlos ValdovinosSimplificado Punto, Mexico

Overview

The dictionary defines ‘to advocate’ as mean-ing ‘to argue for’ or, more broadly, ‘tosupport’ a cause. To what extent can andshould a plain language movement or profes-sion do either of these? Certainly we doplenty of arguing for plain language. Thequestion is what plain language institutionsshould do to support the cause.

The working group considers that advocacyremains vital if we are to strengthen plainlanguage throughout the world. To realisethe potential that plain language offers to thepublic, to the economy and to democracy,countries already engaged in plain languageneed to share their success with others thataspire to do so.

Every country that has introduced plain lan-guage benefited from early institutionalsupport. In Sweden, this came through theMinistry of Justice. In the United Kingdom,the Plain English Campaign and the PlainLanguage Commission had a significant im-pact. In the United States, there was theDocument Design Center and, more recently,the Center for Plain Language. In Australia,the Law Reform Commission of Victoria—since replaced by the Victorian Law ReformCommission—completed ground-breakingwork.

What has worked at a national level is evenmore important at an international level. Ithas already proven invaluable for countrieswithout plain language initiatives to learnfrom those where plain language has alreadybeen introduced. This chapter will use Mexicoas an example to illustrate how much easierit is to persuade government or business atsenior levels when we can show how othercountries have accepted the case for change.

International advocacy could continue on thesame basis as it does now, through ad hoc co-operation between national organisationsand international bodies such as PLAIN andClarity. But maximising advocacy may re-quire a more structured approach in thefuture, which suggests scope for more formalinstitutional arrangements. This could beachieved through a loose federation of exist-ing organisations or a formal newinternational institution.

Recommendation

The working group supports advocacybecoming a core part of any internationalplain language institution that mightemerge following this options paper. Theadvocacy of any institution should be fo-cused internationally, working closelywith national bodies to provide the fol-lowing kinds of support:

• engaging in direct lobbying ofgovernments and industry

• providing information and resources fornational organisations

• hosting or supporting internationalevents and exchanges

• developing testimonies and case studiesfor use at a national level.

5.1 The need for international advocacy

As absurd as it may seem, language clarity isnot a trivial matter in modern life. Over thecenturies, humanity and—by no coinci-dence—governments have developed aceremonial and complex language, at timesto distinguish those in upper levels of the so-cial hierarchy. Today in the 21st century,governments and private institutions are stillinfluenced by this communications para-digm.

5. Advocating plain language


The natural consequences of this present ahigh cost to society: for governments, loss ofconfidence in their public management; forcompanies, the loss of business. Yet transpar-ency and accountability are central pillars ofboth democracy and economic efficiency.

Defending plain language is not a romanticidea or a passing fad, but a permanent cul-tural and paradigm shift. It means strugglingagainst scepticism, resistance to change, andpersuading politicians who prefer monumen-tal projects with high political value to thesmall details that distinguish a civilised andeducated society.

International experience has shown there isno exact formula for implementing a plainlanguage initiative. There have been initia-tives begun by organisations working outsidegovernment and business. In other cases,governments adopted internal models eithertop-down or bottom-up.

Similarly, plain language is often linked to so-cial groups who may require very differentstrategies, including:

• societies with different indigenous groupsor multilingual groups

• societies with ethnic groups with differentbeliefs and customs

• government bureaucracies at national, stateand local levels

• legal systems

• technical and scientific fields.

For years, the most industrialised countries,along with a number of developing countries,have been discussing administrativemodernisation as a means of strengtheningdemocracy. The challenges each countryfaces are varied, but they have three things incommon:

• improving citizens’ confidence ingovernment, business, and the law

• improving services and quality of life

• improving efficiency and reducing publicdebt, and reducing costs to business.

Each country sets out its own priorities, andeach also seeks the best tools and practicesfor its needs. In doing so, they are aware theyare not alone—the great majority are affili-ated with international organisations thatencourage the exchange of best practice. This

is the case whether it be reducing bureau-cracy, optimising budgets, restructuring orsimplifying procedures and processes.

Countries such as Sweden, Australia, theUnited Kingdom, the United States andCanada have, for around 30 years, been ex-ploring and developing a range of strategiesapplied to clear communications in a numberof fields. They have succeeded in creatingawareness in the public sector and, in manycases, in the management of private institu-tions. They have produced concrete examplesof clarity in language and demonstrated itssocial benefits.

These advances mean that conditions existfor setting out a road map and internationalstandards for language clarity initiatives to beadopted by new countries, improved on bycountries already working on the issue, andperfected by the countries that have madethe most advances.

For example, the support Mexico has re-ceived from these countries and internationalorganisations meant that in 2004, the initia-tive known as ‘Lenguaje Ciudadano’ (CitizenLanguage) was implemented successfully.Undoubtedly, the enthusiasm of Sweden, theUnited States, Australia, the United Kingdomand, in particular, the Spanish Academy, wasnot only a source of inspiration, but a short-cut to advancing a couple of decadesresearch into, and learning about, best prac-tice.

But the struggle for plain language is by nomeans over, even in countries that have moreadvanced programs. As the recent lobbyingfor plain language laws at the federal level inthe United States shows, advocacy can stillproduce major initiatives that will furtherstrengthen the reform of public language.

5.2 Scope for advocacy by aninternational institution

While it is easy to observe the past successesand the potential for plain language advo-cacy, the next step is to consider the best wayto promote plain language internationally inthe future.

We argue that strengthening plain languagearound the globe will require further interna-tional cooperative action, and that suggestsdeveloping a more conscious institutionalstructure. The final section of this chapter


discusses the institutional options for coordi-nated international action. The rest of thischapter will refer only to the role of an ‘inter-national institution’ in advocating for plainlanguage.

While we feel that some kind of institutionalstructure is necessary to maximise the impactof advocacy, the plain language communitywill need to decide whether that structure is:

• a loose but co-ordinated network

• a federation of existing bodies

• an entirely new organisation.

Advocacy should be one of the main consid-erations in selecting the right institutionalmodel. Advocacy should then become a corepart of whatever institution emerges.

International advocacy

Whatever institutional vehicle emerges, thefocus of its advocacy should be directed atinternational rather than national action,although it will inevitably need to workclosely with national bodies.

Administrative changes in both public andprivate sectors tend to be traumatic and arefrequently radical. In Mexico, for example,every six years there is a change of presidentand state governors, and every three years achange of local government, which unfortu-nately leads to a struggle for continuity inpublic policies. To combat this, formulas for asmooth transition and continuity must befound.

An international institution could play a stra-tegic role in this context to defend plainlanguage:

• as a decisive factor in building democracy

• as a central pillar of transparency andaccountability that works againstcorruption

• as helping combat the manipulativepractices of authorities

• as helping reduce arbitrariness byauthorities and bolstering trust amongcitizens

• as reinforcing citizens’ right to understandthe workings of government, allowing themto better fulfil commitments andresponsibilities

• as reducing costs of transactions forinstitutions and citizens.

An international institution would also:

• remind new administrative regimes of plainlanguage initiatives

• support societies in defending the use ofplain, simple and direct language ininstitutional and individual relationships

• organise international events such asconferences to bolster internationalexchange of best practice and innovation

• encourage organisation and integration ofmore countries to support and extend plainlanguage worldwide.

A new international institution should be-come an international lobbyist, pushing forplain language in bodies such as the UN, orsetting up international standards or conven-tions. It may also organise or support directactivities such as international conferences asa means of promoting international action forplain language.

Support for national organisations

However, any new international institutionshould not compete with or seek to supplantorganisations working within a particularnational sphere. So there would be no pushto compete with the advocacy of the Centerfor Plain Language (United States) or PlainEnglish Power (New Zealand). Here, theinternational organisation would play asupporting role, putting its name behind thenational efforts in a particular country, but beguided by that country.

The most useful thing that the internationalbody could do is to encourage and supportnational plain language organisations to be-come established in as many countries aspossible. It could provide a network, modelsand perhaps resources for budding plain lan-guage efforts. In this way, it would be meetingits international charter to advocate by ex-tending plain language, but without havingto run these things itself. It could achieve thiswhether as a formally constituted organisationor a more informal network.

As the institutional foundation of plain lan-guage develops throughout the world, the newinternational institution can also act as a cata-lyst to bring all national organisations togetherfor joint action.


5.3 Areas of activity for internationaladvocacy

Direct lobbying

When a country identifies the need tostrengthen clarity in its communications, atleast three sets of interested parties must beidentified to lobby for plain language:

1. Those whose responsibility is to improveadministrative practices in a country.

2. Sceptics or conservatives who arereluctant to accept paradigm changeunder the pretext that technical orprofessional language cannot beinterfered with.

3. Champions of change whoseenthusiasm can transform languageuse, and who see clarity as a means ofachieving better results in managinginstitutions.

Advocates can help these groups to identifyspecific objectives, benefits to be achieved,quick advances, impacts and contributions.

Support for lobbying by other individualsand organisations

Apart from direct involvement in lobbyingfor clear communication in a particular coun-try, an international plain language institutioncould also support key individuals and localorganisations who are already lobbying. Attimes, the authority of an international bodywill be influential. At other times, change willrequire opinion leaders who enjoy prestigeand recognition in their own society andinstitutions.

Extraordinary as it may seem, while peopleare generally aware of the lack of clarity withwhich governments and corporations dealwith society, it is like the hum generated by abroken air conditioning unit—you can hear itall the time but no-one complains because itforms part of ambient noise. People adaptand learn how to get along with it withoutpaying it any attention. It is only when theunit breaks altogether or is turned off thatpeople notice the difference and realise howannoying the sound really is.

The same thing happens with vague, confus-ing language: as long as no-one concernsthemselves with it, society adapts. But whenan initiative on language clarity emerges, theneed to implement it is quickly realised. In

the case of Mexico, when the need for clarityin language was identified, defenders andsupporters of the initiative appeared, alongwith institutions prepared to join the cause.

International advocacy then becomes impor-tant to provide models for action inindividual countries, such as:

• academic involvement to validate thebenefits of plain language. This may rangefrom constructive criticism to thedevelopment of academic programs to trainexperts (especially linguists, and lawyers).

• the creation of not-for-profit citizens’networks that, due to the quality andprestige of their members, are respectedand recognised by their society. In the caseof Mexico, the Plain Language Network ismade up of academics, experts ininstitutional communication, opinionformers, Transparencia Mexicana,representatives of business forums andgovernment employees in positions totransform institutional methods.

• the establishment of acknowledgementprograms and incentives for those whopromote the use of clarity in language.Examples include the Plain Swedish Crystalin Sweden, and the Citizen LanguageRecognition in Mexico, among others.

Providing information and resources topromote plain language

There is no doubt that the political will ex-pressed by a government or a company mustbe seen in the budget, structure and the pay-roll. There may well be an interest in plainlanguage, but the first problem faced by en-thusiasts is to justify and explain the budgetsand resources required to begin a plain lan-guage initiative. So one of the first jobs ofinternational advocates is to help developingcountries to identify the need and to offerthem persuasive information and guidance.

An international plain language institutioncould help guide other countries in identify-ing international funding sources to supportan emerging plain language program. In thecase of Mexico, American USAID, the BritishCouncil and the British Embassy, the SwedishEmbassy and the Spanish Agency for Inter-national Cooperation for Development(AECID) were critical in implementing theCitizen Language initiative. Without the in-formation and resources provided by such


organisations, an isolated initiative is lesslikely to reach its potential.

A new institution could also play a role in:

• promoting the exchange of experts’experiences in the field

• helping develop materials, methods andcontent

• training and educating experts in the fieldwho can duplicate experiences within agovernment or institution

• sponsoring and promoting study trips andinternational exchanges that allow fullimmersion in the subject

• facilitating consultancy and peer reviewingbetween member countries

• encouraging countries to join andparticipate in international organisationsand committees working for languageclarity to maintain up-to-date knowledge,exchange new methodologies andinnovative ideas

• establishing standards that recogniseadvances in citizens’ language

• creating internet resources, references andnews about national and international events.

Organising and hosting activities thatpromote plain language

As the saying goes, ‘prophets have no honourin their own country’, which is why externalinvolvement with a government can helpbring about a solid foundation for plain lan-guage. Following are some of the activitiesthat an international institution could sup-port in helping a country establish a plainlanguage initiative.

Launching an initiative

The launch of plain language program in acountry could bring together people poten-tially interested in plain language, focusingon those in decision-making positions withthe power to persuade others in offices andofficial bodies. This could begin with an openinvitation to:

• civil servants from the country’s variousministries and bodies

• representatives of the academy

• communications professionals

• other opinion leaders.

The highest levels of government should beinvited to these meetings, along with:

• the authorities whose job it is to approvethe project

• ambassadors and legal representatives fromthe home countries of the internationalspeakers and experts

• the media, including newspapers, TV andradio and expert speakers in the field.

An initiative of this kind would highlight theissue in a particular country, generate somesupport, build contacts and identify areas ofopportunity.

If there is any lesson to be drawn from thedevelopment of plain language in other coun-tries, it is that a handful of people using themedia effectively can have an enormous in-fluence. A strong example would be thesymbolic shredding of government forms inLondon in 1979, which boosted the influenceof the Plain English Campaign and directgovernment action in simplifying a range offorms. This also generated a taste in the me-dia for plain language as a regular story, andin turn a public awareness of the need forchange.

An international plain language institutioncould help a growing range of countries tomount similar start-up initiatives.

Focused events

After helping to launch a plain language pro-gram, an international institution could alsohelp with lobbying of specific groups of alliesor potential opponents. The outcomes maynot be those expected, nor the optimum ones,but they do represent the start of an aware-ness campaign for those who question theparadigm shift.

Roundtable discussions with experts

Participants in roundtable events shouldcomprise a range of specialists in linguistics,public policy, experts in different areas andinternational consultants, as well as represen-tatives from the private sector in a position tolobby the government.

This kind of meeting could help develop prin-ciples, standards and tools to help integrateand apply plain language in government andother contexts.


Workshops

Workshops would be aimed at people whoare directly involved in producing documentsand communications. Here, internationalorganisations can assist by providing materi-als and teaching methods, whether by director distance learning.

In Mexico’s case, the first workshop involvedexperts from the United States, the UnitedKingdom and Spain, as well as Mexican lead-ers in communications. These workshops didnot seek to produce experts in plain lan-guage, but introduced the field to awaken aninterest in the subject and encourage partici-pants to put it into practice.

Five years on, the workshops proved an ef-fective way of identifying agents for changeand reaching the sceptics. But workshopshave a limited capacity, making this a slowmethod. Over this period, the Mexican gov-ernment was able to train around 5,000 civilservants from a total of some 65,000 careeremployees.

Distance-learning programs, on the otherhand, have an astonishing capacity for pro-motion and growth. For example, theMexican Treasury Department (SAT), incharge of fiscal matters and tax collection,managed to train over 33,000 employeesthrough this method.

Conferences and talks

Positioning and defending an initiative likeplain language means arranging regular con-ferences and talks for multidisciplinarygroups and organisations. These forums de-mand convincing content based on facts andresults obtained from experience in othercountries to highlight the benefits of imple-menting plain language.

Testimony of the benefits and results

There is no better way to persuade the insti-tutions and employees of any government orprivate company than testimonies, facts andresults. This is because those who narratetheir own experiences have passed throughthe most complex stages in implementingclear language policy, and as such are thebest representatives to voice plain languageinitiatives.

Effective testimonies generate credibility andovercome the scepticism and fear of changing

the paradigms of communication. This is es-pecially true if these testimonies come fromadministrative institutions or bodies that usu-ally follow rigid, inaccessible or evenincomprehensible policies, such as those incharge of tax collection, attorneys in chargeof litigation, or any body in charge of techni-cal operations.

Facts and experiences are a key agent forchange, since they broaden the vision ofthose in charge of setting up and implement-ing a plain language initiative. Facts make upa varied mosaic of possible applications andgoals that such a strategy can attain. Suchfacts range from rethinking a letter for masspublic distribution, a customs form, a bag-gage reclaim form, a regulation, a legalsentence, or even a law or internationaltreaty.

Measuring results demonstrates the beforeand after transformation of communication.Every sustainable public policy must be basedon measurement of its results, which may bequantitative in economic terms or qualitativein the public perception of the quality of aservice.

In Mexico, for example, the institution incharge of tax collection undertook a pilotproject in one area to rewrite their letters totaxpayers who lag behind with their contri-butions, using a simple and clear citizenlanguage. The results showed an increase incollection of 18 per cent and a reduction inclarifications from 33 per cent to just threeper cent. An international plain language in-stitution would have a vital role in collectingthis information and using it to advocate forbroader change.

© Carlos [email protected]

Carlos Valdovinos waspreviously General Director ofRegulatory Simplification atthe Ministry of PublicAdministration for the FederalGovernment of Mexico. In thisposition, he was in charge ofimproving federal publicadministration throughsimplifying internalregulations and processes,promoting plain language and strengthening theevaluation of public policies. In the international field,Carlos has been a Mexican delegate for the OECD and in2009 joined the World Bank.


Sandra Fisher-MartinsPortuguês Claro, Portugal

Overview

This document sets out some options for cer-tification of plain language practitioners. Itwill help the plain language community tomake some informed decisions about anynext steps in what is one of the more conten-tious areas that this paper discusses.

Certification is arguably an important steptowards professionalising plain language,and has benefits for practitioners, employersand the public. For practitioners, certificationcan raise professional status and differentiatethem from related disciplines. For employers,it’s a guarantee that the practitioner has theskills needed to perform a job. For the public,it’s a protection and an assurance of profes-sional conduct, accountability and quality ofservice. Of these three, the benefits for thepublic are the most important justification forcertification.

But certification is also a difficult step thatneeds to be managed carefully. Deciding onwhether to certify plain language practitio-ners and how to go about doing it is along-term project. Sound foundations mustbe laid before we make any progress: a defi-nition and standards for plain language, aclearer understanding of what plain lan-guage practitioners do and the skills andknowledge required to do it.

We also need to look closely at the risks in-volved. The most obvious is the damage tothe profession’s credibility if certified profes-sionals fail to provide the expected level ofservice. There might also be disputes betweenpractitioners and the certifying agency. Theseare only some of the questions to answer aswe move onto the next stage.

To address these issues, our initial view isthat any certification scheme should be vol-untary and focus not on what trainingpeople have, but on their competence andtheir ability to do a defined job. And weshould learn from the experience of other as-sociations and disciplines that have dealtwith the risks. The plain language commu-nity could then develop an appropriatestandard with expert help from a standard-developing organisation so it could apply topractitioners in any country.

Certification may take more than a decade toachieve. This would place it among the last ofthe options discussed in this paper. However,to achieve even this timeframe would meanstarting now.

Recommendation

We recommend exploring the possibilityof certifying plain language practitionersagainst a standard for professionalknowledge, skills and practice. The firststep should be to form a ProfessionalStandards Committee to oversee the re-search and the practical steps involved.

6.1 Clarifying the terms ‘certification’ and‘accreditation’

To begin, we need to clarify what we meanby two terms that are commonly confused:certification and accreditation.

Certification attests that a product, service,system or professional complies with a stan-dard. For professionals, it’s a way of showingclients or potential employers that their expe-rience and skills have been assessed by anindependent, unbiased authority that consid-ered them competent in their field.Certification can be compulsory, such as forregulated professions like doctors and airlinepilots, or voluntary.

6. Certifying plain language


Accreditation recognises an organisation’scompetence to assess whether a person, aproduct, a service or a system complies witha standard. Accreditation is normally volun-tary and issued by accreditation bodies suchas the Standards Council of Canada, Portu-guese Institute for Accreditation, SwedishBoard for Accreditation and Conformity As-sessment, and the United KingdomAccreditation Service.

In this chapter of the options paper, we’ll fo-cus on the certification of plain languageprofessionals. We’ll also briefly discuss thepossibility of a certifying body or bodies be-coming formally accredited.

6.2 The benefits and risks of certification

The benefits

Three broad groups will potentially benefitfrom certification:

• practitioners

• employers

• the public.

For practitioners, certification can raise pro-fessional status and differentiate them fromcompetitors in closely related fields. For em-ployers, it’s a guarantee that the practitionerhas the skills needed to perform a job. For thepublic, it’s a protection and an assurance ofprofessional conduct, accountability andquality of service.

Certification is often seen as one of a number ofnecessary steps towards professionalisation.In Sweden, the only country with a three-yearuniversity diploma in language consultancy,most government agencies will only hire cer-tified professionals. They do so in the beliefthat a certified professional maximises thequality of the work they need and the ben-efits that this delivers to the public.

Some plain languagepractitioners arguethat certificationshould not be pursuedas an end in itself, butas a means to improvethe services that prac-titioners and employersprovide to the public.

The working group agrees with this view.Certification is worth pursuing ultimately be-cause of its potential to improve the quality ofpublic communications by recognising andstrengthening the skills of the practitionersthat work to improve them.

The pressure of legislation

In recent years, successful advocacy for plainlanguage has led to a number of laws thatare beginning to mandate plain language fordocuments that have a social impact, such asin credit, finance and government. The con-sumer protection laws in South Africa andthe Plain Writing Act in the United States arethe best recent examples.

Inevitably, when a state mandates particularactions through statute, there follow ques-tions of how to measure those actions. Thisgenerates a market for services that can as-sess and attest to compliance. While the lawscontain definitions and some guidelines, in-evitably organisations seeking to comply willwant to turn to professional help. Already inSouth Africa, the laws have generated newcommunications practitioners promotingthemselves in this emergent market.

The risk to plain language is that not all ofthe practitioners entering this growing mar-ket will be fully proficient. And without someform of certification to assess their abilities,they may conduct sub-standard work in thename of plain language that damages thecredibility of all plain language practitioners.This would also reduce the benefits plain lan-guage could bring to the public because ofthe new laws.

A major benefit of certification would there-fore be to maximise the impact of plainlanguage laws by providing a structured andcredible process for assessing the practitio-ners who would help organisations toimplement them.

Accreditation body Certification body Plain-languageprofessional


The risks

While the benefits of certification appear ob-vious, it also opens up, as one member put it,‘a can of worms’. The risks it poses include:

• potential and costly disputes

• low or uneven rates of participation

• litigation over poor work by a certifiedpractitioner

• consumption of limited resources.

Disputes among practitioners

One of the major concerns is that practitio-ners might disagree with the criteria used ordispute any judgement made about theirown proficiency. This risks opening up thefield to legal processes that it can ill afford.Public coverage of any such dispute coulddamage the field overall and achieve the op-posite of the intended outcomes.

Some practitioners may object in principle tohaving to ‘prove themselves’ and refuse toparticipate in a certification scheme, whichwould render it pointless. Senior practitio-ners, for example, may feel they have asufficiently established reputation not to needcertification. More junior practitioners, on theother hand, could see certification as a pathtoward professional recognition and be eagerto participate. The initial balance of certifiedpractitioners may therefore be skewed to-ward the middle ranks of the discipline.

To minimise these objections and potentialoutcomes, the plain language communitymust be involved from the beginning in defin-ing the certification criteria and process. Thisalso means that senior practitioners shouldoversee the process through establishedorganisations such as PLAIN and throughany new institutional structure they agree to.We will need to consult regularly and moveahead cautiously.

Since compulsory certification could meetwith serious resistance (and would requirestate regulation) it would be preferable if anycertification were voluntary. Whatever insti-tutional structure administers it, it wouldwork to build practitioners’ acceptance andparticipation rather than force them tocomply.

Potential for litigation

The next general risk is the damage to the na-scent profession’s credibility if certifiedpractitioners fail to provide the expected levelof service. This may also open up the certify-ing body to claims that an organisation hadrelied on a practitioner’s certification andought to receive compensation from thatbody because a service delivered was belowstandard.

Many professional associations have dealtwith this by putting in place processes fordealing with complaints against certified pro-fessionals who break their standards ofconduct, along with mechanisms such asprofessional indemnity insurance. So whilethese are all barriers to certification, the expe-rience of other professions shows they aresurmountable.

Prioritising our resources

Another concern expressed about certifica-tion is the energy and resources that it maytake. Some argue that for the benefits that itbrings, we can ill afford the time of the lim-ited number of practitioners around theworld who would need to set up a scheme.They argue that our resources are better di-rected at more readily achievable measures,such as establishing a definition, furtheringadvocacy and developing research and train-ing.

This is understandable, but it implies that thekey question is when, rather than if, weachieve certification. Certification may takesome time, but the working group recom-mends it is worth pursuing to achieve thebenefits it offers for our public language. Weshould proceed cautiously as our resourcespermit.

6.3 What could we certify and how?

Certifying people or organisations

The first question to tackle is what exactlywould we certify? Certifying people is the ob-vious option if the goal is professionalisation.However, we could also consider certifyingservices. Instead of assuring that a person hasthe necessary skills to perform a certain func-tion, certification would assure that a personor more likely a company can provide a cer-tain service—that they have developed a


process or method that allows them to re-spond to a need in a way that produces theexpected results.

For companies, it might be preferable to certifytheir services and not just the people whoprovide them. This would allow for continuitywhen staff leave and show they’ve developedprocesses that don’t depend on individuals.Practitioners, even if self-employed, will almostcertainly favour professional certification, asservice certification tends to be a complexprocess with costs that might exceed its ben-efits.

We think both forms of certification could beconsidered, as they are complementary. Forinstance, a company could certify its servicesand employ certified professionals. However,we realise that certifying services would re-quire a lot more administration and greaterefforts to monitor. We suggest focusing ourinitial efforts on creating a framework forcertifying professionals and later, dependingon demand, think about service certification.

Methods for certifying practitioners

We will examine two ways of certifying plainlanguage practitioners:

• certification following a training program

• certification against an industry standard.

The Swedish case: automatic certificationfollowing a training program

At the moment, the only certified plain lan-guage practitioners are the Swedish languageconsultants. Swedish certification is a threestep process:

• complex entrance test (only six per cent ofthe applicants pass the test)

• three years of training

• a final exam, which gives you a diploma.

The diploma is the certificate and the univer-sity provides the certification.

End-of-course certification vs professionalcertification

This ‘automatic certification’ following anend-of-course, curriculum-based examinationdiffers from a professional certification. Bypassing a final exam, the candidates showthey’ve achieved the learning objectives. In aprofessional certification process, in whichcandidates are assessed against a formal

standard, the question is not ‘what do theyknow?’, but rather ‘can they do the job?’.

Professional certification assessments arebased on a professional role delineation or jobanalysis. To get a certificate, candidates mustprove that they have the knowledge andskills required to perform a specific task.

In addition, professional certification assess-ments should meet rigorous psychometriccriteria, which means they should be a validand reliable way to measure the candidate’scompetence.

Standard-based certification: assessingpractitioners against a professional standard

Plain language professionals have differentbackgrounds in education and experience buthave common skills that allow them to per-form certain functions. Assessing themagainst a standard for professional knowl-edge, skills and practice is probably thefairest and least controversial road to certifi-cation.

6.4 Standard-based certification

Developing a professional standard

The first step towards a standard-based certi-fication will be developing a professionalcertification standard. The first question thisraises is whether this should be an interna-tional or national standard.

Some countries have been using plain lan-guage for decades while others are juststarting to embrace it, so it is natural that jobdescriptions vary significantly. National stan-dards could focus on local needs andrecognise knowledge or skills that are valu-able only locally, but would be difficult toimplement. Each country would have to de-velop its criteria for certification and createan agency to assess professionals. This wouldbe expensive and not viable for those coun-tries with just a few practitioners.

An international standard could be devel-oped by a central certifying body and appliedlocally by certifying agencies or directly bythe central body. This certification could betransferable, allowing the practitioner towork in other countries. We recommend that,in the same way we might define standardsfor plain language that apply internationally,our standard for certifying plain language


professionals should apply to practitioners inany country.

The second question is whether to have a singlestandard or a range of specialist standards.Plain language practitioners have differentroles. Some are trainers, some are writers, andsome are editors. Should the certificationstandard reflect these specialisations or focuson common skills?

Due to the costs of developing standards, werecommend starting with a general certificationand later, depending on demand, developingstandards to certify plain language trainers,writers, editors, legal drafters, and so on.

Finally, there is the question of who will de-velop the standard. A professional certificationstandard could be developed with input from:

• the plain language community with inputfrom all stakeholders

• the International Organization forStandardization (ISO)

• a standard-developing organisation (SDO)

• the university sector.

Developing a standard is a complex andlengthy process. We believe the plain lan-guage community must be involved butshould seek help from experts.

The ISO is one of the first options that cometo mind. However, the ISO focuses on inter-national standards with wide applicationand its process may be unnecessarily complexand expensive for our purposes.

The other option would be to use the servicesof an accredited SDO. Funding permitting,this would be our recommendation, as theirexpertise would ensure that all parties areheard and the final result is as consensualand applicable as possible. However, wemust make sure the SDO helps us developthe standard in a consulting capacity andthat the standard remains the property of theappropriate plain language organisation.

Another question would be the potential roleof universities in developing the standard.Clearly, any standard should align with fu-ture training developed at universities forplain language practitioners. The options pa-per chapter on training discusses a project fordeveloping a curriculum in Europe for plainlanguage at university level. If we proceedwith standard-based certification, the

completion of a university course would notautomatically give practitioners certification.But it makes sense that the professional stan-dard meshes closely with any curriculadeveloped for plain language practitioners.

Assessing practitioners against thisstandard

With the standard created, we enter a secondphase with a new set of questions.

Firstly, how will practitioners be assessed?The assessment must be fair, credible, reliableand valid. It will have to measure what it issupposed to measure—the ability to performa specific job. Given the complexity and im-portance of the task, we recommend gettingprofessional help to design the assessmentmethod and instruments.

Next, who will assess practitioners? Shouldthey be assessed centrally or locally? The ex-isting international association, PLAIN, orany new organisation such as an institute orfederation, could assess and certify practitio-ners.

The other option would be to have nationalcertifying agencies that would localise theinternational certification criteria and testpractitioners in their own language. At themoment, only Sweden has an agency—theAssociation of Swedish Language Consult-ants—that is involved in certification.

We recommend a mixed solution: practitio-ners should be assessed locally in countriesthat already have a certifying agency (suchas Sweden) or have a sufficient number ofpractitioners to warrant setting up an agency.The certification would be issued centrally,such as by PLAIN or by a new body. Whenlocal agencies are not available, practitionerscould be assessed by the central certificationbody.

Finally, who will be assessed? We feel thatcertification should be voluntary. Practitio-ners should be free to seek it, if they feel theycould benefit from it, or to leave it.

We expect the certification process to causesome controversy. On the one hand, there isthe ‘experienced practitioners’ vs ‘newcom-ers’ issue. Should we consider differentcertification processes for newcomers and ex-perts? Should an experienced practitioner beable to get certified by presenting a portfolioand a newcomer by sitting an exam?


We believe so, as long as the different formsof assessing them are psychometricallyequivalent and none of the candidates is putat disadvantage for choosing one over theother. On the other hand, we have those thatreceive formal training and, through an end-of-course examination, become ‘certified’. Atthe moment, that’s only happening in Swe-den, but with more training programs in thepipeline, more people could find themselvesin this situation.

We’re aware that suggesting already-certifiedprofessionals go through a certification pro-cess would be unwise. For such cases, werecommend a transition phase, in which theirexisting certification would be automaticallyrecognised by the certifying body. After thetransition phase, any courses claiming totrain certified plain language professionalswould have to include a certification processrecognised by the international certifyingbody.

Finally, there is the question of whether tohave a one-off certification or a renewal sys-tem. Professional certification is usuallytime-limited. By getting re-certified every fewyears, practitioners show their commitmentto lifelong learning and continuing educa-tion.

Becoming an accredited certification body

In a third phase, the certifying body or bodies(if the certification is done locally) might seekaccreditation as a way of showing its compe-tence in assessing a professional’s compliancewith the standard. Accreditation, which isvoluntary but costly and time-consuming,would be granted by the nationalaccreditation body of the country where thecertifying body is based.

There are two main reasons for a certificationorganisation to seek accreditation:

• to differentiate itself from its competitors

• to respond to a market demand forcertifications issued by accreditedorganisations.

None of these apply to our situation. First,our professional community is too small toattract other organisations offering compet-ing certification schemes. Second, the marketfor plain language services is not at the pointwhere customers expect professionals to havean accredited certification.

Additionally, it is unclear whether a nationalaccreditation would be valid in other coun-tries. This means that a centralised accreditedcertification body could certify practitionersinternationally, but these certifications mightnot be considered accredited in their coun-tries. If so, the investment in accreditationwould only benefit local professionals.

In our opinion, accreditation is not a priority.

6.5 What are similar professions doing?

To help us assess the options for certification,we looked at the certifications offered bythree professional associations: the Editors’Association of Canada (EAC), the Institutefor Professional Editors (IPEd) in Australia,and the Society for Technical Communication(STC). The EAC’s and IPEd’s certification isstandard-based, while STC is still developingits process. We also looked at the investiga-tion of the Usability Professionals Associationinto certification.

Editors’ associations: test-based certification

The Editors’ Association of Canada offersfour certification tests based on its Profes-sional Editorial Standards, which set out theskills and knowledge editors need to do theirjob. Candidates can earn certifications inproofreading, copy editing, structural editing,and stylistic editing. By completing the fourtests, they become a Certified ProfessionalEditor.

According to the EAC, ‘there are no formalrequirements for taking the certification tests.However, the EAC Certification SteeringCommittee recommends candidates have atleast five years of editing experience beforetaking the tests and that they prepare well’.

The EAC publishes certification study guidesand a workbook with practice tests. It alsoprovides seminars to help candidates preparefor the exams.

In Australia, the state-based editors’ societieshave joined together to form a national certi-fication body called the Institute ofProfessional Editors (IPEd). This offers test-based accreditation of editors supervised byan Accreditation Board working to thebenchmark of Australian Standards for EditingPractice.


Certified editors demonstrate their profes-sional competence and understanding ofediting standards, skills and knowledge bypassing the IPEd accreditation exam. Certi-fied editors can then use the postnominal AE(Australian Editor). Their certification is validfor five years, and renewal requires AEs toprovide evidence of their continuing involve-ment in the profession and their participationin professional development.

The Australian certification scheme was theresult of 10 years of planning and consulta-tion. IPEd’s forerunner, the Council ofAustralian Societies of Editors, set up the Ac-creditation Working Group in 2001 toresearch assessment schemes. IPEd estab-lished the Accreditation Board in 2005 to acton the working group’s recommendations.The Board has held responsibility for devel-oping and implementing the scheme sincethen, and introduced the first exam in Octo-ber 2008.

Society for Technical Communication:portfolio-based certification

The STC is currently developing a certifica-tion program for technical communicators,which ‘will be based on assessing portfoliosand work artifacts, not examinations’.

According to the STC, ‘practitioners will be-come certified in six core competency areas:

• User analysis

• Document design

• Project management

• Authoring (content creation)

• Delivery

• Quality assurance.’

The certification will be valid for three years.Re-certification will involve participating ineducational and professional activities.

In the future, as it expands its ‘Body ofKnowledge’, the STC might offer an exam-based certification.

Usability Professionals Association

In 2002, the Usability Professionals Associa-tion investigated the need for a certificationprogram for usability professionals. Based onfeedback from members and other profession-als, the UPA Board of Directors decided thatit was then premature for UPA to develop a

certification program. A report on the UPAwebsite stated:

However, this work also produced astrong consensus on related initiativesthat would provide immediate value forthe profession. Among these is developinga body of knowledge to help usabilitypractitioners grow professionally andhelp others understand usability better. Abody of knowledge might include:

• a list of skills

• prerequisite knowledge

• framework of usability life-cycle practices.

This body of knowledge could then beused as the basis for a professionaldevelopment plan, curriculum and self-assessment tools. The UPA is planning tomove these initiatives forward.

This work could also provide input to anyfuture efforts to create a certificationprogram. The UPA remains open toparticipating with other non-profitorganisations in such an effort.

This supports the notion that plain languagecould proceed firstly by mapping the profes-sional knowledge, skills and practice ofpractitioners in our field.

6.6 The next step: a Professional StandardsCommittee

The many questions highlighted in this paperrequire further research. While we havemapped out some major issues and options,working through these will take some time.

We suggest putting together a ProfessionalStandards Committee to carry out this work.The Committee could further explore thepros and cons of certification, the differentmethods of certification and the implicationsof launching a certification project.

The structure of the committee will dependon the overall institutional structure thatemerges from the international workinggroup process. It could remain under the aus-pices of the working group, or perhapsbecome part of any new federated body orinstitute. Or it could be taken up by an exist-ing organisation such as PLAIN.

The pace of development will need to bejudged against the priority of completing


other work outlined in this options paper. Butsince certification will take time to achieve,we believe that the first cautious steps shouldbe taken now.

© Sandra [email protected]

Sandra Fisher-Martins runsPortuguês Claro, a trainingand consultancy firm thatintroduced plain language inPortugal and has been helpingPortuguese companies andgovernment agenciescommunicate clearly since2007.

Sandra is particularlyinterested in the use of plain language and informationdesign in public documents as a way of helping citizensmake informed choices about their health, education,welfare, and civil rights. Her clients include theGovernment, Inland Revenue, Social Security, Caixa(Portugal’s largest bank) and ZON(telecommunications).

Sandra is the Portuguese representative for Clarity. Sheis a member of the board of PLAIN and of theInternational Plain Language Working Group.

Member and other newsand eventsClarity Breakfast in London onTuesday 29 March, 8am

The next breakfast meeting will be held inthe City Marketing Suite at the Guildhall.To find it, use entrance G on the map atwww.clarity-international.net/Confer-ences/conferences.htm (thanks to Claritymember Paul Double). Please emailDaphne Perry at [email protected] to reserve a place. The subjectis ‘Plain English in a City law firm.’

The International Language and LawAssociation will be holding severalconferences this year:

May 5-8: The Letter of the Law, Athens,Greece

June 17-18: Law, Language and Litera-ture, University of Paris Ouest

30 June-2 July: Sixth Conference on LegalTranslation, Court Interpreting and Com-parative Legilinguistics in Poznan, Poland


Dr Neil JamesPlain English Foundation, Australia

Eamonn MoranDepartment of Justice, Hong Kong

Overview

Before we can decide which of the many ac-tivities in this options paper we mightpursue, we must discuss an inevitable diffi-culty: exactly who will coordinate and fundthis effort? What role will existingorganisations play and what new institu-tional structures might we need?

This chapter starts by assessing four optionsfor the institutional structure of plain lan-guage:

• Option 1: working solely through existingorganisations

• Option 2: continuing informal cooperationbetween existing organisations (the statusquo)

• Option 3: formalising an internationalfederation of existing organisations

• Option 4: establishing a new,comprehensive international plainlanguage body

At one end of this spectrum, there would beno change to current arrangements, and itwould be left to organisations such as PLAINor Clarity to decide whether they will pursuethe options in this paper. This maximises ex-isting resources and offers the path of leastresistance, but it may also restrict interna-tional coordination.

At the other end of the spectrum, we couldestablish a completely new internationalbody with a wide ranging brief to implementthe preferred options that emerge from thisprocess. Some practitioners are concernedthat the practical barriers to this approachare too formidable at this time, and that we

should explore less formal mechanisms to co-ordinate our efforts. A new organisation maycompete for valuable resources.

In between these two options are continuedinformal cooperation or a more formal fed-eration of existing bodies. The InternationalPlain Language Working Group is an ex-ample of informal cooperation, and thesimplest response would be for this to con-tinue. This would satisfy the caution of somepractitioners and provide the flexibility tostart with easier activities while we decidewhether to develop a more complex institu-tion. The chief disadvantage is that without aformal legal entity, we would not be able toapply for funding to achieve many of theoptions we might agree to, which wouldslow progress.

The next step would be to formalise interna-tional cooperation by establishing a‘federation’ as a legal entity, with memberswho are already working through the Inter-national Plain Language Working Group:PLAIN, Clarity and the Center for Plain Lan-guage. This continues internationalcooperation but adds the capacity to applyfor funding from bodies such as theEuropean Union. This would extend the re-sources available to realise the economic andpublic benefits of plain language morequickly than current resources permit.

Recommendation

We recommend working toward option 3,a formal federation of existingorganisations through a constituted bodythat has sufficient legal status to apply torelevant bodies for funding. This wouldformalise the existing arrangements of theInternational Plain Language WorkingGroup by one further step. The fallbackwould be to continue internationalcooperation by maintaining the workinggroup.

7. Strengthening plain language institutions


This chapter discusses the four institutionaloptions in more detail, along with the spheresthat any international federation should op-erate in, the legal structure and governance itmight need, and possible memberships andfunding options.

Recommendations

We recommend:

• the activities of any internationalinstitution should be focusedinternationally, working closely withnational bodies rather than replicatingtheir work.

• if the plain language community adoptsoption 3, the working group shouldcanvass international interest in estab-lishing the institution within a specificcountry. The group can then assess thebest legal status, organisational structureand name.

• an international institution under option3 should have a small organisationalmembership at the outset, but considerprovision for expanded membership inthe future.

• the institution should initially seekfunding from public and private bodiesrather than membership fees andservices, but consider broadening itsfunding sources if it expands.

7.1 What options are there for plainlanguage institutions?

Option 1: work through existingorganisations

The first option to consider is the simplest:leave existing organisations to take up the ac-tivities recommended in this paper. Thesemight include plain language organisationssuch as PLAIN or Clarity (for certification,publications and advocacy), but also univer-sities (training and research) or other relevantbodies such as the International Organizationfor Standardization (standards).

Even if existing plain language organisationsdo not respond, it is possible that others willact on the ideas discussed in this paper. Asthe previous chapter on training outlined,universities in Europe are already preparing

a project to develop a graduate curriculumfor plain language. Plain language laws inSouth Africa are already raising questionsabout how practitioners might be certified.Existing plain language organisations couldwork to influence some activities while takingothers on themselves.

The main advantages of leaving the work forexisting organisations are that we make thebest use of existing resources and do not setup a body that might compete for funds. As itrepresents the option of least change, it mayalso be more readily acceptable.

It is likely that plain language organisationswill need to be involved even where otherorganisations take on some tasks. A body likethe International Organization for Standard-ization might be persuaded to develop plainlanguage standards, but it would not havethe expertise to develop them without inputfrom plain language experts. Likewise, manyexisting universities would need the expertiseof practitioners to develop the most effectivetraining.

Even if these disparate organisations did de-cide to introduce the activities this paperrecommends, there would remain the chal-lenge of coordinating their efforts to establishconsistency. This suggests that plain languageorganisations may need to have some kind ofcoordinating influence. The chief difficultyhere is that existing plain languageorganisations may not have the resources,and in some cases the charter or interest, topursue the full range of activities discussed inthis paper.

Clarity, for example, has a focus on legal lan-guage, is not a legally constituted body andoperates through an active but voluntarycommittee. The Center for Plain Language inthe United States is a national rather than aninternational organisation, and its focus isunderstandably directed towards nationalaction and interests. The Plain Language As-sociation InterNational (PLAIN) is now alegally constituted body with a functioningboard and has the most potential to take onthe activities outlined in this options paper.But like Clarity, its resources are limited: ithas no office, no paid staff and is run by avoluntary committee.


Option 2: an informal federation

The next option would overcome this limitedcoordination by establishing informalcooperative action without forming a newlegal entity. This option in fact represents thestatus quo, given that three plain languageorganisations jointly formed the InternationalPlain Language Working Group that has pro-duced this paper.

In 2007, PLAIN, Clarity and the Center forPlain Language each nominated two mem-bers to form the working group, and agreedon a further six members to represent a rangeof countries and languages. The group firstmet at the Clarity conference in Mexico Cityin November 2008 and agreed on the topicsexplored in this paper. The memberorganisations reviewed a preliminary draft ofthe paper after the PLAIN 2009 conference inSydney, and this published version reflectstheir feedback.

The easiest way to implement option 2 wouldbe to continue with the International PlainLanguage Working Group as the means forthe plain language community to co-ordinateinternational action. Before doing so, itwould be worth considering whether theworking group model is the most suitable forthe longer term, or whether another modelmight be adopted. This may mean changingthe name of the group, writing an informalstatement of purpose, reviewing the processfor selecting members, or even confirmingparticipation as part of each organisation’sown objectives or governance structure.

Option 3: a formal federation

The next step from informal cooperationthrough a working group is to formalise themechanism by establishing a separate legalentity.

This has one clear disadvantage: cost. If aninformal structure can achieve the necessarycooperative action, establishing a new entitymay take resources from the memberorganisations, perhaps for little gain. Volun-teers run most plain language bodies, andtheir efforts may be diluted if they have toadminister and report through yet anotherset of meetings and financial statements.

Yet the argument in favour of establishing aformal body directly addresses this concern.There is one major flaw in maintaining an in-

formal body: funding. Without a legally con-stituted entity, no working group would beable to apply to most public or privatesources for grants to finance the activities thispaper explores. If we rely solely on volunteerefforts, it will take much longer to achievewhatever activities we reach consensus on.

Option 3 would therefore take the status quoone step further and incorporate the currentworking group as a formal legal entity. Wecould justify the extra administrative burdenof a formal federation body if it means secur-ing project funding that would pay plainlanguage practitioners to develop standards,or research, or training, or advocacy.

The curriculum development project dis-cussed in the training chapter is an exampleof where there is a real possibility of securingfunding—in this case up to €300,000 from aEuropean Union program. Yet internationalplain language practitioners are hampered inbecoming part of this project because theyhave no formal legal entity to apply through.

Option 4: an entirely new organisation

The final option would be to establish anentirely new body. This might take on abroad mandate to implement all of theagreed options that emerge from this process,including:

• authorising a standard definition

• establishing standards

• setting up professional certification andtraining

• pursuing research and publications

• advocating for plain language.

Such a body would replace the InternationalPlain Language Working Group and work toprofessionalise plain language. It may alsotake on activities (such as conferences andpublications) that existing organisations offerand may over time supersede them.

This approach has the advantage of creatinga single organisation with better coordinationand economies of scale. However, it would befar more costly to set up and existingorganisations are likely to see it as an unnec-essary competitor.

The alternative would be to establish a neworganisation with a more limited mandatethat complements existing organisations and


their activities. One approach, for example,might be to form a professional association,focusing on activities such as standards, certi-fication and training, leaving advocacy,conferences and publications to existingorganisations.

A new organisation with a narrower man-date would reduce the resources required,but it does not solve the problem of having torely on several organisations to achieve thefull range of recommended activities. Wewould also not have the benefits of a singlecoordinating authority to maximise the effec-tiveness of international action.

Of course, it may be possible to remain withstatus quo, move toward option 3, and assessthe desirability of option 4 over time. There isin some respects a logical evolution from oneoption to the next. But that also suggests weshould avoid jumping too far too fast. Thecurrent feedback is that option 4 would betoo ambitious as a next step.

Recommendation

We recommend working toward option 3,a formal federation of existingorganisations through a constituted bodythat has sufficient legal status to applyto relevant bodies for funding. Thisapproach would formalise the existingarrangements of the International PlainLanguage Working Group by one furtherstep. The fallback position would be tocontinue international cooperation bymaintaining the working group.

7.2 What spheres would a plain languageinstitution operate in?

This section assumes that we will continuesome kind of international cooperation, mostlikely through option 2 (the status quo) or op-tion 3 (a formal federation), but with option 4(a new organisation) a more remote possibil-ity. In any of these cases, we need to definethe spheres of interest that an institutionmight operate in. The following discussionwill refer simply to ‘an institution’ or ‘an in-ternational institution’ without prejudgingwhich option we might adopt.

International or national?

Any institution’s focus should almost cer-tainly be international. There is little point induplicating the activity of nationalorganisations. Whether a group or a federa-tion, the institution should be seen as amechanism for international cooperation anddevelopment of plain language to strengthenthe public benefits that it will bring.

Section 3.1 discussed the relationship a newinstitution would have with existing interna-tional bodies such as PLAIN and Clarity. Thenext challenge we face is how the interna-tional institution would relate to existingnational organisations. We recommend that itshould focus on supporting national plainlanguage bodies where they exist, such as theCenter for Plain Language in the UnitedStates or the Association of Swedish Lan-guage Consultants in Sweden, and notreplicate their services.

For example, the institution could advocatefor plain language in a country where theconcept is new, providing expertise and au-thority. The ‘citizens’ language’ initiative inMexico was an example of how that canwork. But once it fosters national bodies, theinternational institution could then redirectits resources to other countries. The overallgoal of its advocacy program would be tomaximise the international impact of plainlanguage.

Similarly, if the institution develops a certifi-cation program, it should do so withreciprocal arrangements with national bodiesthat already offer certification (currently onlySweden). The international institution neednot have its own system for testing profes-sional memberships in that country. Butwhere a country does not have certification,the international institution could take onthat role until a local industry association de-velops.

Standards could also benefit from a comple-mentary approach. As the earlier chapterdiscussed, there could be a high-level interna-tional standard set by an international body,which is then supported by more detailednational standards adapted to the locallanguage and context.

Where training programs would benefit frominternational action, the institution couldserve as the conduit for cooperation. The


option of applying for European Union fund-ing to develop tertiary-level plain languagecourses is a perfect example. There would begreat benefit in linking expert practitionerswith universities to develop a standard cur-riculum that can be taken up in a range ofcountries. Having a formal entity would helpus access funds to do so in a way that is notfeasible for national organisations.

Recommendation

We recommend that the activities of anyinternational institution should be fo-cused internationally, working closelywith national bodies rather than replicat-ing their work.

7.3 What would the legal structure of anew international body be?

While questions of the scope and spheres ofoperation are vital at the outset, the firstpractical hurdle would involve the logistics ofsetting up a new organisation. Here, there isuncertainty about the best way to proceed.

Jurisdiction

If we proceed with options 3 or 4, the newentity would need to be legally constituted soit can enter into contracts, operate bank ac-counts, apply for funding, and so on. Thefirst question is what country theorganisation might be constituted in andwhat laws it would operate under.

The two current international plain languageorganisations face a similar problem. ThePlain Language Association InterNational(PLAIN) is now formally constituted inCanada, which sets minimum requirementsfor Canadian participation on the Board.While Clarity has recently debated a draftconstitution, it is not yet a legal entity at all.

We looked briefly at the option of setting up‘internationally’ under the auspices of theUnited Nations under Article 71 of the UNCharter. Even if this were feasible (which isdoubtful) it would not necessarily be to ouradvantage. Doing so may mean theorganisation could not then undertake activi-ties related to those of an industryassociation.

If we are to take a further step from the sta-tus quo and form a legal entity, we face thepotentially vexed question of choosing acountry and jurisdiction to incorporate in.The organisation could operate internation-ally from there, and perhaps set upsubsidiary entities in other countries if neces-sary.

One way to proceed would be for the Inter-national Plain Language Working Group toput the concept out for expressions of interestfrom various countries and select the bestproposal we receive. Another approachwould be to choose a location to complementexisting organisations. With PLAIN consti-tuted in Canada and the Center for PlainLanguage in the United States, there may bea case for establishing the new institution inEurope to advance plain language in thatpart of the world.

Jurisdiction may also be influenced by theavailability of funding. There are strong pros-pects for financial support from theEuropean Union, but taking advantages ofthese would require a European legal entity.Establishing the institution in Europe mayalso help to reach a wider range of countriesand languages than may be the case if it wereconstituted in North America. We will needto weigh up all of these factors.

Legal structure

The second question to resolve is the appro-priate legal model of any new body. Would itbe best to make it a for-profit corporation, ora corporation limited by guarantee, or per-haps an incorporated association with anon-profit charter?

Our recommendation is to set up any newbody under a structure such as a non-profitcompany limited by guarantee (in a Com-monwealth country) or the equivalent to thatin the jurisdiction the organisation may be lo-cated in. This means that any profits couldnot be shared among members, but must bedirected to the activities of the organisation.But it also gives potential directors more pro-tection against personal liability andstrengthens the scope for revenue-generatingactivities to subsidise its public programs.

One disadvantage of this approach is that amember of a company limited by guaranteemust be a legal entity. Of the three membersproposed for the federation model under


option 3, Clarity does not yet have legal sta-tus. One way forward would be for thepresident of Clarity to be the company mem-ber as trustee for Clarity. But this requirementmay vary depending on where the institutionis established.

Organisational structure

There would certainly need to be a governingBoard for any new body, operating to alegally constituted governance framework.This may be its constitution, perhaps supple-mented by a reporting framework or policymanual. Board memberships would be volun-tary positions taken up by industrypractitioners rather than professional direc-tors.

To achieve the option 4 model, theorganisation would almost certainly needpaid professional staff. Options 2 and 3 couldproceed with a voluntary Board and only es-tablish offices or staff if it secures theresources to do so.

Name

The other potentially divisive question couldbe the name of a new body. The words ‘inter-national’ and ‘plain language’ are probably agiven to include, but the keyword that needsmost consideration is what type oforganisation it is styled. Options used bysimilar bodies include:

• institute

• association

• federation

• society

• college.

‘Association’ or ‘college’ carry connotationsof a professional association, while ‘society’and ‘institute’ have equal connotations ofeducational and public purpose. ‘Federation’may be attractive as a way of describing op-tion 3, but may become less accurate if theorganisation evolves toward option 4. ‘Fed-eration’ also has connotations related toindustrial organisations such as trade unionsrather than professional associations.

The consensus among the International PlainLanguage Working Group favours the word‘institute’, although some of the members arealso attracted to ‘federation’. Either wouldcarry the necessary connotations for its pro-

fessional status as well as its public purpose.

Of course, this issue will not arise if the plainlanguage community adopts option 2 and de-cides to retain the International PlainLanguage Working Group and its name.

Recommendation

We recommend that if the plain languagecommunity adopts option 3, the PlainLanguage Working Group should canvassinternational interest in establishing theinstitution within a specific country. Thegroup can then assess the best legalstatus, organisational structure andname.

7.4 What memberships would aninternational institution have?

The membership of an international institu-tion will depend on the option the plainlanguage community chooses.

Members of a continuing working group

If we proceed with option 2, then existingmembership arrangements could continue.This means the three member organisationswould be PLAIN, Clarity and the Center forPlain Language, each of which can nominatetwo members plus a candidate for Chair. An-other six members would be selected by thisgroup to represent a range of countries andlanguages.

The original group included three representa-tives from the United States, one fromCanada, three from Europe, two fromAustralasia, one from South Africa and onefrom Asia. A balance of genders was also afactor, with seven women and five men.

However, if we decide to proceed with thisoption, it would be worth reviewing whetherthis remains the best membership structure,particularly as the three memberorganisations are heavily biased toward theEnglish language and to North America. Wecould formalise membership fromorganisations such as the Association ofSwedish Language Consultants. Yet this maybias the membership away from countriesthat do not have established plain languageorganisations, or where relevantorganisations are commercially constituted


but have public programs, such as the PlainEnglish Campaign (UK) or the Plain EnglishFoundation (Australia).

Members of a federation body

If we pursue option 3, then we would beforced to resolve these issues and codify themembership in a formal constitution. Theeasiest approach would be to limit the mem-bership to the three organisations thatinitiated this process. PLAIN, Clarity and theCenter for Plain Language would be constitu-tional ‘shareholders’ of the new entity.

We could also consider expanding theorganisations that would become constitu-tional members (like shareholders) byestablishing a more open organisation mem-bership category. This would providemaximum flexibility and make the interna-tional institution a more representativeumbrella for cooperative relationships be-tween a growing range of national bodies.There could even be separate organisationalmembership categories for ‘for profit’ and‘not for profit’ members.

As a first step, it may be practical to restrictmembers to those that formed the Interna-tional Plain Language Working Group, butwrite its constitution with the flexibility toadd other member organisations over time.

Individuals

Individual membership of the institution willdepend on the activities it decides to take on.If a federation body does not administer stan-dards or a certification program, there maynot be the need for individual members. Theinstitution would also need to be careful thatindividual membership did not imply compe-tence in professional practice unless it hadthe structures in place to assess that.

If the institution did offer certification, itwould need to test (and re-test) the compe-tence of members and offer them professionalrecognition in return. The individual mem-bership may be tiered to reflect theexperience and seniority of each practitioner.The institution would need to develop a char-ter of ethics and have mechanisms to enforceit.

Like broader organisational membership, it isunlikely that the federation model envisagedby option 3 would introduce individual mem-bership at the outset and may in fact never

do so. But it may also be worth reflecting thepossibility in its constitution so that indi-vidual membership could be included if theorganisation moves in that direction.

Recommendation

We recommend that an international in-stitution under option 3 should have alimited organisational membership at theoutset, but consider including provisionsfor expanded membership in the future.

7.5 How would a new institution befunded?

There are three possible sources for fundingan international plain language institution:

• public or private funding bodies

• membership fees

• fees for services.

Under option 2, there would be very littlescope for funding from any of these sources,and the working group would need to pro-ceed on a largely voluntary basis. This is howit has operated to date, with individual mem-bers providing their time unpaid. Someorganisations have provided in-kind support,such as the Plain English Foundation hostingthe group’s e-forum and Clarity publishingthe options paper in its journal.

Public and private sources

Under option 3, grants from public or privatesources would provide the main funding fora formal institution. Indeed this is the mainreason for moving from the status quo to afederation model. To apply to bodies such asthe European Union or to a private educa-tional trust, we would need to be a legalentity, perhaps with some tax deductiblestatus.

Organisation membership fees

Under option 3, there would also be thepossibility of organisational members contrib-uting to the new institution, but the reality isthat this support would be in-kind ratherthan by funding. Organisational membershipfees would only become realistic if the mem-bership expands and the institution movescloser toward option 4.


Service fees

It is only under the option 4 model that indi-vidual members would become moreprominent as part of a professional member-ship and certification system. In this case,membership, educational and certificationservices would be a primary source of income.This is a standard model for professionalassociations.

Similarly, any standard that an option 4 insti-tution develops could be made available at acost. This doesn’t prevent a ‘short form’ orsummary of the standard being publiclyavailable, but the full standard would beavailable for purchase only. This is largely themodel that organisations like the ISO operateunder.

Activities such as publications could also befunded by commercial sale or inclusion aspart of membership fees. Back issues of jour-nals or occasional papers could also be madeavailable as e-documents on a cost recoverybasis. This may also be feasible under option3. The three member organisations mightdecide to make the journal Clarity the officialpublication of all three organisations toextend its subscription base and resources.

Activities such as conferences can also poten-tially make a profit to be returned to theinstitution’s general activities. However,given that Clarity and PLAIN both alreadyrun international conferences, this may be alower priority for the new body unless allthree organisations agree that the new insti-tution take on this role.

Recommendation

We recommend that the institutionshould initially seek funding from publicand private bodies rather than member-ship fees and services, but considerbroadening its funding sources if itexpands.

© Eamonn [email protected]

© Dr Neil [email protected]

Eamonn Moran is LawDraftsman in the Departmentof Justice of Hong Kong, and aMember of the Law ReformCommission of Hong Kong. Hehas 35 years experience inlegislative drafting, includingeight years as ChiefParliamentary Counsel inVictoria, Australia. He iscurrently President of theCommonwealth Association of Legislative Counsel.

Eamonn is a keen supporter of the use of plain languagein legislative drafting and in 2005 was awarded anAustralian Public Service Medal for ‘outstanding publicservice to legislative drafting and public law, and to thepromotion of plain legal language’.

Dr Neil James is ExecutiveDirector of the Plain EnglishFoundation in Australia, whichcombines plain English auditing,editing and training with acampaign for more ethical andeffective public language.

Neil has a doctorate in Englishand has published three books andover 60 articles and essays onlanguage and literature. His latestbook Writing at Work focuses on reforming the rhetoricof the professions.

Neil is a regular speaker in the media throughoutAustralia, where he features on the ABC Radio network.He co-convened the PLAIN 2009 conference with Dr PetaSpear and is currently chair of the International PlainLanguage Working Group.

How to join Clarity

The easiest way to join Clarity is to visithttp://sites.google.com/site/legalclarity/,complete an application, and submit it withyour payment. You may use PayPal or acredit card to pay.

Prospective members in Canada, Italy, andthe United States may also pay by bankdraft. If you prefer to submit a hard copy ofthe application, you may contact your coun-try representative for submissioninstructions. Country reps are listed onpage 2.


The system of Clarity and PLAIN holdingconferences in alternate years works well.PLAIN and its conferences have a broad,multi-discipline focus. Clarity, its journal andits conferences, have a focus on legal commu-nications—while welcoming members,delegates, speakers, and papers from allfields.

Clarity’s and PLAIN’s conferences managealways to build on the achievements and suc-cesses of each organisation’s earlierconferences. Given the outstanding success ofPLAIN in Sydney in 2009 and Clarity inLisboa in 2010, we are eagerly awaitingPLAIN in Stockholm in 2011. See http://www.plain2011.com/.

One way in which the conferences improve isin the sharing of papers after the confer-ence—increasingly, this happens both in printand online, in writing, and in film.

In the next issue of Clarity, you will be able toread the highlight articles from the Lisboaconference. That issue of Clarity is being pre-pared. We fully expect it will be mailed toyou on time in May 2011.

Evolution of the plain-language worldand of Clarity

The evolution of the plain-language world,and of Clarity, have been the main topics inrecent:

• messages from the president, see Clarity 63May 2010, p 42, downloadable at http://www.clarity-international.net/pastjournals.html1

• Clarity’s newsletters. The newsletter isemailed to members for which we have anemail address. If you are not receiving it,then you can arrange to do so at http://www.clarity-international.net/join.html.

The discussion about the evolution of Clarityhas reviewed:

• the ongoing broad changes in the plain-language world

• the need for Clarity to evolve in response tothose changes

• how Clarity might evolve.

Although the discussions have involved sometension and some sadness, the good news isthat—at the well-attended Clarity members’meeting in Lisboa—Clarity’s members recom-

Message from thePresidents

Christopher Balmford’s term as president fin-ished at the end of 2010. So—as recommendedby the members’ meeting in Lisboa, and asapproved by Clarity’s Committee—Clarity’spresident elect, Candice Burt, became president.Candice’s term is for 3 years, ending on 31December 2013.

This message from the presidents is in 3 parts—a joint message from both Candice andChristopher, and then a note from Christopherand a note from Candice.

International Plain Language WorkingGroup’s options paper

This issue of Clarity publishes the draft of theInternational Plain Language WorkingGroup’s options paper on standards. Thegroup consists of representatives from Clarity,PLAIN (see http://plainlanguagenetwork.org/), and the Center for Plain Language (seehttp://centerforplainlanguage.org/).

Preparing the options paper has been a longand spirited process. At PLAIN’s 2009 con-ference in Sydney, the group distributedhardcopies of an early draft that had beenproduced after a great deal of useful work.Much further work has been done since thento get the options paper ready for full publi-cation.

For a year or so, this issue of Clarity had beenset aside to publish the options paper. Every-one involved in drafting and reviewing theoptions paper apologises for the delay incompleting the paper which has caused thedelay in getting this issue of the journal toyou. Even so, they—and everyone involved inrunning Clarity—hope you share our viewthat the quality of the paper, and the impor-tance of the topics it discusses, justify thedelay.

Ongoing conference success

Clarity’s conference in Lisboa, in October2010, was a great success. Our congratula-tions and thanks to Sandra Fisher-Martins ofPortuguese Claro for organising and hostingthe conference so brilliantly.


mended to the Clarity Committee that itapprove and implement a range of proposalsfor Clarity’s evolution. Those proposals hadbeen circulated to members in the messagesfrom the president and in Clarity’s newsletter.

The further good news is that Clarity’sCommittee approved the members’ recom-mendations.

You can read the minutes of the Members’meeting here: http://www.clarity.shuttlepod.org/Resources/Documents/Clarity%20Minutes--Lisbon%202010.doc

Highlights of Clarity’s pending evolution are:

• a website revamp—in fact, the revamp haswell and truly begun, with more to come.Our thanks to Helena Englund Hjalmarsson.

• launching social networking activities

• surveying members about Clarity’s role andstructure

• revamping the design of Clarity’s logo,website, and journal

• setting up a committee to prepare a draftconstitution for Clarity. Our thanks toEamonn Moran QC for agreeing to chairthat committee and to Sandra Fisher-Martins, Amy Bunk, John Wilson and BenPiper for volunteering to serve on it.

Play a part

Clarity’s future is bright—there is much to beinvolved in, to contribute to, and to learn from.

With our long-awaited online membershipsystem in place, you can join and renewonline—please encourage others to join too.See http://www.clarity-international.net/join.html.

Candice Burt, President of Clarity

Christopher Balmford,immediate past President of Clarity

From immediate past presidentChristopher Balmford

Clarity is in good hands—and there aremany of them.

The number of people actively supportingClarity is growing. This is a wonderful thing.If we are to further professionalise the prac-tise of plain language and to take the nextstep towards a reader-friendly world, then

international organisations like Clarity andPLAIN need to step up and do more. For sev-eral years, this has been happening atPLAIN. Now it is happening at Clarity too.

My thanks to Candice for taking over aspresident. My thanks to many people fortheir support in my term—extra deep andabiding thanks to Julie Clement, EamonMoran QC, Annetta Cheek, Sandra Fisher-Martins, Candice Burt, Helena EnglundHjalmarsson, Joe Kimble, Cindy Hurst (whohas done Clarity’s administrative work foryears), Peter Butt, and Mark Adler.

Christopher Balmford,immediate past President of Clarity

From current president Candice Burt

In Lisboa—as is always the case at a plain-language conference—the quality of theconference sessions, and the enthusiastic dis-cussion between them, showed the strongsupport people have for Clarity’s activitiesand aims. Also—and perhaps for the firsttime—the discussion at the members’ meet-ing, and its recommendations to theCommittee, showed equally strong supportfor Clarity’s plans.

My thanks to Christopher for initiating andworking tirelessly to shape this round ofClarity’s evolution. It is always challenging tosteer an organisation in a new direction, andChristopher has taken on this challenge withdetermination, focus, and his ever-presentsense of humour.

The next step is surveying members so thatthe Committee better understands members’views about Clarity’s role and structure. Withthat understanding, we will be better able toshape Clarity’s constitution, focus, and activi-ties. In turn, as Clarity evolves, we will bebetter able to professionalise, to advocate for,and to deliver plain language.

Candice Burt, President of Clarity


Clarity … the journalPublished in May and November

Advertising ratesFull page: £150Smaller area: pro rataMinimum charge: £20Contact Joe Kimble, [email protected]

Copyright policyAuthors retain copyright in their articles.Anyone wanting to reproduce an article inwhole or in part should first obtain theauthor’s permission and should acknowledgeClarity as the source.

SubmissionsWe encourage you to submit articles to beconsidered for publication in Clarity. Sendsubmissions directly to editor in chief JulieClement. Please limit submissions to approxi-mately 1,500 or 3,000 words.

PresidentCandice [email protected]

Immediate Past President,resigned 31 December 2010Christopher [email protected]

Editor in chiefJulie ClementPO Box 13038Lansing, Michigan 48901Fax: 1 517 334 [email protected]