BALANCE for Blind Adults’ Official Response

BALANCE for Blind Adults provides services and programs to adults who are blind, in the City of Toronto, and has been doing so for the past 31 years. Our community support services are funded by the Toronto Central Local Health Integration Network. These services include Orientation and Mobility instruction to guide dog users, to enhance and bolster the relationship between guide dog and handler. We are often called in to help when our client first receives their new guide dog (which may be their 2nd, 4th or 6th dog), and dog and handler are getting to know each other’s needs, and forming their bond. In addition, we are regularly asked to assist when a dog and handler are learning a new route. We provide assistance all over the city, with negotiating stairways, subways and pathways, as well as office buildings, gymnasiums and college and university campuses, bus routes and much more. All of our clients are adults , and about 10-15% of them are guide dog users. We have 3 Orientation and Mobility Instructors, who teach full time in the city, and each of them are experienced and skilled in working with guide dog handlers and their dogs, after they have returned from their supplying and training facility, whether in the United States or Canada.

Since word of the new proposed Service Dog Standard has come to the attention of guide dog users in Canada, the BALANCE phones have been ringing steadily, with our clients asking us to make a submission on their behalf, as an Orientation and Mobility training facility. We have decided therefore to take the unusual step of speaking on behalf of our clients and their current and future dogs, and on behalf of our instructors, whose training is based on a clear understanding of the rigorous international standards for the training and treatment of guide dogs for blind persons.

We support the efforts of the Canadian General Standards Board to carefully draft a comprehensive standard with the intention of protecting the public and “service” dogs. However, we would assert that the proposed new standards don’t take into account the unique tasks required of guide dogs who are working with people who are blind, and they require additional tasks that are not possible or are not necessary, for these people and dogs to perform. We  therefore  submit that we would support a standard that states that guide dogs for blind persons that have been trained by a school that has been accredited by the International Guide Dog Federation, have sufficient training to work as service dogs in the community. In addition, the standard would state that instructors who train students at these accredited schools have sufficient training to instruct users of guide dogs, and users of guide dogs who attend the schools have received sufficient training to use a guide dog in public.

Given that strict international standards exist, we would ask that the proposed standard include an exemption for schools that are accredited by the International Guide Dog School Federation, and further, that their graduate teams be exempt from the strictures built into the Canadian draft standards, that simply should not apply to guide dog users who are blind or their dogs.

As we are an organization with about 10% guide dog user clients, 10% guide dog user staff, and 20% guide dog user board members, we feel it is necessary to point out the challenges inherent in the proposed new standards, and the need for an exemption for guide dog users who are blind persons.