Canadian Guide Dogs (Ottawa) Response

In Canada, the Canadian General Standards Board has developed and will soon be implementing a national standard for service dogs. While the concept sounds positive, in our opinion, this could have negative consequences for our clients.

We are writing to you today to advise you about this Canadian national service dog standard and to ask for your support.

Background:

Canadian Guide Dogs for the Blind is a member of:

  • The International Guide Dog Federation (IGDF)
  • Assistance Dogs International (ADI)
  • Canadian Association of Guide and Assistance Dog Schools (CAGADS)

The Canadian Association of Guide and Assistance Dog Schools has a membership of nine organizations, including Canadian Guide Dogs for the Blind. Membership in CAGADS is contingent on being a member of IGDF or ADI.

The Issue:

This new standard has been developed over the last couple of years through a committee working with the Canadian General Standards Board. A number of IGDF and ADI member organizations have been represented on this committee. However, our existing industry standards from IGDF and ADI are not part of this plan. In fact, the proposed national standard, as set out, falls far below the accepted industry standards that are already in place.

What does this mean to you?

Our main concern is that if this standard is adopted nationally in Canada, a certification process will then be implemented in Canada. Our understanding is that this certification will be conducted by an independent body. Each guide dog or assistance dog team would be charged a fee for the certification process. A certification from the accredited ADI or IGDF organization, such as Canadian Guide Dogs for the Blind, may not be considered relevant. You may end up with out of pocket expenses for certification, even after graduating from Canadian Guide Dogs for the Blind; and you may encounter a larger number of dogs certified by an independent party with no experience working for any guide dog or assistance dog school. Again, standards would be reduced from what we currently have in place.

History of the draft Service Dog Standard:

Following the initial idea of developing a standard for PTSD dogs, it was decided by Veterans Affairs Canada and the CGSB to develop a national standard for all service dogs, including guide dog and assistance dogs that have graduated from Canadian Guide Dogs for the Blind.

Once the members of CAGADS were made aware of the new initiative, we applied to join the working committee to provide perspective and input. CAGADS members at the table are: Canadian Guide Dogs for the Blind; BC & Alberta Guide Dogs; Dogs with Wings; Dog Guides/Lions Foundation of Canada; National Service Dogs; and Pacific Assistance Dogs Society.

When we joined the committee, we were advised that there are no national or international standards pertaining to the training of either guide dogs or service dogs. As such, the committee decided to move forward without recognizing the standards and accreditation process already developed by ADI and IGDF.

Proposed Canadian Service Dog Standard:

The proposed Canadian Service Dog Standard would be a consensus “Industry Standard” that is reviewed by stakeholders every five years. An industry standard is not a law, but may be used by national regulatory bodies such as Transport Canada, who may choose to adopt the standard as a requirement to travel via aircraft, etc.

All working dogs would be referred to as “Service Dogs”. Every new team, regardless of where they were trained, would be tested by an Assessor, appointed under the new standard, to pass a test and then be granted the Canadian Service dog Standards ID Card. Without passing this test, you would be unable to obtain the National ID card and, as such, may not have the right of public access and travel. The test may be repeated regularly during the working life of the dog. This test may make any ID card from Canadian Guide Dogs for the Blind redundant. IGDF and ADI standards would not apply. Therefore, beyond graduating from Canadian Guide Dogs for the Blind, you would still be required to obtain the Canadian Service Dogs Standards ID Card by passing this additional assessment test, meaning an additional step for you to gain public access, including any financial obligations which will be associated with the test.

CAGADS Recommendations:

The organizations within CAGADS believe that it is inappropriate to have our graduate teams examined by an external body. We have developed and secured the public’s trust in all matters pertaining to public access and travel of our graduate teams.

We believe that all individual trainers and organizations would benefit from, and should seek, to join their international professional peer groups (ADI & IGDF), if they desire to assist and work with persons with disabilities. Both organizations have mentor facilities to assist others to join. We believe that any standard in Canada should also recognize ADI and IGDF.

British Columbia has a legislative program in place, which we feel is a great example of how things should work nationally in Canada. In British Columbia, if an individual does not wish to go to an ADI or IGDF organization, then, there is an alternate route they may take via the BC Justice Institute. Upon completing a pre-determined test, the teams receive the same government card as the IGDF & ADI teams. We believe that the new national standard should recognize both ADI and IGDF graduate teams and those not wishing to attend an ADI or IGDF organization should have a national process where they too may be recognized having successfully passed a test to achieve public access rights in Canada.

Note: All IGDF & ADI graduates currently have freedoms and rights to travel both nationally and internationally having graduated at an ADI or IGDF school.

CAGADS recommends:

  1. All ADI & IGDF organizations and standards continue to be recognized as they have been for 88 years in North America.
  2. ADI & IGDF graduates should not have to take a further test by an outside body having already graduated at their professional school.

How can you help? Have your voice heard!

The process of public consultation is underway. We strongly encourage you to review the standard set out and forward your comments to the Canadian General Standards Board. We need support from our clients. Action needs to be taken now in a proactive approach before this new standard becomes adopted in Canada.

You may review the standard by following the link:

http://www.tpsgc-pwgsc.gc.ca/ongc-cgsb/programme-program/normes-standards/notification/public-eng.html

You may comment on the standard by following this link. Please keep in mind that you must first read the standard and then comment on specific sections. You cannot just make a general comment based on the information we have provided.

http://www.tpsgc-pwgsc.gc.ca/ongc-cgsb/programme-program/normes-standards/notification/comment-secret-eng.html

Please note the deadline to comment is July 14, 2017.

This is completely voluntary, but we feel that having your say is beneficial to you personally, as well as to Canadian Guide Dogs for the Blind.

We hope that you will see the urgency in this matter, which, we feel, may completely compromise the work of Canadian Guide Dogs for the Blind, and other organizations within the International Guide Dog Federation and Assistance Dogs International.

Sincerely,

Canadian Guide Dogs for the Blind
4120 Rideau Valley Drive North
PO Box 280
Manotick, Ontario K4M 1A3

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