Coalition Conference Call with Canadian Human Rights Commission, September 8


Summary of Concerns raised by stakeholders regarding the Canadian General Standards Board draft Service Dog Standard

Conference call, September 8, 2017

  • Many proposals in the Standard are irrelevant, unnecessary and dangerous for guide dog users. There are a number of human rights issues that need to be addressed.
  • The Standard’s tone is problematic – it is steeped in medical jargon.
  • There were many issues with providing submissions/comments on the Standard: the length of time was insufficient (only given 2 weeks); the submission process was inaccessible; and, there were confusing/conflicting messages on how to provide submissions
  • In regards to the development of the Standard, it is inappropriate to have a secretive process that is going to impact the lives of people with disabilities. The process should be inclusive and transparent.
  • The Standard should either be withdrawn, or at a minimum, guide dogs and guide dog users should be exempt.
  • It is important that the Canadian General Standards Board understand and reflect back on the original purpose/mandate of the Standard, which was to help veterans. However, the proposed Standard, as is, would not be beneficial to veterans either, as it does not provide them with the proper training.
  • The Standard resembles legislation from the 1950’s, where people with disabilities were treated without autonomy. The Standard does not reflect the current social model of disability, which looks at removing barriers and allowing people with disabilities to make their own decisions for their lives.
  • Service dogs can assist in a number of different ways with a number of different disabilities; however, the Standard takes a cookie cutter approach and a one-size-fits-all approach. This blanket approach is often found to be discriminatory in human rights law. Therefore, the notion that all people who need and use a service dog can fit into this Standard is a problem.
  • Requiring users to know how to administer first aid to dogs, how to deal with broken bones, abrasions, cuts, and when to administer CPR, are all inappropriate and unrealistic requirements.
  • The sections on inspection and testing, which allows for a third party inspector to come to your home, are inappropriate and intrusive and reiterate the paternalistic idea that people with disabilities need to be observed and monitored. In addition, the powers of a third independent certifying body are unclear, which is a problem.
  • Although it is important to obtain the appropriate training and support for guide dogs, there are better ways than those outlined in the Standard. Most guide dogs attend schools that are already meeting standards, such as those set out by the International Guide Dog Federation. Therefore, there is no need to have another layer of standards imposed on guide dog users and there is no need to abandon the current standards that exist, in lieu of these substandard guidelines.
  • The issue of fake guide dogs should not be dealt with through this Standard.
  • Putting the onus on guide dog users to meet these high standards is inappropriate. Many users would not pass the proposed Standard. All of the responsibility of an individual’s disability is being put on the individual. The emphasis needs to be placed on the dog and not on the person with a disability and their engagement with society as a whole. The only responsibility the individual should have is to make sure their dog is behaving appropriately in public spaces.
  • The proposed Standard should be a policy, not a standard. This standard setting approach instead of a broad public policy approach is not helpful. It also needs to be framed under a human rights based model. If the Standard goes through as is, there will be numerous human rights complaints.
  • The goal of the upcoming Accessibility legislation is at odds with this Standard. This Standard also goes against the principles of the UNCRPD.
  • Most people get their guide dogs from the USA – there are more schools and the wait times are shorter. However, if Americans decide that they can no longer provide guide dogs to Canadians, because of the proposed Standard, wait lists would become a lot longer, depriving individuals of their choice and right to a guide dog.
  • Carding is unnecessary. The only two questions people should need to ask are: Is this a service animal? What does it do for you? The Standard could increase the level of carding when in public spaces and will make travelling even more difficult. What kind of impact would these standards have on people visiting Canada? Instead, the Canadian General Standards Board need to focus on how to make it easier for people who use guide and service dogs to move around freely.