Guide Dogs for the Blind (GDB) Response

Dear Canadian General Standards Board Committee Member:

Guide Dogs for the Blind (GDB), the largest guide dog training school in North America, stands opposed to the proposed Canadian National Standards for Service Dogs.

GDB has been partnering blind and visually impaired individuals with highly trained guide dogs for the past seventy-five years and has been providing these same services to Canadians for the past fifty years. Currently, GDB has over 300 active working teams in Canada.
First, GDB is fundamentally opposed to any regulations that require a person with a disability to experience the undue burden of proving to a government or public entity their need for an accommodation such as a guide dog, enduring testing from a public entity that is not fully knowledgeable as to the appropriate behaviors or training of a service animal for the mitigation of a disability, or the necessity to carry and produce identification at the request of the public. We feel that the requirement to show identification has, and will continue to lead to harassment of those with disabilities. It is our understanding that the reasoning behind the creation of the proposed standards is to protect the public from ill-trained dogs who may place the public in danger. However, this proposal places the burden for controlling this nuisance on persons with disabilities who have well-trained dogs and are operating appropriately in public, which is the majority of guide dog teams.

Over the past seventy-five years, GDB has established internal standards regarding the education and preparation of guide dog mobility instructors, the breeding and training of our dogs, the instruction of our clients, including post- graduation follow-up care, and the provision of veterinary care for our dogs which also continues after the graduation of the team. These standards are industry leading, and we are recognized worldwide for our excellence. We also want to express that the proposed “test” within this standard is highly unrealistic and unfair to the handler and the dog. We urge you to reconsider the elements of these tests and seek out guidance from established organizations with the appropriate expertise.

In addition, GDB is a member of the International Guide Dog Federation (IGDF) which certifies guide dog training programs. We are already required to meet rigorous standards for dog training and client instruction, including respectful treatment of clients and humane management of dogs in order to maintain our certification. We assert that, should you continue on the path of establishing these proposed standards, that guide dog teams who have graduated from IGDF certified programs be exempt from these regulations.

If you would like more information about our program and/or our training and certification processes, please do let me know. I am very happy to share information about our high standards of quality assurance.

Sincerely,

Christine Benninger
President and CEO

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