During the second quarter on Saturday night, Kirk and his Hawthorn opponent Sam Mitchell were positioned behind James as he bounced the ball on the wing.
As they ran towards the contest, Kirk and Mitchell bumped one another and the Swans co-captain subsequently collided with umpire James as he jogged backwards from the contest.
Speaking before Swans training at the SCG on Tuesday afternoon, Roos said his players had asked him how to approach a situation like Kirk's and he was unable to advise them.
"I think the difficulty at the moment is that I can't coach them until I get clarification. I'm not suggesting Sam's done anything wrong either, to be perfectly frank, but the rules as they're written are quite grey.
"Brett's asked me already, if he's in that position again, what does he have to do and I said 'Brett, I can't tell you. I've got no idea. I have absolutely no idea.'
"Hopefully we can give the players some more guidelines come Wednesday or Thursday."
Roos said he hadn't noticed the incident during his first viewing of the match replay, but once Kirk had been cited, he said the coaching staff had watched it "4000 times".
The report comes as part of the AFL's crackdown on contact with umpires.
The no-go zone behind umpires at centre bounces was trialled in the NAB Cup but was not brought in for the home and away season.
However, the AFL had indicated it would crack down on reckless contact with umpires, including bumping another player into the umpire.
Roos said regardless of whether Kirk was suspended, the AFL's interpretation of the rules needed to be clarified.
"Whether it's (director of umpiring) Jeff Gieschen or (match review panel chairman) Andrew McKay or whoever, we've certainly got some concerns," he said.