This is GDUC’s first real attempt to escalate its position against the proposed Standard, with a great deal more to come in the near future.
What follows is the text of a letter sent to Carla Qualtrough, Minister of Public Services and Procurement. Minister Qualtrough has overall responsibility for the CGSB.
It was also sent under cover to:
- Prime Minister Trudeau
- Minister of Justice and Attorney General of Canada, Jody Wilson-Raybould
- Minister of Veterans Affairs Canada and Associate Minister of National Defense, Seamus O’Regan
- Minister of Sport and Persons with disabilities, Kirsty Duncan
- Contacts at both the Canadian Human Rights Commission, and
- Minister Qualtrough’s office
Body of Letter
January 29, 2018
Dear Honourable Minister,
Guide Dog Users of Canada is a registered charity focusing on upholding the rights of guide dog handlers, and providing education to the general public. Since 2015, we have been represented on the Canadian General Standards Board Technical Committee responsible for the development of a national voluntary standard on service dog teams. Unfortunately, after being involved with this project for 2 and a half years, we now come to you with some extremely serious concerns on which we would be pleased to elaborate at the earliest opportunity.
Essentially we feel that the project has gone completely off track. Although it may be rare for a minister to intervene in such matters, we believe that if you fail to do so, the resulting standard will represent a giant step backwards for those of us who use guide or service dogs to mitigate aspects of our disabilities.
Prior to the commencement of the project, the CGSB concerned itself with the development of standards pertinent to consumer and industrial products. Consequently, we believe that its processes, procedures, and overall way of operating are not well suited to tackle a standard involving sentient beings, E.G., guide or service dogs and their human partners.
Numerous comments received during the public review phase revealed that the CGSB failed to address human rights considerations in the draft standard. It is our understanding that corrective action is being taken, but we have reason to believe that those efforts may be too little, too late. If in fact it is really necessary to regulate the performance of guide and service dog teams, we feel, on balance, that a social policy process will better uphold human rights.
At the outset, the project was funded by a contract between Veterans Affairs Canada and the CGSB to develop a standard relevant only to PTSD service dog teams. In July 2015, the TC decided to expand the scope of the standard to include all types of service dogs, including guide dogs. GDUC did support that decision, based on an agreement with our representative that we could later call for an exemption of guide dog teams if the standard did not address our unique needs. We’re now at that point, but our efforts to obtain an exemption for guide dog teams are being stonewalled by the CGSB at every turn. We now believe that the TC lacked the authority to alter the scope of the standard in the first place, and request that you intervene in order to bring the focus of the standard in line with the terms of the original contract. Without intervention, the standard is on the path of becoming a one-size-fits-all solution for guide and service dog teams that may well create more problems than it will solve.
The International Guide Dog Federation, IGDF, has 92 member schools in 30 countries. Since 1929, when The Seeing Eye was established in New Jersey, IGDF schools have been producing high quality guide dog teams which are “both safe in, and safe to the public.” Its internal standards are more than sufficient to ensure the production of successful teams, which now serve as benchmarks for the training of other types of service dogs. The CGSB refuses to acknowledge or recognize the IGDF’s excellent track record, which we believe is more than adequate to justify an outright exemption of guide dog teams from the standard. Instead, the CGSB appears bent on offering a vague equivalency in place of an exemption, the details of which remain cloaked in secrecy.
The CGSB’s insistence on non-disclosure agreements served to keep the guide and service dog communities at large in the dark, and resulted in considerable shock and outrage when those communities learned that not only such a standard was under consideration, but that it was being developed entirely without their input.
The public review phase of the project began in May 2017, but the CGSB failed to make the review materials accessible to users of assistive technology. While the CGSB did rectify its mistake, it did so 3 weeks later, but not without considerable prodding on the part of GDUC and other like-minded organizations. Add to this situation, the unfriendly and rigid nature of the feedback mechanism itself, and you have a recipe for intense frustration.
There was an additional, serious problem with the public review draft. That draft mysteriously lacked some critical material pertinent to guide dog teams which clearly demonstrated crucial differences in the way they work as compared to their service dog team peers. This material was part of the previous draft, and despite numerous requests, the CGSB has failed to provide an explanation as to why it was removed. In addition, the draft standard imposes a number of conditions on us that are totally unacceptable, one of which is that we be able to set broken bones. Surely a common sense based approach to medical situations, involving appropriate engagement of a veterinarian, is a better way to proceed.
In conclusion, any one of our concerns is more than sufficient cause for alarm, but taken in combination, we believe that if the project is allowed to continue on its present course, the results will be disastrous for users of guide and service dogs. Our members are in full agreement. In a recent poll, 98% of them said that GDUC should vote against the standard, while 96% supported a complete exemption of guide dog teams trained by IGDF member schools. We find that the CGSB is not conducting itself in a fair and transparent manner, and appears to be pressing for completion of the standard with little or no regard for those who will be most affected by its implementation.
Thank you for taking into consideration this extremely complex situation, and I look forward to hearing from you.
President, Guide Dog Users of Canada
It is our understanding that the public draft standard underwent significant revisions as a result of feedback received from stakeholders. We believe that those changes will make the second public draft standard more generic, causing it to be even more dangerous to us than the first. We think that the second public review phase will commence in March.
What I can promise at this point is that GDUC will continue to do everything in its power, and I mean everything, to ensure that, at a minimum, guide dog teams trained by IGDF member schools get the exemption we so richly deserve. We may well go further depending upon the overall climate in terms of upholding our human rights. While human rights are not one of our core skillsets, we are receiving sage advice from those whose business it is.
Our working group in terms of combatting the standard is comprised of Christine Switzer, Alan Conway, and yours truly. Christine’s husband Joe, despite the fact that he is battling leukemia, has made himself available to support us, for which we express our deepest appreciation. Not only do we work extremely well together, but we have the ability to reach out to those who have special expertise on any given aspect of the standard. All of us have, and will continue to put tremendous energy into advocacy efforts, and our collective investment with regard to time is literally off the charts. Simply stated, we’re fighting for the future of all Canadian guide dog handlers, which is not a responsibility we take lightly.