The Coalition’s position
We have asked of Minister Carla Qualtrough, Minister of Public Services and Procurement, and Minister Seamus O’Regan, Minister of Veterans Affairs Canada to facilitate:
- The immediate exemption of all Guide Dog Teams and Service Dog Teams in Canada from the CGSB standards.
- Return to the original 2015 Veterans Affairs Canada mandate of ensuring high quality training for Veterans Service Dogs
- Suspend or stop completely the standards process and instead have a robust Social Policy process together with Veterans, expertise within the broader community and managed by the CHRC to ensure the training support for Veterans is relevant and is aligned with UNCRPD.
- Build capacity with existing Service Dog Schools and Veterans to support effective training outcomes for Veterans Dogs which can lead to support of all Canadians requiring well trained Specialized Service Dogs.
Chair Yvonne Peters
Yvonne gave a brief overview of the history of the coalition which consists primarily of Guide Dog Handlers and we welcome Service Dog Handlers:
In late June of 2017 we woke up one morning to find the Canadian Government, through the Canadian General Standards Board (CGSB), had been working on and planning for over two years to introduce standards governing the work of Service Dog Teams. We were all quite shocked and alarmed they were putting significant layers of requirements for Guide Dog Handlers that are not necessary, are irrelevant and violate Human Rights Principles, which is true for all Service Dog Handlers.
So I felt we needed to respond as quickly as possible and during the public comment phase many issues were wrong like the content, the format and accessibility to be able to comment. It was quite a time of activity and we came together as a strong group and agreed on what we wanted and put that in our submissions. Generally the Coalition has taken a strong stance against the standards, it is our belief we do not need these standards that most of us attend, all of us probably are already accredited by the International Guide Dog Federation, there are already standards in place and there is no need for additional standards. We strongly object to a one size fits all cookie cutter approach to standards. At minimum Guide Dog Handlers should be exempt from these standards and we also realize the standards themselves have lots of problems so alternately we would like to see these standards be scrapped, We fully support the original intent which was for Veterans Affairs to develop specific standards for service dogs needed by Veterans. We do not dispute that this may a needed thing however it does not involve us. What we disagree with, object to and oppose is the CGSB arbitrarily without consultation deciding to apply these one size fits standards to all Guide Dog and Service Dog Handlers.
Social Media Report – Tom Dekker
(Statistics report provided following the meeting notes.)
Tom gave an important and exciting update on the work he and Ken have done since June setting up the blog, the Facebook page and the Twitter account. They are available to assist people to learn to use Zoom as a free conference call model so smaller groups of people can work together and develop areas of interest to contribute to the Coalition goals. Further, he is requesting people write blog articles so we can keep interest and the momentum going. Please do not contact Tom directly about coalition work as our official email contact is at firstname.lastname@example.org
Update on Standards Activities:
Report from Guide Dog Users of Canada – Greg Thompson, Alan Conway, Christine Switzer.
GDUC is a voting member of the Canadian General Standards Board Technical Committee, CGSBTC, and joined at the beginning in June 2015. The goal in joining was to protect the rights and interests of Guide Dog Handlers, and to offer their expertise and knowledge in the development of a standard for Veterans Dogs. At the time they felt they needed an expert in standardization at the table, and chose Michel Bourassa as their voting member. Mr. Bourassa was to take his direction from GDUC, and report back to GDUC. All committee members had to sign nondisclosure agreements. However, it became clear in June 2017 that the standard available for public comment was not the one that GDUC had worked on or agreed to. GDUC sent in a public comment against the standard. Soon after, they changed their voting member to Christine Switzer who is now the current representative on the CGSB committee. She attended the CGSB meeting in September 2017 where it was to review all the Public input. GDUC polled its membership in advance, and went into the meeting with a clear 99% mandate to exempt Guide Dog Teams from the standard. GDUC was not permitted to bring this up at that meeting. GDUC is currently developing strategies to address this issue.
Overview and Intervention of the Canadian Human Rights Commission Report – Yvonne Peters
(CHRC report is included at end of the meeting notes.)
The CHRC, after attending the Standards committee meeting in Sept 2017, wrote an opinion. This was responded to by the Standards Board. The CHRC has no further plans to review another draft of Standards at this time. The CGSB responded in Dec 2017 and that letter is attached. It was pointed out that a companion document and any other appendixes attached to the standards, should the standards become law, are not law. Only what appears in the actual body of the standards are considered the legal document. Anything else is information only.
Update on Political Initiatives – Mary Ellen Gabias
Meeting minutes are attached after these meeting notes. This report is on the meeting that took place on November 9th 2017 with senior people from Minister Carla Qualtrough’s Office. There is a list of attendees in the minutes of that meeting. Many thanks to Maria Kovaks for her tenacity in getting this meeting. A follow up meeting was agreed to in January 2018 and we are following up on this.
We definitely were clear about the Human Rights issues, how the process was flawed and not aligned with the UN Convention, The government attendees had the CHRC report, we pointed out that nearly all the submissions we had been sent by people, it there overwhelming opposition to the standards including the world blind union, Guide Dog Schools and many others. The Guide Dog community is saying this standard is not not appropriate for us and they are unnecessary for us. We made all the arguments we have made to each other. They asked for time to figure it out and we will meet again in mid January. One thing the CGSB is doing in the companion document is trying to use a few human rights phrases. We need to be really firm as the entire process is flawed and a companion document and phrases like equivalency are not acceptable. The standards have the goal of moving in the same direction as the BC process that sets up a system where the government is determining who can be registered using the term certification. They are hoping people may be lulled into a false sense of acceptance and compliance when in fact this entire 2 and half years has been a non human rights process. They are hoping to peel off as many of us as they can by pretending they listened to our submissions and are allowing us equivalency.
We discussed and everyone felt strongly that even though the CGSB is an arms length process, because of the blatant Human Rights violations of this standards process took that we must press the Government at our next meeting with Carla Qualtroughs Office to intervene even if this is not an easy political solution.
Report on research, writing of the Menzies Report -Jean Menzies
(Report is attached after the meeting notes.)
Jean shared all the information on the hard work she and her husband Jim have done these past 6 months, researching information and meeting with Federal Government Departments. They have worked tirelessly on researching, collecting and reading all reports and information and wrote a report called A failed Process. Please see this report at www.hooh.ca and on their blog at https://canadianguidedog.wordpress.com/
Coalition Members asked questions and shared different ideas regarding the information they heard and ideas about going forward. It was agreed we would continue the political work, the letter writing to MP’s and regularly do blog postings. Yvonne thanked everyone for all their hard work and for sharing. The coalition work is expanding and we are requesting rather than emailing demand people separately regarding the work of the Coalition, people can email the coalition at anytime to ask questions to specific people and it will be rerouted. If you have information or articles to be posted on the blog please send them to our email address as well.
Coalition Website/blog: www.hooh.ca email: email@example.com
End of January 17, 2018 meeting notes and beginning of attachments
Social Media Report-Tom Dekker and Ken Sudhues
All 50 posts are public.
Total direct views: greater than 19,560 (Facebook rounds off numbers higher than a thousand and several posts went higher than that.
Average views per post was close to 400.
Engagement rate (viewers who liked, commented or shared) averaged 7 – 10 percent
Highest engagement rate (11 – 14 percent) was for reactions or responses to the draft CGSB standard.
Lowest engagement rate (0.3 percent) was for an item about therapy dogs in a strata complex.
60 percent of those liking the page are women.
Likes come from Canada, USA, the UK, New Zealand, Germany and Trinidad.
Total views: 4641
Highest views were August, September and November (close to 1000 views per month).
December (236) and January (151 to date) view rates are much lower.
Total visitors: 2472.
End of report by Tom Dekker and Ken Sudhues
Jean Menzies Report
Jim’s Activities on the CGSB File:
- Wrote the report, A Failed Process.
Federal government correspondence:
- I wrote letters sharing the report with the Prime Minister’s Office and the Ministers of Public Service & Procurement Canada, Veterans’ Affairs Canada, Department of National Defence, and Sport & Persons with Disabilities.
- I shared the report with both opposition leaders and the critics from both opposition parties for each of the affected ministries.
- I also sent the report to staff within Public Service & Procurement and CGSB.
- I had responses from the Prime Minister and the ministers of National Defence and Veterans’ Affairs, as well as a staff response from PS&PC.
- My basic read of those responses is that my comments, along with those of many others, are being taken into account in the preparation of the next draft, which will be released “in the new year”, which means sometime in 2018. In the meantime, Minister O’Regan in Veterans’ Affairs seems to be the most responsive on the issue, and has encouraged continuing engagement.
- Of note, there were no responses from the ministers of Public Service & Procurement, nor Sport & Persons with Disabilities, nor were there responses from any opposition members.
- I also wrote to our local MP to share the report; we have a strong working relationship with her, and she is supportive of our cause.
Federal Government conference call:
- I had a conference call discussion with staff from the Office of Disability Issues within the Ministry of Employment and Social Development Canada.
- They were polite and listened carefully to our concerns, promising to take them into account in any future interactions on the CGSB file.
- They defended CGSB’s process, despite the evidence of process failure that was included in our report.
Provincial government correspondence:
- I wrote letters sharing the report with the premiers and relevant ministers of every province and territory.
- Setting aside the inevitable “auto responses”, I heard back from all except Saskatchewan, PEI, Northwest Territories, and Nunavut.
- The provincial responses fall into two camps. Mostly, they indicate that their own existing legislation will continue to prevail, and if they use the CGSB work, it will only be as one piece of a broader consultative process.
- A couple of responses indicated a lack of understanding of the issues, but this is not surprising (NB I think there were some French / English translation issues in my correspondence with Quebec).
- I also wrote to our local MLA, but have not received a response.
- I shared the report and had a productive correspondence with IGDF; I believe they used the report in their subsequent participation on the CGSB committee.
- During the preparation of A Failed Process, I made two Access to Information Requests:
- I received a voluminous response from Veterans’ Affairs Canada (542 pages), and am beginning to work through it now.
- I still have no response from PS&PC, which is a violation of the Access to Information Act that I will be following up shortly.
- I shared the report with Guide Dogs for the Blind, since they had expressed an interest in the issue and were looking to share information with their graduates.
Response of the Canadian Human Rights Commission
Drafted after attending the Sept 2017 3-day meeting of the CGSB’s Service Dogs Standard Technical Committee.
Overall CHRC concerns
The CHRC has concerns that the process the CGSB has undertaken: has not sufficiently consulted, included, and considered the views of those persons with disabilities affected by the standard, and; will not produce a standard that protects human rights. Further, we are concerned that the process so far, and the draft standard—especially if implemented widely–could create, rather than remove, barriers for persons with disabilities.
Our specific concerns and recommendations are included below.
Specific CHRC concerns
Purpose and scope
The CHRC understands the draft standard was first developed for Veterans’ Affairs with the goal of ensuring that Veterans have access to quality service animals and to provide assurance that the psychiatric service dogs being provided to veterans are properly trained and meet appropriate behaviour requirements. We support this work, which can improve the daily lives of veterans. We do not want to create a barrier or slow down the access to service animals for veterans.
However, while the CHRC has only observed one technical committee meeting, we feel that the community of service dog users/providers could benefit from a larger policy discussion to identify the scope of issues related to service dogs to explore whether, for example, standardization is the best solution to reach the goal. It is not clear, based on the information we have, whether other options to a standard were ever discussed. We also noted that the scope of the project appears to have changed and grown from its original focus, and has attempted to engage in standards discussions for wider populations.
The CHRC has also not received information that assures us that a rigorous policy analysis was undertaken to inform the process or the proposed standard.
As some of the stakeholders at the technical committee meeting suggested, the CHRC would recommend the CGSB pause to reflect and ensure the process undertaken is the right one to meet the goal, and that the standard covers the appropriate scope.
In light of this, we would make the following specific recommendations.
We recommend that, as was suggested by a stakeholder in the technical committee meeting, CGSB roll the scope of this particular standard back to its original and more focussed purpose. This could provide time for a larger policy discussion but at the same time allow the draft standard to be piloted for a specific population: veterans. In any pilot of the standard, we recommend that the standard be evaluated and reviewed with stakeholders within a year, using a human rights framework. It should also be re-assessed in the context of any broader policy discussions that may take place, and updated to align with any newer relevant standards.
For the larger policy discussion, the CHRC recommends that the CGSB situate this work more squarely within the broader government agenda to develop accessibility legislation to make Canada a more inclusive society.
To ensure that the landscape is more fully understood, the CHRC recommends that the CGSB undertake additional research and policy analysis and in particular, prepare a scan of the legal, regulatory, social, political, economic, jurisdictional, and technological facets of the issues that should be taken into consideration in developing a standard that is most helpful to remove barriers and support inclusion and equality.
We also urge the CGSB to work with ESDC and Veterans Affairs Canada to engage with the provinces and stakeholders to consider the scope of issues raised, the problems and barriers, and to explore all relevant possible policy solutions in the current context. This discussion should be accessible to a wide variety of stakeholders, be transparent and ensure that any next steps are not creating barriers for persons with disabilities.
Embedding human rights principles
The proposed draft standards, as they currently stand, do not reflect fundamental human rights principles articulated in the UNCRPD or domestic human rights legislation.
For example, the standards do not recognize that persons with disabilities have the right to use a service animal to assist them in functioning with dignity and independence in society, nor that persons with service animals have the right to access services and employment without discrimination.
It is the view of the CHRC that treating someone with a service animal adversely or refusing to accommodate them to the point of undue hardship could amount to discrimination prohibited under the Canadian Human Rights Act (CHRA). The CGSB must keep in mind that even if the standard is met, the standard itself may be discriminatory and furthermore it does not eliminate the duty to accommodate.
To ensure that any future standard is relevant and provides appropriate guidelines to government and members of the industry, the CHRC recommends that the CGSB refer to the purpose and principles of the UN CRPD and embed these more clearly and thoroughly in the draft standard and its process.
Participation of stakeholders and consideration of diverse views
The CHRC has concerns about the consultation process used to develop the proposed draft standards. The CHRC believes that it is essential that initiatives and standards such as these be developed with the full and meaningful participation of those who rely on service animals.
We recommend that CGSB more thoroughly review, consider, integrate, and respond to the concerns of stakeholders raised in the detailed submissions received.
We would recommend that CGSB specifically reflect on and respond to the submissions provided by: the Manitoba Human Rights Commission; Jim Menzies (Canadian Service Dog Standard: A Failed Process) and; the article by James A Kutsch (Additional Regulation Isn’t Necessary to Resolve the Issue of Fake Service Animals). These documents in particular, highlight some of the concerns we share with stakeholders.
We also recommend that the CGSB consult more broadly with stakeholders, and in planning these, reflect and reconsider these questions:
- How can a more inclusive process be undertaken that ensures diverse groups of stakeholders are around the table?
- How can the process support meaningful dialogue that considers intersectionality needs and supports persons in vulnerable circumstances?
- How is the CGSB ensuring the coordination/participation of all jurisdictions which is critical to develop a national approach?
CGSB response to the CHRC report
December 14, 2017
Piero Narducci, Director General
Human Rights Promotion Branch
Canadian Human Rights Commission
RE: Development of a National Standard of Canada for Service Dog Teams
Dear Mr. Narducci,
Thank you and your staff for meeting with us at the Canadian General Standards Board on November 2, 2017. We are very pleased to collaborate with the Canadian Human Rights Commission on the development of the draft national standard on service dogs.
We at, the Canadian General Standards Board want to reiterate to your team information about our role and clarify some of the elements outlined in your email of October 16, 2017 that we discussed with you and your team on November 2, 2017. That being said, your continued support in helping move this file forward is a key contribution to successfully completing the standard. We welcome your ongoing advice and that of other experts in this field to ensure that the draft national standard will align with current Canadian policy. Additionally, by colloborating with you and your team, we are hopeful that additional outreach can be made available to stakeholder groups so that they will be aware of the draft national standard and the public value and good that this will bring to all people with disabilities.
In terms of developing this draft standard, we shared information on the approach, our role at the Canadian General Standards Board and how our work is linked to legislation and regulation at our meeting in early November with you and your team where we discussed your email of October 16, 2017. Our work is based on knowledge of technical experts who live and work in the community to which the standard is related and they make decisions in terms of the content of the standard. Through our meetings and interactions with stakeholders we work to develop a voluntary standard that is a framework that can be used in policy, legislation or regulation.
We also have worked and will continue to work with federal and provincial partners. To date we have communicated with the Department of National Defence, Transport Canada, the Canadian Transportation Agency, the Department of Finance Canada, Agriculture and Agri-Food Canada, the Department of Justice Canada, Veterans Affairs Canada,
Economic and Social Development Canada along with the provincial governments of Alberta, Ontario, Nova Scotia and British Columbia. We will continue to reach out to government bodies and encourage ongoing communication as we move forward. The technical committee is open to stakeholders who have a vested interest in the work underway on service dog teams and there are mechanisms in the process for all Canadians to participate and be represented. Work to strengthen the membership of the technical committee is ongoing to ensure that all relevant stakeholders continue to be represented. New members have been recently added to the Committee from the International Guide Dog Federation and the Canadian National Institute for the Blind. We will continue revisiting the scope of the draft standard at future meetings and continue reminding technical committee members of their role regarding the objective and content. This will help all members to better understand their functions and hopefully increase any issues raised with your organization about transparency.
We take heed of your advice to move more slowly, to ensure due diligence in listening to stakeholders, to learn from our experiences and to build trust with the community. We are also taking steps through the technical committee to consider a pilot approach with Veterans Affairs Canada.
The next iteration of the draft standard will be posted for its second public review early in 2018 and all comments received will again be shared with the technical committee for their consideration. Similarly, the information documents you identified have been shared with and considered by the technical committee. These are normal steps in the standards development process and part of our open and transparent approach.
As an enhancement to our regular approach, a third party is being engaged to assist with the second public review to ensure that anyone that wants to comment can and have the accessibility to do so. This organization’s role will allow for stakeholders who cannot use the regular comment form, to be able to call in and explain their feedback verbally. The third-party organization would then transcribe and submit the comments.
We want to work with the Canadian Human Rights Commission so that this national standard can help people living with disabilities. Your wisdom and insights have been very valuable.
Original signed and sent by mail
Directrice principale, Bac en comm. MAP
Direction générale des services intégrés / Services publics et de l’Approvisionnement Canada firstname.lastname@example.org / 873-469-3250 (office) (613) 897-3414 (cél.)
Senior Director, B. Comm (Hons), MPA
Integrated Services Branch / Public Services and Procurement Canada email@example.com / 873-469-3250 (office) (613) 897-3414 (cell)
Report on Nov 9th 2017 Meeting Minutes with Carla Qualtrough’s Office
Expected Outcomes of the Coalition/Government working group as presented on Nov 9th 2017, Conference Call. The Government represented by Public Services and Procurement.
This first meeting was the opportunity for the Guide Dog Handler and Service Dog Handler Coalition Representatives to present the history, background and context to our expected outcomes required to fix the failed standards.
It was agreed by all there will be another meeting of this working group in mid January 2018 in order for the Government to review the multi faceted issues that have impacted us as stated in our presentation and to discuss how the Government will proceed on the expected outcomes. This begins with enacting our number one expectation of immediate exemption.
The immediate and number one expectation we have of Minister Carla Qualtrough, Minister of Public Services and Procurement is to facilitate:
- The immediate exemption of all Guide Dog Teams and Service Dog Teams in Canada from the CGSB standards.
- Return to the original 2015 Veterans Affairs Canada mandate of ensuring high quality training for Veterans Specialized Service Dogs
- Suspend or stop completely the standards process and instead have a robust Social Policy process together with Veterans, expertise within the broader community and managed by the CHRC to ensure the training support for Veterans is relevant and is aligned with UNCRPD. The presentation follows.
- Included with above begin capacity building with existing Service Dog Schools and Veterans to support effective training outcomes for Veterans Dogs which can lead to support of all Canadians requiring well trained Specialized Service Dogs.
Presentation by Dr. Susan L. Hardie
Introduction: It is important that I locate myself in this discussion. I am a person who has worked in the disability field, inclusive but not limited to mental health, for three decades (i.e. research, policy analyst, community developer, advocate, clinician) and as a Service Dog Team Handler of almost 18 years (owner/handler) with PTSD and hearing impairment. Dr. Hardie also acknowledged that she is a voting member on the CGSB Technical Committee.
Contribution to discussion: I want to support Mr Trudelle’s (Canada Standards Board) point, that the non-disclosure agreement has been, and continues to be, a significant issue that needs to be addressed.
I will be speaking today as an individual, an individual with expertise. I highlight “expertise” as there is a recurring narrative of those expressing concerns about the Standards work of CGSB as “not understanding”. I want to assure you that I do understand.
First I would like to acknowledge that CGSB responded to a request to develop a standard. I also want to acknowledge that Veteran Affairs stepped up following a meeting of stakeholders, and entered into a contract with CGSB, it was my understanding with the intent to making a difference in the lives of all service dog users (in society).
Yet, the missing link in this work appears to be the lack of connection, on an ongoing basis, to the communities of guide dog and service dog users, and existing values, languages, policy frameworks congruent with the United Nations Convention of Rights of Persons with Disabilities, the Canadian Charter of Rights and Freedoms, etc.. In order to address this significant gap, I want to suggest three specific actions:
(i) Stop (or minimally suspend) the Standard development: this action should occur until the second point, robust community needs assessment, is completed;
(ii) Completion of a robust, community needs assessment with, and for, service dog users in all aspects (i.e. inclusive of needs, interest in participation in solutions, etc.): It would be great to include Service Dog and Guide Dog Handlers so that there might be opportunities to work together on cross-cutting issues in future.
A robust community needs assessment is essential to:
- Identify needs of Guide and Service dog users;
- Seek solutions with existing legislation and regulation; and,
- If needs still unaddressed to seek new solutions with one of those solutions potentially being a standard.
(iii) Support Veteran’s Affairs in development of policies and procedures to guide decision-making regarding Service Dog teams: Allow those of us with expertise in development of disability, inclusive of psychosocial disability, policy and practice to work with Veterans to develop policy and procedures to guide decision-making regarding immediate needs of Veterans. This requires robust research and policy analysis informed by a best-evidence process.
What happened was that once the contractual agreement was in place, when the needs for a Standard was not completed by CGSB, and the non-disclosure issue really impeded the ability for the disability community to share their invaluable knowledge around human rights, disability policies, mental health policies that are congruent with the UN Convention on the Rights of Persons with Disabilities, etc..
The values of language need to be totally congruent with the UN Convention of the Rights of Persons with disabilities as a place where you start. You do not add it on at the back end. It’s a fundamental framework and we need to work together to come up with solutions first within existing legislation and regulations, and then additional solutions….one of which may be a standard.
I am not a lawyer, yet I wonder if there is a way to revisit the CGSB contractual agreement with Veteran Affairs? ……. so there is a policy and procedure work undertaken specific to Veterans? I will leave this question with you.
Points raised on the call
- The Coalition thanked the Government for their commitment to work with us and discuss the current issues and solutions we presented in this Coalition/Government working group.
- We believe this is the beginning of a relationship that can become a model to resolve the clash between the Charity/Medical model that many government agencies and departments work from and the Social Policy Model. This can recognize and commit to the paradigm shift by Government, required to support the new CDA and align the work to be done with the UNCRPD.
- The government stated the technical committee had reviewed the submissions and were trying to achieve a delicate balance to meet the concerns of all the people impacted by the standards.
- They also stated they were not experts in the field and needed to better understand all the issues for Guide Dog Handlers and Service Dogs Handlers and the impact of the standards.
- The Government expressed it will need time to review the information presented and a second meeting of the Coalition/Government working group will meet again in mid January 2018. All parties agreed to this next meeting.
- There was a short history given of the disability rights movement in Canada, the rights fought for and won. The continuation of the fight for those rights which are based in Human Rights and aligned with UNCRPD.
- The term “Nothing About Us Without Us” is an important foundation of any work being done that impacts any of us in the disability community.
- A short history of Veterans Affairs Canada that took seriously the needs of Veterans for well trained Specialized Service Dogs.
- The standards process was one of several research and development initiatives that VAC is funding towards their goal.
- However the agreement between VAC and the CGSB to develop standards is the only VAC initiative which seriously over reached its mandate and arbitrarily and with no authority included all Guide Dog Handlers and Service Dogs Handlers in Canada.
- The Social Policy work agreed to by many of the VAC staff and experts before the Standards Board took over never happened and a secret prescriptive medical/charity model took over.
- Standards are one possible outcome of a community development process not the starting point.
- There are many issues with the current standards process that need to be investigated and addressed.
- However the first immediate issue is to extricate and exempt all Guide Dog Handlers and Service Dog Handlers in Canada from the VAC-CGSB.
- Few in the Dog Handler community were aware of the committee’s work until the Public Comment phase of the standards in June 2017.
- The reaction was swift and negative from Guide Dog Handlers, Service Dog Handlers, Schools, Blind Persons Organizations, Disability Organizations who sent in submissions.
- The existence of the secret standards development, the implications on our lives as blind people and people with disabilities who handle dogs, has created a firestorm and recognition that we now must add yet another issue to our daily lives and fight for our rights to exist in this country without government over reach and discrimination.
- The new Department of Sport and Persons with Disabilities and the development of the CDA, gave people in the disability community hope we were finally heading in the right direction.
- The coalition was formed to fight the standards over reach and the unnecessary interference in our lives that took place in secret for 2 years.
- Many of the submissions were sent to The Prime Ministers Office, Minister Qualtrough then Minister of Sport and Persons with Disabilities, Minister Kent Hehr, then Minister of Veterans Affairs and the Minister of Public Services and Procurement who was on leave.
- Some people received form letters stating the issues that were brought forward were the responsibility of The Department of Public Services and Procurement and we were referred to this department.
- We were assured by CGSB staff and Government Officials that all of the submissions would be thoroughly reviewed and discussed by the standards committee members and appropriate measures taken in September 2017, including the exemptions called for in many submissions.
- There was much concern expressed in the submissions regarding the methods and process used by the CGSB and overwhelmingly the main agreement was to exempt all Guide Dog Handlers and Service Dog Handlers from the standards.
- Agreements made with organizations and individuals with regards to the process were not followed through on.
- One example is that Guide Dog Users of Canada attended these meetings to mitigate any harm the standards process may have on Guide Dog Handlers. The GDUC was assured that at anytime Guide Dog Handlers could decide to be exempted from the process. This has been ignored.
- The GDUC membership voted 99% to have Guide Dog Handlers exempted from the process 98% voted the standards process stopped. Yet while on the agenda, was never discussed or acted on in the September 2017 meeting.
- Further we are clear that fundamentally any work in the disability community must begin with a process aligned with the UNCRPD, that is centred in Human Rights.
- What the CGSB is attempting to do is use Human Rights terminology and tape a companion document on the back end of a secret prescriptive decision making model.
- The companion document is in no way a solution to the problem; this process overstepped its mandate. It is interfering with the Rights of Guide Dog Handlers who already work with their accredited schools through the excellent standards already set with the International Guide Dog Federation. (IGDF)
- In 2015 when this standards process started, there was no work on a Canadians with Disabilities Act. The main issue that impact Guide Dog Handlers and Service Dog Handlers including Handlers who are Veterans, is Access Rights and Choice.
- Access denials to restaurants, hotels, taxi’s that leave Handlers in the pouring rain on the curb with their dogs are on the rise.
- The only standard that is acceptable is behaviour. You can write as many standards on paper and write all the companion documents you want to. However it is us in the real world that know it’s the behaviour of us and our dogs that measures our right to be in public. If we or our dogs are misbehaving then ask us to leave. If our dogs are under control then leave us alone.
- We along with every other citizen have a right to unfettered access in public and we also have a responsibility to behave responsibly or be asked to leave.
- We believe this government is truly committed to equality and equal citizenship for people with disabilities. For Guide Dog Handlers and Service Dog Handlers in this discussion, the Government must exempt us from any more oppressive and punitive standards that continue to erode our rights.
- It should be noted that Guide Dog Schools in North America have been in operation for over 90 years for some schools like the Seeing Eye and over 75 for others like Guide Dogs for the Blind.
- The Guide Dog Handler community has grown over the past 100 years and has robust and well-managed training schools. They have well developed standards of excellence and a certified training process for most schools in the world. The International Guide Dog Federation accredits 92 schools in 34 countries. Guide Dog Handlers receive excellent training from well established schools. The standards being developed through the CGSB for Mental Health Dogs for Veterans have nothing to do with us. In fact they are counter productive and will interfere with our existing training.
- The only accreditation Board in North America, in California, is being shut down Jan 1 2018, by the State of California as being obsolete and irrelevant. They and most countries recognize IGDF certified school dogs as the standard they accept for Guide Dog Handlers living in and entering their countries.
- There are two important Human Right issues for Guide Dog Handlers and Service Dog Handlers. One is access and one is choice. This process is eroding both of those.
- Guide Dog Handlers and Service Dog Handlers including Veterans who are Dog Handlers have the Right to unfettered access equal to all Canadians. We also have to right to choose what methods, technology, mobility items we use. We have the rights and our dogs are our choice just like a cane or wheelchair is.
- However Guide Dog Handlers and Service Dog Handlers are the most publically scrutinized, access denied and government over regulated of any citizen in Canada. This VAC-CHSB standards exercise has taking great liberties over our liberty.
- Representatives expressed their experiences with the BC law and the over reach and two tier system. The amount of harassment and denying of access rights to public spaces and taxi refusals have increased exponentially since passing of the BC law.
- Representatives shared their shock at this surprize set of un-necessary un-needed standards. We are working on removing barriers and these standards will build more barriers.
- One person stated that he started using Guide Dogs 50 years ago when there were no laws and it was much easier to be in public as Guide Dog Handlers were well trained and their dogs well behaved. This is still the situation today. However with all the bureaucratic red tape access rights are worse than ever.
- One important issue to be looked at is that VAC should increase training capacity in existing schools for mental health dogs and for the many Veterans that require dogs that are cross trained dogs for other disabilities as well. This will improve access for all Canadians.
- These schools are certified with Assistance Dogs International. ADI
- This standard will make it more difficult for Veterans as we have found in the BC experience in the Guide Dog and Service Dog legislation making our lives more difficult.
- Even this standard being talked about is already causing problems for us in terms of people with Guide Dogs in travel and in Provinces looking for an easy cheap way to slap together regulations into law without thinking of the Human Rights implications or including us.
- The standards process using non disclosure agreements is something they do when dealing with patents and does not fit for us.
- An exemption for Guide Dog Handlers is the only way out. People have long relationships with their schools and they receive excellent training from them. There is no reason for the government bureaucrats to overstep their authority and pull us into this mess. These standards interfere with well established training.
- The final point is we fully expect the Government of Canada to stop this inappropriate method of developing Social Policy and listen and work with us to fully realize the implementation of the UNCRPD. The first step to that end is the exemption from these VAC-CGSB standards.
Department of Public Services and Procurement
Assistant Deputy Minister, Tammy LaBelle
Nicholas Trudel, Senior Director for Public Services and Procurement,
Jacqueline Jodoin, Senior Director of the Canadian Standards Board
Nicholas Kang and AJ Cheema, Senior Advisors to Minister Qualtrough.
Guide Dog Handler and Service Dog Handler Coalition
Mary Ellen Gabias
Dr. Susan Hardie