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National Coalition of People who use Guide and Service Dogs in Canada, May 10 Conference Call Minutes

Coalition Chair Yvonne Peters opened the meeting and thanked CFB for use of their Conference Call line.

Yvonne recalled the First Coalition Conference Call on July 5, 2017, organized by Tom Dekker and Albert Ruel at GTT. It brought together people from across the country who were very alarmed at the National Standards that were put out for public review.

Agenda

  • Debriefing regarding the withdrawal of the Canadian General Standards Board , CGSB, in continuing with the writing of Standards
  • Future steps of the Coalition
  • Ideas

Yvonne explained the coalition had started 10 months ago after finding out the Federal Government was developing standards that would impact al of us who use Guide Dogs and Service Dogs in Canada in a negative way. We all agreed to stop the CGSB standards process.  The standards development started with Veterans Affairs wanting to develop standards for psychiatric dogs for Veterans and they contracted with the CGSB to do this in early 2015.. The CGSB has their own methods and process, none of which is based in Human Rights. It is based on development of industry standards like wiring and flame retardant.  The process quickly morphed into a secret behind the scenes working group under the CGSB for two years, that had decided to include all Guide Dogs and Service Dogs in Canada without any discussion, consultation or consent of the people impacted.  They put the standards they had developed up for public review in May 2017, which was the first time most of us had heard about them, hence the start of the coalition to stop them.

Yvonne gave a huge thank you to everyone who devoted their time to write responses to the standards, write and meet with their MP’s, write the Ministers and the Prime Ministers, set up the social media campaign with a blog and facebook page, set up the email list, do the research and write a major report, get information through the freedom of information act, everyone who stay connected with each other, met with the Canadian Human Rights Commission, the Assistant Deputy Minister of Procurement and everyone who participated in the list to further develop strategies and evoke discussion.  All of us came together and were laser focused on the task to stop the standards. Here we are 10 months later with the CGSB ending their process and we believe that Veterans Affairs is going back to their original mandate to develop standards for dogs specifically trained for Veterans.

Opened a debrief of what happened over the past 10 months. Lessons learned, comments, etc.

  • Report from Jim Bergeron about his meeting with his MP. The MP stated, after investigation, that it appears the CGSB did not have the appropriate mechanism to develop these types of standards. He also brought up the issue of jurisdiction and that Veterans Affairs was within their right to make standards for dogs for Veterans.  Jim stated he cannot confirm the CGSB would not be involved in the issues of standards regarding PTSD dog standards for Veterans; however, it is his understanding that all Service Dogs and Guide Dogs in Canada are no longer being included, only Veterans dogs.
  • Christine Switzer is hearing there is some push back to the decision to not include all Service Dogs in Canada. However, this is only from one or two people. Some people are looking at quality assurance rather than standards.
  • Alan Conway is very pleased this has happened and thanked everyone for putting so much energy into stepping up and stopping this.
  • Susan Hardie wanted to thank the group for welcoming her as a Service Dog user in the coalition and this has made the journey much easier.

Next Steps

Yvonne brought forward the issues that are still outstanding for all Service Dog users in Canada. Regardless of the Federal Standards being withdrawn. The main issue being Access Rights.

Many are stating they feel the coalition should continue. Yvonne felt we have operated rather well as a grass roots informal structure, especially since we have no resources. She did not think we could go on forever that way, and we need to think about how the coalition could continue and evolve without losing its grassroots strength.

Question: are people happy and want the coalition to continue?

Answer: The response was a resounding and unanimous yes!

Yvonne then described two possible structures:

  • One is the more formal one setting up a non profit, have an elected Board, bylaws and starting yet another organisation where much of the energy and resources would be siphoned off to maintain the organization itself. Book keeping, audit reports, etc. This could interfere with the way the coalition has worked successfully so far as a loose structure with individual commitment of time and work as people can give it.
  • The second is for the Coalition to consider seriously, instead go under the Umbrella of another organization with credibility, equipped to offer structure and support and not interfere with the goals of the Coalition. This would allow us to apply for funds through the Umbrella Organization and also utilize their expertise. Susan Hardie, the Executive Director of the Canadian Centre of Disability Studies, CCDS has offered to have the Coalition work under their umbrella as a Community of Practice. The coalition would continue as it is now making our own decisions. The benefits would assist us with research, apply for resources as needed and allow us to continue making decisions the way we are currently doing. It would give us some time to develop our own credibility.

Susan gave an overview of the work the CCDS is doing. Since she joined in 2014, they have been restructuring and are now   operationalizing becoming a hub of knowledge in the area of disability issues. They are increasingly serving a role of facilitator for research, education and development  which supports community mobilization.

As we are growing in our strategic plan we are looking at our ability to support community practice which is used a lot in professional circles. It is also a way to support people with shared interests. CCDS role would be to work with the Coalition around the three areas of  research, education and development assisting to identify the needs of the community towards their stated goal.

Yvonne explained one of the ways we would develop our relationship between the Coalition and the CCDS is through a memorandum of understanding, MOU. It would be an agreement on how we would work together, so we retain who we are and how we do things.  Susan stated she would like it to be a partnership between CCDS and the Coalition. The link to the website is www.disabilitystudies.ca

Questions and Answers regarding being under the CCDS umbrella

  • Question: Would we be under the CCDS umbrella and still maintain our independence and be partners with CCDS?

Answer: Yes The CCDS and the Coalition would negotiate things like the number of conference calls, webinars, research topics, level of staff time to support the coalition in areas like applying for funding to support the work of the Coalition. This would be done after the MOU is signed and as work of the Coalition develops. The hope would be to have the work of the Coalition supported through ongoing funding in the CCDS strategic plan.

  • Question: Do you have other partnerships similar to this proposed one?

Answer: Yes CCDS is working with another organization and are developing a joint research plan. It is working out very well.

  • Question: How would an MOU with an informal grass roots group work? Who would sign on behalf of the group?

Answer: In the past groups such as ours, have decided on a designated Representative or Chair to sign. The Coalition could also discuss and decide on  a small team of people who all sign on behalf of the bigger group. There is always an element of trust and the Coalition would need to review any proposed MOU and then appoint one or several representatives to sign and be responsible to report back to the entire Coalition.

  • Question: Who does CCDS report to, how is it structured.

  • Answer: Originally CCDS started as a Manitoba Incorporation, then in 2004 became a National Organization, became Federally incorporated as a Charity with corporate status in both Manitoba and Ontario. The goal is to have the hub in Manitoba and have the spokes increasingly have a presence in with working with organizations across the country. Susan listed several organizations they have partnerships with.
  • Question: How does CCDS work. Are they research based and are they centred around colleges and universities?

  • Answer: Our structure is unique in that CCDS is a community based organization which is University affiliated. We are structured to work with Canadian groups in the disability sector specifically around best evidence. We have been approached by Community Living groups, disability specific groups to support research and program development. Whatever the community needs, we try and address those needs.
  • Question: Is there some kind of timeline for how long the agreement/MOU would be?
  • Answer: With other organizations we committed to the first year then revisit the MOU every year andlook at where the organization is at and what where they want to go in the future, This also allows the work of the organization to be built into the CCDS operational plan. Our best practise is to keep the communication up and have an ongoing dialogue to ensure we can support the organization throughout the year.
  • Question: I looked at your website and was very impressed. As our fight is steeped in Human Rights, what is your relationship with the UNCRPD should we need more support in that area.

  • Answer: Susan thanked them for looking at the website, which is becoming bi-lingual. The CCDS just hired a new staff member who along with another staff member will be attending the CRPD meeting in June. We are on the UNCRPD and we are a rep on the International Committee. We have historic and current knowledge on the UNCRPD and can be helpful in that area.  CCSD was involved in the writing of the UNCRPD
  • Question: Is there any limitations on our activities going under the umbrella of CCDS like our advocacy work.

Answer: CCDS will continue to work with organizations to co-create best evidence briefs to be used to improve the lives of people using guide and service dogs.  Susan promised to follow up with CCDS lawyer who advised the inclusion of statement that CCDS and The Coalition can work on areas of research, education and development with indication that CCDS can not pursue pure advocacy work with The Coalition. Thus, there are limits regarding advocacy on what CCDS can do as it is a charitable organization, but this limit is not imposed on The Coalition.  Susan shared she likes to think about what is needed to advance work, someone working within systems (which means there will be limits in area of advocacy such as CCDS which is a charity) and others outside of systems (without limits of advocacy).  Together these groups can make a difference as it is Susan’s sense you need both for real change (Please note this reflects Susan’s theory of change).

Comments made about going under CCDS umbrella

  • It is an interesting idea and certainly having been involved with setting up organizations, the amount of paperwork load and reporting to Revenue Canada is over whelming and it can really interfere with the amount of time available to do the actual work you wanted to do in the first place. This would allow us to actually do the work needed. I agree with this idea.
  • Others stated their agreement with this partnership as we do not have to do all the paperwork in a formal structure and as we do not know how long the coalition’s work will take.This supports individuals to be as active as they can when they can and contribute their skills and time as they can.
  • Doing it this way also supports working together with the already existing Rights Holder run Organizations and they can support the Coalitions specific goals without interfering with their specific mandates.
  • Having all of our organizations working together in support of one another will make us all stronger and our voices louder.
  • Another person commented he really liked the idea of going under the umbrella of the CCDS and liked the structure and fully supports the coalition going under it . He also wanted to commend Tom Dekker and Yvonne Peters on the Jonathan Mosen Blindside podcast interview.

Yvonne asked if there are any objections into developing a draft MOU to come back to the group.  All agreed to go ahead and draft the MOU between the Coalition and the CCDS.

Future Work

  • Continue to write our MPs, thank them for listening and any their support in how things worked out.
  • Keep our ears peeled to what the governments next steps will be now that the CGSB has withdrawn from the standards .
  • Tell our MP’s not to let any next moves on any standards must be with handlers and must be based in Human Rights
  • We need to keep the pressure on.
  • The PILC (Public Interest Law Centre in Manitoba) in follow up to our meeting last fall, has agreed to take on the Coalition as a client and is developing an opinion regarding the Human Rights aspects and the Equality aspects of the different Federal and Provincial laws and standards introducing measures like registration and carding and how that may create more barriers than support enhancing equality and access rights.
  • Another initiative is some of us have been invited to present at the CASHRA Conference (the Canadian Association of Statutory Human Rights Association) Conference in June. This will give us an opportunity to wake up Human Rights Commissions to areas where legislation is being introduced that has a potential discriminatory impact, they should  be the first ones there doing the shouting. Hopefully we can get Human Rights Commissions engaged.

Other ideas

  • The Canadian Transportation Agency is looking at mobility devices and can we as a Coalition look at transportation issues both Federally and Provincially. Tom brought up an issue where a bus company demanded his BC Certification number for his Guide Dog before he could get a reservation. There is national disability groups who attend consultations and its time that Service and Guide Dog Handlers have our own voice.  Marcia has agreed to follow up in the CTA meeting in June.
  • Yvonne felt in all these types of areas do need addressing and that its time for Guide Dog users and Service Dog users are representing themselves on these committees or any other issues that impact us and not in a token way.
  • Richard Marion brought up correspondence from the European Guide Dog Association that was passed onto Heather and Yvonne. He stated there is a move Internationally to look at agreeing to ISO (International Standards Association, which Canada is a voting member) standards for the IGDF (International Guide Dog Federation which accredits most of the Guide Dog Schools in the world) and ADI (Assistance Dog International which accredits many of the Service Dog Schools worldwide) and it appears that Canada has withdrawn from the idea at this time. Heather stated that she is following up both with the European Group and with Paul Metcalf at the IGDF. There is definitely much International work going on related to standards and it would be good to get that information and understand what is happening. Our understanding is important.
  • We are tracking what is happening provincially with standards.
  • There is a lot going on and we are in response mode and we need as we get involved in anything, we need to figure out what we want. We are not yet exactly clear on what we want to have happen. We know any approach will be steeped in Human Rights and what does that mean? It is important to develop a process where we define for ourselves what a Human Rights approach means and when we are involved in various areas, what are our positions. We are clear generally what it is we want to accomplish, however we need to work together in many areas toget down to specifics.
  • Lets ensure we pump up our social media work and tell our story and ensure we have a history. A small team of coalition members are working on this. Anything people feel could go on the blog, please send to info@hooh.ca. More information to come.
  • A new member said she is very happy to meet all of us and wanted us to know she will be becoming a new Guide Dog user soon and believes in the work we are doing and she will do what she can to support the work of the Coalition.
  • There was some discussion on forced registration and government sanctioned stops and carding like in BC and the difference between an identification card In Ontario that was never designed to be used to card people before they were allowed in public spaces. It was to empower people that if they could not educate the person as a last resort they could use their card.
  • Good points were made by a new member who was denied a taxi while on her way to a radio interview to celebrate International Guide Dog Day. She is very impressed by the coalition and feels the transportation issues are very important to work on. She wants to know how we can work together to deal with these transportation issues. A coalition member will speak with her to discuss this further.
  • A point was raised that everything we are talking about is about access rights. We should be turning all our attention at that and not always reacting to standards,  and every other new scheme the Governments come up with. We need reinforce our rights as full citizens.
  • One member would like to see come out of the group is a piece of model legislation for guide/service animals that could be promoted by this group.  If government cannot get it right, let’s provide them with an example of what we, the users, feel should be included to promote our use of service animals and protect our rights from those who may abuse them. While the focus needs to be on promoting our rights, we still need to include strong punishments for those who may/will abuse those rights.
  • We need to prioritize what we can do and this list is important.

Yvonne closed the meeting by thanking everyone for working through the past 10 months and is looking forward to all of our continued work on these issues.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Air Passenger Protection Regulations – Consultation Paper

Several sources provided the Coalition with the following information:

On May 23rd, the Transportation Modernization Act received royal assent. Among other things, it “…mandates the Canadian Transportation Agency to develop regulations for airlines’ obligations to air passengers”. On the following CTA webpage titled Air Passenger Protections, the CTA launched a consultation and it outlines a few different ways to provide input.

While the Act did not specifically mention the rights of persons with disabilities, when the Senate passed the bill the sponsoring Senator made the following remarks: “The committee heard witnesses from the Canadian National Institute for the Blind and the Council of Canadians with Disabilities who discussed the barriers that people with disabilities face when accessing air transportation services. For example, people with disabilities may face particular challenges with long tarmac delays as well as with the carriage of their mobility equipment and service animals. The committee would therefore encourage the Canadian Transportation Agency to include stakeholders representing people with disabilities in its public consultations regarding the development of regulations to implement an air passenger bill of rights.”

Click here to read the consultation paper on air passenger protection regulations.

These consultations are open until the end of August.

CGSB Technical Committee Interim Report and GDUC Response, February 2108

Here is the interim report issued by the project’s Technical Committee co-chairs on Friday, February 2.  The report was circulated widely and we are working to determine exactly who received a copy.  Following that is our response, which was also sent under cover to a number of Cabinet Ministers, the PM, and contacts at both the CHRC and Public Services and Procurement.  We’ll have more to say about the implications of the report in the not-too-distant future.

Interim Report

January 31, 2018

CGSB Service Dog Standard Technical Committee – Interim Report

This report was developed to inform interested parties at the federal government level of the progress of the work being done by the Canadian General Standards Board (CGSB) and the CGSB Committee on Service Dogs that is developing a National Standard of Canada for Service Dog Teams.

Purpose of this Standard

To establish criteria and best practices, roles, responsibilities and expectations around the production and use of Service Dogs, with the goal of promoting barrier free access for Service Dog teams while ensuring the safety of both the user and the general public.

Users of this Standard

  • Government – To provide all levels of government with a consensus-based National Standard that reflects industry norms and best practices, with the goal of promoting consistency and equality in regulation across Canada.
  • Industry – To promote informed and inclusive policy development for agencies and businesses that creates shared values and expectations for industry and Service Dog users and transcend provincial boundaries.
  • Users of Service Dogs – To promote and support the development of regulation and policies that will:

1) inform and protect those with disabilities seeking service dogs from providers that are fraudulent or act in ways that worsen their disability and

2) enhance accessibility and inclusion across provincial barriers for Service Dog users.

Establishment of the Committee

  • CGSB was contacted by the Department of National Defense, Veterans Affairs Canada and the Canadian Foundation for Animal Assisted Support Services to develop a National Standard of Canada for Service Dogs.
  • CGSB was provided with names of stakeholders that were invited to form the Technical Committee (TC).

o Other interested parties also proactively contacted CGSB and they were offered to join the Committee.

o CGSB to date has not refused membership to any interested stakeholders that meet CGSB Policy and Procedure requirements.

o CGSB continues to add members to the Technical Committee based on any gaps that arise in membership.

  • Using CGSB Policy and Procedures, a Technical Committee was created that was determined to be fair, balanced and reflecting the needs of producers, users, general interests and regulators.

Mandate of the Committee

  • The Committee was tasked with the mandate to create a National Standard of Canada for Service Dog Teams.

Selection of Co-Chairs

  • It is customary for Technical Committees to only have one Chair, but in this situation, CGSB recognized there were diverse opinions in the industry and on the Technical Committee regarding Service Dog Standards. A well-rounded approach for the leadership of the Committee was sought and a call for nominations of Co-Chairs was distributed.
  • Members were nominated for the Co-Chair positions and the Committee held a vote. Following CGSB Policy and Procedures and based on the ballot results, Kristine Aanderson and Danielle Forbes were elected as Co-Chairs.

Terms of Reference

  • The Scope of work for the Technical Committee was determined at the first meeting held in October 2015. It included: definition and use of the term disability/user of a service dog, development of a standard that will enable freedom of movement and safe access in society and inclusion of provisions for the welfare of the service dog.
  • At this meeting, the outline for the Scope of the Standard was also determined by the Technical Committee. The definition of the term “Service Dog” voted on by the Committee included both Service Dogs and Guide Dog Teams, and unanimity was achieved (including members representing Guide Dog training organizations and Guide Dog User Groups). This decision is evidenced in the formal meeting Minutes.

Program of Work

  • At the first meeting in October, 2015, the technical committee members were informed of the need to maintain confidentiality of the proceedings from the general public, but were strongly encouraged to ensure that the members and stakeholders of their organizations were well informed of the proceedings and given opportunities to bring forward ideas, questions or concerns during the process. This was done to ensure that more than two years was given for the members and stakeholders to actively participate in the standard development process prior to the publication of the standard.
  • Also at the first meeting, Working Groups were formed to develop specific content for the draft Standard. These Working Groups developed definitions using existing industry standards to create a framework for discussion, and developed an informative appendix which addressed the care and training of service dogs.
  • These Working Groups were given a number of months to develop their documents and these documents were sent to the Committee prior to meeting to ensure all Committee members had time to review the work and contribute their input.
  • The Working Group documents were discussed during various subsequent Committee meetings in Ottawa/Gatineau and a draft standard was developed using the consensus-based approach.
  • Consensus on the draft Standard was reached in Spring 2017, and the draft was posted for a 60-day Public Review period. There was a significant number of comments received, totally approximately 600 pages. Every public comment was distributed to Committee members for review and then discussed at the meeting in September 2017. Relevant changes were made to the draft during the meeting to address the comments and strengthen the draft Standard.

Meetings

  • Six meetings have taken place in Ottawa/Gatineau since October 2015.
  • At each of the meetings, extra time/attention was given to the issues of:

disability sensitivity,

taking steps so committee members would feel safe in the meeting space,

ensuring the process follows CGSB Policy and Procedures,

providing time for input from the Committee members at all stages of standards development and achieving consensus on all sensitive topics before progressing.

  • A small number of committee members felt that they could not participate in select meetings for personal reasons and could not communicate a solution to their concerns to the co-chairs. Their lack of participation in multiple days of the meetings made it difficult to include their voices in discussions, but any written material they had provided was read to the committee in their absence.
  • To ensure that all voices are given an opportunity to be heard during the entire process, the co-chairs have made themselves available outside of the committee meetings to members of the committee and to public interest groups. Many meetings have occurred this way, including multiple occasions where co-chairs have abbreviated vacations to address matters individuals felt needed to be addressed immediately.

Points of Consensus

  • Points of consensus

o The need for a Service Dog handler to meet minimum requirements to ensure the safety of the public and the wellbeing of the service dog.

o The need of the Service Dog to meet minimum requirements of temperament, ability to work and physical health.

o The need of the Service Dog Team to be well matched to meet the needs of the user and the dog.

  • Points with vigorous discussion, but ultimately achieving consensus

o Definition of Disability

  • Discussion was had that using a Social Model of Disability would be best, however members of the Committee raised concerns that this could provide barriers for regulators in implementing the Standard, as it was more advanced than much of what currently exists in Canada. A decision was reached to use language reflecting the Social Model of Disability but include requirements to ensure an individual with a disability would qualify under existing Canadian regulations.

o Hierarchy of disabilities

  • There was a spirited debate during the fall 2017 meeting regarding the question of ‘Should all disabilities be treated equally under the standard, or should some disabilities be given priority status for non-disability-accommodation based reasons?’ It was noted by the committee that the standard should allow individuals to be able to meet the standard with accommodations for their specific disability, but that no disability or disability group should be given exemption from adhering to a standard based on history or perceived status of the disability. It was consensus of the committee that all disabilities should be treated equally by this standard.

o Inclusion of Guide Dogs in the Standard

  • Concern was raised from the Guide Dog Community that this Standard would cause additional hardship for Guide Dog handlers. This was the topic of much discussion and thorough consideration by the Committee. Through discussion, elements were added to the draft to ensure that there would be no additional hardships or restrictions on Guide Dog handlers above what is already required of them by International Guide Dog Federation accredited training schools where they obtained their Guide Dogs.
  • The International Guide Dog Federation (IGDF) board member who is on the Technical Committee fully supports the inclusion of guide dogs in this standard. He believes that this standard is needed to support and protect guide dog users, while not adding any additional hardship for IGDF teams.

o Equivalency

  • There is a strong desire on the Committee for the Standard to outline the service dog training schools or organizations that already have industry standards that are equivalent to the proposed National Standard. Through rigorous discussion, it was determined that any equivalency would need to ensure the organization has oversight and a commitment to fair and equitable treatment of Canadians with Disabilities and the inclusion of accepted best-practice standards for the welfare of the service dogs.
  • Much of the miscommunication that exists currently with concerned stakeholders is surrounding the issue of equivalency for existing certified dogs. It is noteworthy that National Standards cannot make statements to determine what an equivalency may be. This is the role of a regulatory body (ie. the provinces, Veterans Affairs, Transport Canada etc..). The National Standard will establish its own set of criteria and any equivalencies will be determined as the implementation in Canada occurs. The Committee has, however, undertaken to help offer guidance and support on this matter and create a companion document to the National Standard that will explain to regulatory bodies that there may be other equivalencies (industry standards), and that the intention is not to have any current re-testing, re-certification or changes in any way to existing certified dogs.
  • It is important to note that the draft standard is comprised of current industry-based standards for service dog teams. There are no elements in the standard that would cause a current working service dog team from an accredited service or guide dog school to have to complete additional steps in order to be in conformance with the standard.

o Humane treatment of Service Dogs

  • There was a general consensus on acceptable methods of the treatment of Service Dogs, but a vocal minority initiated spirited discussion, arguing that methods and devices that have a high potential to cause the service dog pain should be allowed in the standard. The Committee was able to achieve consensus (but not unanimity) on the concept that the Service Dog shall be treated in a humane manner that does not cause them fear, distress or pain. This included a prohibition in the Standard on certain types of equipment, such as collars delivering electrical current or shock to the skin of the dog or using metal points/prongs on the dog’s neck. This is consistent with the position of the Canadian Veterinary Medical Association.

Public Comment

  • The first draft of the National Standard was available for a Public Review period of 74 days from May 2, 2017 to July 14, 2017. Over 600 pages of public comments were received during this process. The Co-Chairs carefully examined every comment submitted and a copy of all comments was provided to the Technical Committee prior to the September 2017 meeting. Comments were reviewed and discussed by the Committee at this 2017 meeting to ensure all concerns and viewpoints were addressed.
  • During the Public Review Period, concern regarding accessibility for visually impaired Canadians was identified, so additional time and resources were quickly provided to ensure the voices of all Canadians were heard.
  • The comments received from the Public Review Period can be grouped into four types:
  • Praise for the Standard

o Positive comments were received indicating:

  • There is a strong need for this Standard
  • The direction of the Committee is positive
  • This draft Standard does a good job of balancing the needs of the Service Dog users, the public and the welfare of the Service Dog
  • Many Canadians are eagerly awaiting the publishing of this new Standard as it will enhance their daily lives
  • Concerns related to misunderstandings

o Many comments that raised significant concern about the draft Standard were rooted in misunderstandings and fear about what the Standard would mean for their daily lives. Examples of this included concern from Guide Dog Users that this Standard would result in:

  • Requirements for Guide Dog users to complete additional certification steps after being paired with their Guide Dog from an accredited school (which it would not)
  • Accredited U.S. Guide Dog schools would no longer support placing dogs in Canada (which it would not, as confirmed by a board member of the International Guide Dog Federation)

o As a result of the number of comments based on stakeholder misunderstandings of the draft Standard, the Technical Committee is developing a companion document to accompany the Standard to provide the information needed.

  • Personal Opinions

o There are many issues related to disabilities and Service Dogs that Canadians have a variety of personal opinions on. The opinions reflected in the comments were not unanimous on any subject and they mainly reflected the viewpoints raised during discussions had by the Technical Committee during the development of the standard, prior to achieving consensus on these issues. During the Public Review Period, some Canadians also shared their negative personal experiences under current frameworks and fears of ‘losing their dogs’ should an overly restrictive standard be implemented.

  • Concerns resulting in changes to the draft Standard

o Overly Intrusive

  • Many comments noted that some individual points of the Standard were too intrusive and should be removed. These included specific requirements on the food, grooming and other care elements for the Service Dog.
  • Intrusive elements were unanimously removed during the September 2017 Committee meeting.

o Overly Prescriptive

  • Many comments indicated that there were individual points of the Standard that were too prescriptive regarding how the Service Dog should be cared for. An example of this was the requirement for all Service Dog Handlers to have formal canine first aid training.
  • Overly prescriptive elements were unanimously removed during the September 2017 Committee meeting.

o Overly specific

  • Some comments noted that certain definitions were too specific and resulted in a lack of clarity on larger definitions. An example is the definition of “Service Dog Teams” (where the person with the disability does not have care and control of the service dog, ie. an Autism Service Dog for use by a child)
  • Overly specific elements were changed at the September 2017 Committee meeting to make them broader, more easily understood and more user friendly.

Next Steps

In order to meet the needs of Canadians to develop a National Standard of Canada, the Technical Committee will complete the following steps.

  • Complete the ‘companion document’ to ensure the Standard is easy for Canadians to use and avoid misunderstandings in the future.
  • Complete a second Public Review Period (according to CGSB Policy and Procedures) to ensure the voices of Canadians are heard.
  • These comments from the second Public Review Period will then be taken to the Committee and any changes to the Standard deemed relevant will be made.
  • Once there is consensus on the Committee, a formal ballot will be held and if consensus is reached on the ballot, the Standard will be published. While it is not possible to achieve unanimity on all issues contained in the Standard, consensus with Service Dog producers, users, general interests and regulators has been achieved at each stage of standards development process. It is worth noting that as Co-Chairs and long-standing industry stakeholders ourselves, we are aware of the many divergent opinions that exist surrounding Service and Guide Dogs from a variety of different groups. We are also aware that to date, there has been some dissatisfaction expressed by certain special interest groups pertaining to the development of a National Standard. Some of these groups are simply fearful of the unknown and do not understand how or if this Standard will affect them. We are trying to dispel these fears by working with these groups and regulators to let them know that there is no intention to disrupt currently certified Service Dog or Guide Dog teams in Canada. Others are groups that do not agree with the best practices currently in existence in the industry and appear to be trying to further a Standard that is in the best interest of their organization(s), rather than the best interests of Canadians. These groups have questioned the CGSB process and consensus-based Committee decisions. We feel confident that while they may have differing viewpoints, that their voices have been heard and the consensus-based process has been followed. The majority of the members of this committee have communicated that they are happy with the process and progress of this Standard. In the opinions as Co-Chairs, all indications have pointed to CGSB representatives adhering to CGSB Policy and Procedures. We have ensured that ample time has been given for discussion during meetings with members of the Committee and consensus has been achieved during discussion of sensitive topics. We also have made ourselves available outside of the meetings for any Committee members or stakeholders to ensure that they feel their voices are heard. It is our opinion that the best interests of Canadians are being served by the development of this Standard. As Co-Chairs, we look forward to working together with members of the Technical Committee and stakeholders to continue to move this Standard forward, reduce misunderstandings and help all Canadians with disabilities to live beyond the boundaries, with the assistance of their talented Service Dogs. The Co-Chairs would like to offer the opportunity to any interested members of federal government or Crown Corporation to meet with us to ask any questions that they may have regarding the Technical Committee, the processes up to this point or future directions. We thank our Federal Partners for their interest and support. We look forward for the opportunity for discussion before presentation of our final report.

Sincerely,

Kristine Aanderson

Co-Chair – CGSB Technical Committee on Service Dog Standards

Registered Psychologist

Kristine Aanderson Consulting Services

Danielle Forbes

Co-Chair – CGSB Technical Committee on Service Dog Standards

Executive Director, National Service Dogs

 

GDUC’s Response

Alan Wickham

Specialized Services Sector

Integrated Services Branch

Public Services and Procurement

Via email: alan.wickham@tpsgc-pwgsc.gc.ca

 

February 7, 2018

Dear Mr. Wickham,

The interim report prepared by the co-chairs of the Canadian General Standards Board Technical Committee tasked with the development of a voluntary national standard on the performance of service dog teams is an attempt to paint a rosy picture of a project which has developed serious shortcomings.  Those who read it may well be lulled into a false sense of security concerning the project’s supposed positive progress.  As a member of the TC, GDUC holds a dissenting view, and feels that it has a moral obligation to Canadian guide dog handlers to provide its perspective.

The decision to elect TC co-chairs was based on the CGSB’s recognition of diverse opinions in the service dog arena, and on the TC regarding service dog standards.  In point of fact, the co-chairs are both affiliated with Assistance Dogs International as service dog producers, and thus cannot, and do not represent divergent opinions.

We call into question the Terms of Reference of the standard as stated in the interim report.  If in fact the CGSB is under contract to Veterans Affairs Canada to develop a voluntary national standard for PTSD dogs, on what authority did the TC decide to create a definition of service dogs that would ultimately determine which types of service dogs would, and which types of service dogs would not, be included in the standard?  GDUC, as the only organization at the table representing Canadian guide dog handlers, did, albeit with reluctance, support the expanded definition, but did so based on an agreement with our TC rep at the time that we could later call for an exemption of guide dogs if we believed that the standard did not address our unique needs.  We are now at that point, but our efforts to obtain the exemption are being stonewalled at every turn by means of diverse tactics and arguments, the latest being “that no disability or disability group should be given exemption from adhering to a standard based on history or perceived status of the disability.”  We reiterate our position that guide dog teams be exempt from the standard, which is consistent with the preponderance of public review feedback received from the blind community.

The CGSB’s insistence on confidentiality 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.  While we were permitted to keep members of our own organizations in the loop, we were prevented from sharing information about the project with those not at the table, which put us in an untenable position with our peers.  Apparently, the CGSB favours secrecy over open and transparent consultation with stakeholders.

In their report, the TC co-chairs indicated that they had, on several occasions, shortened their vacations to meet with stakeholders.  We see these claims as self-serving, and blatantly disrespectful of other TC members who have voluntarily spent thousands of hours reviewing each and every clause of each and every draft over the past 2 years, not to mention the veritable mountain of public feedback.

The report characterizes negative feedback from those who oppose the standard as being rooted in fear and misunderstanding.  Not only do we consider that assertion to be paternalistic, but we view that feedback as coming from people with legitimate concerns, who fully deserved to be taken seriously.  Instead, the interim report glossed over that feedback, much of which concerned the failure of the draft standard to properly address human rights issues.  As an important aside, the words “human rights” were not used even once, unless the authors considered vague references to a social model of disability to be an adequate substitute.  It is more than worth noting that heavyweight organizations such as  the Canadian Human Rights Commission contributed to the public review, which we believe to be unprecedented in the CGSB’s history.  The CHRC provided eight recommendations, and encouraged the CGSB to “pause to reflect and ensure the process undertaken is the right one to meet the goal, and that the standard covers the appropriate scope.”  Their submission went on to say, in part, “We also recommend that the CGSB consult more broadly with stakeholders…”  Other reputable entities, including the World Blind Union, made similar arguments which apparently fell on deaf ears

In reality, the current scope of the proposed standard cannot guarantee equivalency of any kind, nor are there any mechanisms being considered to ensure that regulators will give credence to the companion document which is not part of the actual standard.

The report continually emphasizes the concept of consensus, and implies that there is general agreement among TC members with regard to the standard.  That is not GDUC’s perception, particularly during day one of the September 2017 meetings during which the CGSB interfered with an agenda item related to conducting a vote on the exemption of guide dogs from the standard.  Perhaps more significant is the fact that at least one TC member filed a formal complaint against the CGSB, which has now been escalated to the Standards Council of Canada.

While the standard itself will not technically impose requirements for guide dog users to complete additional certification steps after being paired with dogs from accredited schools, the resulting certification process, following adoption of the standard, may well do exactly that.  Consequently, guide dog handlers, many of whom exist on fixed incomes, are concerned about bearing the as yet undetermined costs of testing and certification.  This is especially true for the approximately 71% of Canadian handlers who obtain dogs in the U.S., and those who choose to attend Canadian schools which will not enter into contracts with the body responsible for certification and testing.  Furthermore, in the Points of Consensus section, the report states “that the intention is not to have any current re-testing, re-certification or changes in any way to existing certified dogs.”  What the report fails to address, is the presumed necessity of certifying guide and service dog teams formed after the standard is implemented, and the potential impact of that process on peoples’ lives.

The report indicates that the International Guide Dog Federation board member who is part of the TC fully supports the inclusion of guide dogs in the standard.  However, the IGDF representative’s views on the matter appear to be at odds with opinions held by some of its member schools.  The fact that a few of the larger American guide dog schools have already written to their Canadian graduates advising that they may have to stop serving them if the proposed standard becomes a reality would seem to bear this out.  After reviewing the IGDF’s response to the public draft, we cannot help but conclude that it is less than supportive of the initiative.  To quote directly from their submission, “The proposal cannot be considered to be an inclusive endeavour.”

With regard to the inaccessibility of the initial public draft for visually impaired Canadians, the co-chairs praised the CGSB for quickly providing additional time and resources to ensure that the voices of all Canadians could be heard.  While the CGSB did eventually produce an accessible public draft, as well as a comment form, it did so almost 3 weeks after the fact, but not without considerable prodding on the part of GDUC and other like-minded organizations.  Those same organizations had to make firm demands for an extension of the public review, which was ultimately granted, but not without initial pushback by CGSB staffers.

In the Meetings section, the report states that extra time/attention was given to the issue of “disability sensitivity.”  Exactly why that sensitivity does not extend to the provision of accessible project materials and communications is beyond us.  Time and again, we reminded the CGSB of its obligation to provide communications in an accessible format, only to have our reminders ignored.  We continue to receive documents in pdf format, including the interim report, which, for many, are challenging to read.

Equally troubling in terms of accessibility, are the CGSB’s plans for obtaining feedback during the upcoming second public review phase.  In an email dated December 15, 2017, the TC Secretary provided notice of a proposal to hire a third party which would accept and transcribe feedback received via the telephone.  Those plans appear to contravene a 2012 decision by The Federal Court of Appeal (Attorney General of Canada v. Jodhan).

In conclusion, Guide Dog Users of Canada objects to the interim report on the grounds outlined above.  We view it as containing several questionable and confusing statements, if not half-truths, and feel that those who read it will be lead into believing that all is well, when in fact there are serious problems on several fronts.  By submitting the interim report without first consulting the remaining members of the TC, the co-chairs have gone against CGSB policies/procedures, broke faith with the committee, and made a mockery of the consensus model.  We therefore close with a demand that the interim report be retracted in its entirety, and that if such a report is really necessary, that the TC be tasked to prepare it in concert so that it reflects the true state of the project.

Thank you for attending to our concerns, and we look forward to hearing from you.

Sincerely,

Greg Thompson                                      Christine Switzer

President                                                    TC Voting Member

Guide Dog Users of Canada                Guide Dog Users of Canada

president@gduc.ca                                chrisanne1962@gmail.com

 

 

GDUC is Ramping Up Advocacy Efforts Against The CGSB Service Dog Teams Standard

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.

Very sincerely

Greg Thompson

President, Guide Dog Users of Canada

Follow-Up

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.

 

National Coalition, Handlers of Guide Dogs and Service Dogs Meeting Notes – January 17, 2018

Coalition contact – Website/blog:  www.hooh.ca   email: info@hooh.ca

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:

  1. The immediate exemption of all Guide Dog Teams and Service Dog Teams in Canada from the CGSB standards.
  2. Return to the original 2015 Veterans Affairs Canada mandate of ensuring high quality training for Veterans Service Dogs
  3. 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.
  4. 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.

Meeting Notes

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 info@hooh.ca

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 ReportYvonne 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/

Next Steps

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: info@hooh.ca

End of January 17, 2018 meeting notes and beginning of attachments

Social Media Report-Tom Dekker and Ken Sudhues

Facebook Statistics
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.

Demographics:
60 percent of those liking the page are women.
Likes come from Canada, USA, the UK, New Zealand, Germany and Trinidad.

Blog Statistics
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.
Other Correspondence
  • 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:
  1. I received a voluminous response from Veterans’ Affairs Canada (542 pages), and am beginning to work through it now.
  2. 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.
  3. 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.

Recommendation 1: 

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.

Recommendation 2:

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.

Recommendation 3:

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.

Recommendation 4:

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.

Recommendation 5: 

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.

Recommendation 6: 

We recommend that CGSB more thoroughly review, consider, integrate, and respond to the concerns of stakeholders raised in the detailed submissions received.

Recommendation 7: 

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.

Recommendation 8: 

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.

In appreciation,

Original signed and sent by mail

Jacqeline Jodoin

Directrice principale, Bac en comm. MAP

Direction générale des services intégrés / Services publics et de l’Approvisionnement Canada jacqeline.jodoin@tpsgc-pwgsc.gc.ca / 873-469-3250 (office) (613) 897-3414 (cél.)

Senior Director, B. Comm (Hons), MPA

Integrated Services Branch / Public Services and Procurement Canada jacqeline.jodoin@pwgsc-tpsgc.gc.ca / 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:  

  1. The immediate exemption of all Guide Dog Teams and Service Dog Teams in Canada from the CGSB standards.
  2. Return to the original 2015 Veterans Affairs Canada mandate of ensuring high quality training for Veterans Specialized Service Dogs
  3. 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.
  4. 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:

  1. Identify needs of Guide and Service dog users;
  2. Seek solutions with existing legislation and regulation; and,
  3. 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.

Participants:

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

Maria Kovacs

Richard Marion

Graham McCreath

Mary Ellen Gabias

Allan Conway

Christine Switzer

Dr. Susan Hardie

Heather Walkus

 

 

 

 

 

 

 

 

 

 

 

Guide Dogs for the Blind’s Response to Delta Airlines Service Dog Policy

As you know, last Friday Delta Airlines announced changes to their policy for customers traveling with Service Animals.  As promised, we are following up with you to share our official position and action plan.

Guide Dogs for the Blind understands the airlines’ desire to address the ever increasing challenges presented by passengers flying with animals and falsely representing them as Service Animals.  Guide Dogs for the Blind believes that these animals who have not been trained to behave appropriately in public pose a threat to the safety of guide dog teams and other passengers. However, it is the position of Guide Dogs for the Blind that the proposed policy change at Delta is in direct violation of the Air Carrier Access Act. The new regulations are discriminatory in nature and cause an undue hardship on individuals who are disabled and who travel with the assistance of a properly trained service dog.

– Requiring service dog handlers to present a health certificate for their dogs 48 hours prior to flying is discriminatory as it does not allow for last-minute or emergency travel. Further, it presents an undue hardship on the handler as no other passengers have to submit similar paperwork prior to travel.  The Air Carrier Access Act clearly states that passengers with disabilities do not need to let airlines know about their disability prior to flying.

– Requiring persons with service dogs to check in “at the counter” is discriminatory as it does not allow equal access to all services provided by the airline including curbside and online check-in.  The Air Carrier Access Act was designed to ensure that persons with disabilities would have free and equal access to the same services as other passengers.

Further, the proposed policy does not directly address the issue of ill-behaved animals and their negative impact on the travel experience for people of all abilities.

Guide Dogs for the Blind is requesting a meeting with Delta airlines as well as a consortium of other airlines to discuss this matter further and to help them develop a solution that does not infringe on the rights of our clients and other handlers of legitimate service animals.  If you are also concerned about this new policy we encourage you to let your voice be heard. You can file a complaint at  https://www.transportation.gov/airconsumer/file-consumer-complaint, or by phone at : (202) 366-2220.

We will keep you posted on any further developments.

Very Best,

Christine Benninger, CEO

The Seeing Eye’s Response to Delta Airlines Service Animal Policy

Many of you have contacted The Seeing Eye with concerns about Delta’s new service animal policy. The new requirements, effective March 1, call for disabled passengers to take several steps before they will be allowed to fly with a service animal. These steps include uploading proof of rabies and distemper vaccinations to the Delta web site on an annual basis, and requiring passengers to report to the check-in counter for verification each time they go to the airport.

The Seeing Eye recognizes that all airlines must establish practical and reasonable policies as part of ongoing efforts to keep passengers safe. However, we believe that Delta’s new service animal policy compromises the rights of guide dog handler’s to fly free from discrimination.

In response to Delta’s new policy, and the likelihood that, if left unchallenged, other airlines will quickly adopt similar requirements, The Seeing Eye has submitted the below complaint to the Aviation Consumer Protection Division at the U.S. Department of Transportation:

“Passengers with guide dogs should be able to complete check-in online, at a kiosk or curbside, just like anyone else. Instead, Delta’s new policy requires these passengers to “Visit the airport check-in counter”, where the disabled passenger’s “request will be verified at the airport by a Delta Representative.” This is an undue burden and a serious inconvenience for blind passengers — especially when traveling with family, friends or business colleagues who prefer to check-in curbside or who have already secured advance boarding passes. This practice violates the disabled passenger’s right to choose what check-in process works best for his/her individual circumstances, and will likely force passengers to depend on Delta representatives or others for additional assistance that they might not otherwise require. Moreover, segregating blind passengers from their traveling companions or other non-disabled passengers simply to enforce compliance with a vaccination requirement that is already mandated by most state laws is degrading and cause for considerable humiliation, embarrassment, and loss of dignity.
The 48-hour advance notice seems to preclude last minute or emergency travel if the trip is the passenger’s first flight of the renewal year.
The policy fails to address what will happen when other airlines need to reschedule disabled passengers onto Delta flights if those passengers do not have the required documentation for their service animals.”

Graduates who are concerned about this new policy are encouraged to submit their own comments describing any negative impact on air travel on Delta by completing the complaint form at:

https://airconsumer.dot.gov/escomplaint/ConsumerForm.cfm

If your only means of contacting the Division is by phone, you may leave a message at (202) 366-2220.

To read more about Delta’s new service animal policy, visit:

https://www.delta.com/content/www/en_US/traveling-with-us/special-travel-needs/service-animals.html

Sincerely,

Ginger Bennett Kutsch
Advocacy Specialist
The Seeing Eye, Inc.
Morristown, New Jersey
(973) 539-4425
http://www.seeingeye.org