The Seeing Eye’s Response

As the first formal guide dog training and instruction program in North America, and the oldest guide dog school in the world, The Seeing Eye, Inc. has been specially breeding and training dogs to guide blind people from the United States and Canada for almost 90 years.

To ensure equity of high-quality service to guide dog handlers, The Seeing Eye works to the internationally recognized and accepted standards set forth by the International Guide Dog Federation (IGDF). As an accredited member of IGDF, The Seeing Eye adheres to a set of standards far more extensive than the proposed standards published by the Canadian General Standards Board (CGSB). Not only do the IGDF standards address applicant/student selection; client and guide dog team instruction and follow-up; guide dog assessment and training; and the humane care, training and treatment by the guide dog user, these standards also address technical staff education and development; the guide dog mobility instruction education program; breeding, puppy raising and veterinary care; kennel specifications; buildings and transport; administration; and the humane care, training and treatment by not only the end user, but also by puppy raisers and guide dog school  staff.

The Seeing Eye recognizes the need for standards, but we strongly object to the highly detailed, prescriptive one-size-fits-all approach in the proposed standard. With decades of experience in the instruction and training of people with severe vision loss, and as a significant provider to Canada?s blind citizens who choose to work with guide dogs, it is our respectful opinion that these standards grossly underestimate the capabilities and abilities of Canada?s citizens who are blind or visually impaired. Moreover, the narrow scope of ?acceptable? equipment and training methods fail to account for factors associated with blindness and the use of dogs that are required to exercise intelligent disobedience.

In closing, we urge CGSB to either adopt IGDF standards for Canada?s guide dog teams, or provide an exemption to its proposed standards for guide dogs trained by schools that are accredited by the International Guide Dog Federation. IGDF?s standards currently serve as a universal benchmark for the safe and responsible management of guide dogs by over 90 guide dog schools around the world.

Thank you for the opportunity to provide our perspective on the proposed standards.

James A. Kustch, President and CEO
David H. Johnson, Director of Instruction and Training

The Seeing Eye
P.O. Box 375
Morristown, NJ 07960-0375