Leader Dogs for the Blind Response

Dear Canadian General Standards Board Committee Member:

Leader Dogs for the Blind is one of the leading providers of guide dogs in North America. We have been partnering blind and visually impaired individuals with highly trained guide dogs in both the United States and Canada since our inception in 1939.  In the past 78 years we have graduated 886 Canadian teams, and currently have 59 active guide dog teams in Canada.

We have reviewed the Canadian National Service Dog Standard and find some areas within the standard that cause us great concern for our graduates and future clients.  First, we are fundamentally opposed to any regulation that requires a person with a disability to experience the undue burden of 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.  It is our understanding that the reasoning behind the creation of the proposed standard is to protect the public from ill-trained dogs who may place the public in danger. We agree with the need for standards and the identification of a qualified service dog will help to mitigate the use of “fake service dogs”.  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.

The Leader Dog program has internal standards regarding the education and preparation of guide dog mobility instructors, the breeding and training of dogs, the instruction of clients, including post- graduation follow-up care, and the provision of veterinary care.  These standards have been developed over the last 78 years and meet or exceed the standards set forth in the International Guide Dog Federation (IGDF) standards.  Since 1989 IGDF has administered an Accreditation and Assessment process that ensures operational standards are maintained and improved to produce high-quality guide dogs.

As a member of IGDF 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 this proposed standard, 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,

Susan M. Daniels

President & CEO

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