Joint Response to Public Comment Pursuant to DGO 3.01.04(D)
DGO 5.23 Interacting with Deaf and Hard of Hearing Individuals
SFPD Department General Order (DGO) 3.01 requires that all policies under development be posted publicly to provide members of the public thirty (30) business days to submit policy recommendations.
Pursuant to DGO 3.01.04 (D), the Department and the Department of Police Accountability (DPA) jointly prepare a public response, which shall be posted on the Department’s website, outlining the recommendations included and not included in the DGO draft submitted to the Police Commission.
Joint responses are captured in the following recommendation grid which captures the original recommendation, whether the recommendation was included or not included in the draft DGO, and the explanation relating to the decision to include or not include the recommendation into the draft DGO.
The Department reserves the right to remove or not respond to comments if they are:
- Unrelated to the subject of the DGO
- Include private personal information (whether the commenter’s or someone else’s), including home address, home or cell phone number, personal e-mail address, or personal identification.
- Include profanity or obscene language
| # | PUBLIC COMMENT | DATE RECEIVED | SFPD RESPONSE | SFPD EXPLANATION | DPA EXPLANATION |
|---|---|---|---|---|---|
| R1 | In Section 5.23.04.A.2.b, I love that this GO is WAY shorter and more general. I would reward "Using an Interpreter" to maybe "Tips for Using an Interpreter". Also it says bilingual in the sentence before. Are ASL people considered bilingual? That line was confusing. | 12/9/25 | Recommendation will not be included in Draft DGO | The intent of this DGO is to provide clear, usable direction while keeping the policy concise and operational. Adding the word "Tips" would unnecessarily undermine the section's authority. "Bilingual" in this context means you speak English AND can communicate in ASL. | DPA has no additional comment. |
| R2 | The second sentence from the purpose statement should be removed or reworded. Why would guidance based on recommendations be in the most authroitative policy SFPD has? | 12/10/25 | Recommendation has been included in draft DGO | This language was intended to help clarify but instead feels duplicative. The section has been removed. | DPA has no additional comment. |
| R3 | Policy section B says without cost to the user, but when SFPD uses language line, SFPD is paying...and what are the other auxiliary aids? | 12/10/25 | Administrative Questions and Answer-not for inclusion in DGO | The "user" refers to the person receiving the service. | DPA has no additional comment. |
| R4 | 5.23.04 A 1 g - does the Department have access to in-person interpreters? Are officers expected to wait however long until they show up? | 12/10/25 | Administrative Question and Answer-not for inclusion in DGO | The Department does have contracted civilian in person interpreters as outlined in section 5.23.04.A.2.c, as well as a small number of Officers who are certified in the use of ASL. Response times for in-person interpreters can be lengthy. Depending on the circumstances of the incident, alternative communication methods can be considered, see section 5.23.04.A.3 | DPA has no additional comment. |
| R5 | Are the standards for what will be scrutinized in court and what is criminal the same? Why cite a DN when they expire every 3 years? The DN should cite the DGO not vice versa. | 12/10/25 | Recommendation has been included in draft DGO | The wording has been changed to be more consistent "2. Interpreters - Except for routine traffic citations, if a conversation is likely to be relied upon as evidence in court, an interpreter should be prioritized." This mirrors the requirements for victims and witnesses in section 5.23.04.B.4 and California Evidence Code §754(j). Interpreters for suspect interrogations are covered in section 5.23.04.B.3.c DN's are generally not referenced in a DGO; these notices are unique in that they refer to 3rd party service vendors. The section has been reworded to remove the direct references to the DN's to now include general information on how to request an interpreter. | DPA has no additional comment. |
| R6 | 5.23.04A2biv says the same thing as i. Combine 5.23.04 3 and 5 or at least put next to each other. What is the follow up procedures for exigent circumstances to make sure officers do not get in trouble? | 12/10/25 | Recommendation has been included in draft DGO | Nice catch, section 5.23.04.A.2.b.iv has been Officers' actions during exigent circumstances are documented on their body-worn cameras to ensure transparency and accountability. This provision applies only for the duration of the exigency; once the exigency has ended, officers are expected to follow standard procedures based on the specifics of the incident, applicable training, and best practices. | DPA has no additional comment. |
| R7 | Is there any general information you can provide about holding cell exemptions for deaf like they do not have to be in a holding cell per DM Booking...? Also spell out TTY. What is the purpose of the telewriter? It does not say | 12/10/25 | Recommendation has been included in draft DGO | The current Booking and Detention manual prohibits placing a person in a station holding cell if they are deaf. TTY is now spelled out as Teletypewriter. | DPA has no additional comment. |
| R8 | Why in a GENERAL order, do you spell out the exact symbols that will be depicted on facility signage? Who falls under all public-facing employees? Does this include people who present at Police Commission for example? | 12/10/25 | Recommendation has been included in draft DGO | The General Order specifies required signage to Public-Facing is is being rewording to "Public | DPA has no additional comment. |
| R9 | There is no information throughout about certified versus non-certified or how that process works or how to become or what that even means | 12/10/25 | Recommendation will be modified and included in the draft DGO | Bilingual certification is a separate Department process. DGO 5.20 defines what bilingaul certification entails. Added a reference after section 5.23.04.A.1.f | DPA has no additional comment. |
| R10 | In section 5.23.04.A.2.b, can i and iv be combined to something like "Look and speak directly to the person, not the interpreter..." | 01/13/26 | Recommendation has been included in draft DGO | Nice catch, section 5.23.04.A.2.b.iv has been removed. | DPA has no additional comment. |