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What U.S. schools decide has no bearing on our opposition to CGSB standards

This summer many of us were alarmed by concerns expressed by US guide dog schools regarding their ability to continue serving Canadians should the CGSB standards be adopted. Guide Dogs for the Blind relieved many graduates when they announced that they would never abandon their Canadian students.

How has the recent statement from GDB changed things?  Not at all!

Though fear that Canadians would be denied access to American schools was one of the elements that made us reject the CGSB standards, it was by no means our only, and not even our major, reason for raising the alarm.

Our position remains unchanged.  The process for developing standards was not a legitimate public policy process.  The standards themselves frequently conflict with good training standards developed by IGDF schools.  The proposed redundant testing and recertification protocols are intrusive, degrading, and treat those with guide dogs as childlike people who must be monitored, instead of regarding guide dog handlers as competent blind adults whose choice of a means of independent mobility should be affirmed and supported.

All guide dog schools continue to oppose the original draft standards.  We are gratified that the schools share our perspective on how the proposed standards will negatively impact graduates.

This coalition is a voluntary group of individuals who have taken the time and trouble to inform ourselves about a process and its outcome. We have learned more than most Canadians know about standard setting because misuse of the standard setting process endangers our right to do something as fundamental as walking around. 

Our most grave problem with the proposed standards continues to be that they are written in a manner and process that is totally devoid of understanding and respect for human rights principles. All organizations of blind Canadians who have spoken publicly have expressed opposition to this process, yet it continues behind closed doors under nondisclosure agreements.  As the people whose rights are being directly and profoundly violated, the members of this coalition will continue to stand.  Human rights issues remain the centrepiece of our opposition to CGSB’s uninformed and illegitimate intrusion into our lives.  We reaffirm our position that these standards must be withdrawn.

Though school comments help inform our independent decisions as individual handlers, we are not defined by what the schools have to say.  The schools have their own reasons for opposing these standards.  If their objections can be overcome and the schools determine that they can live with any future version of CGSB standards, we understand their institutional necessities.  We continue to wish the schools well and value our relationship with them.  Our support for IGDF standards as wholly adequate remains firm. 

However, we remain independent thinking individuals who will make evaluations of any future proposed standards based on an informed understanding of our personal and collective best interests as handlers.  Our interests frequently parallel the interests of the schools.  On those occasions when they do not, we will continue to raise our voices in affirmation of our unique position as the people who work with guide dogs every day.

Signed:

Yvonne Peters

Heather Walkus

Mary Ellen Gabias

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Detailed IGDF Response to CGSB – July 14, 2017

Re: CGSB Service Dogs Team Draft Standard

Firstly, on behalf of the International Guide Dog Federation (IGDF), I welcome the opportunity to comment on the Draft Standard created by CGSB in relation to Service Dog Teams.

In order to advise the CGSB of the credentials that the International Guide Dog Federation has in providing feedback on the proposed standard, we would offer the following background information.

History of IGDF

 The idea of the International Federation of Guide Dog Schools for the Blind (IFGDSB) – as it was originally known – stems from conferences held in France (1973) and London (1976). At the conclusion of the third international conference in Vienna in 1983, attendees agreed the formation of a European-based group to consider “the formulation of guidelines and standards for the training of dogs and to teach blind people the use of dogs”.

It was recognised and acknowledged by the professionals producing guide dogs that a blind person had special and very particular requirements of a guide dog.  A blind person needed to rely on the dog to safely guide them across a busy road consistently, to safely indicate the beginning and end of a flight of stairs (or an escalator), to avoid dangerous obstacles or trip hazards and not be distracted from the task of guiding.  If a dog was inadequate in performing any of these tasks, then the blind person could potentially be seriously injured or even killed.  At the same time, the dog had to behave and be presentable in public and not pose a threat to members of the community.

Much work was done from the 1920’s to determine the most appropriate behaviours to select for in breeding and the best training techniques to produce a guide dog that satisfied the requirements.  For example, breeding to select for dogs with minimal dog distraction, food distraction or prey instinct reduced the chance that the dog would be distracted while guiding, etc.  Training techniques used by trainers of many animals were investigated to develop the most effective way of training guide dogs, from 8 weeks of age, to focus on indicating hazards in a blind person’s path, indicating stairs and hesitating at a road crossing and then crossing in the most direct route when determined safe, etc.

The wealth of over 100 years of accumulated international knowledge by the best experts in the world on guide dogs on the subjects of breeding, training of dogs and training of trainers, dog care, etc., have been embedded into the IGDF standards.

In 1992, formal inspection of member schools began utilising these IGDF standards and, where standards were met, schools were accredited by a trained assessor in line with agreed operational guidelines.

Where standards were not met, action plans were agreed or membership was revoked.

As at the end of 2016, there are 91 member organisations (operating in 29 countries), 4 affiliate organisations and a further 29 organisations working towards achieving the standards set by the IGDF and, thereby, aiming for accredited membership.

Through these organisations, IGDF currently represents around 25,000 guide dog users currently working throughout the world.

In supporting these aims, one of the formal sub-committees of the IGDF is the Development Committee (DC).  Through the DC, individual organisations seeking IGDF membership are afforded ‘expert’ advice and guidance in developing their services such that they do, indeed, meet the high standards required.

Collectively, the knowledge and experience of the modern guide dog movement can be traced back for more than 100 years.  This knowledge and experience has led to the IGDF, as it stands today, representing the highest level of expertise within an extremely specialised field and with proven standards by which all members are measured.

IGDF Standards

The International Guide Dog Federation (IGDF) is the industry-elected peak body responsible for the development, monitoring and evaluation of the standards applied within all IGDF-member organisations, in order to ensure equity of high-quality service to guide dog users and handlers around the world.

It can take many years for a new organisation to achieve the required standards which will enable them to become an IGDF Member – and only following in-depth assessment by another of our ‘expert’ sub-committees (Accreditation Committee – AC).  All member organisations are then re-assessed on a 5-yearly basis to ensure that the standards are maintained before their ongoing accreditation is approved.

The standards themselves go into great detail and cover the following key areas:

  • Standard 1 – Applicant / Client selection
  • Standard 2 – Client and Guide Dog Team instruction and follow-up
  • Standard 3 – Technical Staff Education and Development
  • Standard 4 – Guide Dog Mobility Instructor (GDMI) Education Programme
  • Standard 5 – Humane care, training and treatment of Guide Dogs
  • Standard 6 – Breeding, puppy raising and veterinary care
  • Standard 7 – Guide dog assessment and training
  • Standard 8 – Kennel specifications
  • Standard 9 – Buildings and transport
  • Standard 10 – Administration

These standards are continually monitored, reviewed and updated.

With the re-assurance that comes from a graduated dog / handler team from an IGDF member organisation, comes increased confidence – both for the individual relying upon their guide dog for safe, independent travel and, also, the wider public who need to know that the dog comes from a solid background which includes significant ‘public access’ training / testing and has been raised to the highest standards of health and welfare.

Ongoing assessment – both for the continued accreditation of a member organisation and, also, individual follow-up of each working dog / handler team – ensures that the high standards required are maintained.

IGDF standards are set, evaluated and reviewed such that quality, service and expectation is considered on a worldwide level – thus enabling equal access to international travel for all, regardless of a need to rely upon a guide dog for an individual’s independence.

Review of draft standards as proposed by CGSB

Initial comments:

  • There is neither acknowledgement, nor recognition of current IGDF (or ADI) standards.
  • The proposal lacks clarity on its impact, strategies and governance.
  • The printed standard is 61 pages long – a long and difficult document
  • Focused on standardisation of the service dog team (which proposes to protect the public, the user and service dogs).
  • Posits that wait times led to some trainers now entering the field that do not have the appropriate experience and education, resulting in self-trained teams without assistance and ‘fraudulent’ teams – whereby dogs are passed off as ‘service dogs’ but have had no relevant / formal training.
  • Provides a basic benchmark for the performance of a service dog team but this is primarily focused on ‘simple’ obedience and a (one-off?) test for public access.
  • Does require comprehensive knowledge on the handler’s part in several areas (a positive)
  • The assessments appear onerous (for example – a veterinarian must provide proof that the dog is free from immediate or chronic stress, fear, anxiety, or discomfort, free of conditions that may interfere with their ability to work or may put the public at risk?).
  • The proposed standard is voluntary at this time but, presumably, the intent is for regulators to use these standards as a basis for future regulation development.
  • There is no focus on efficacy of tasks but it does provide a list of common tasks for different types of assistance dogs.
  • Recommends against specific breeds for assistance dog work
  • Specifically prohibits “positive punishment” and “negative reinforcement”. This would not allow for leash/collar corrections or the use of the word “no”.  In the case of asking a dog to lie down, you would be prohibited from exerting any downward pressure with the collar.  This is completely unrealistic as the majority of assistance dog users would not be able to adhere to this (or, crucially, pass the test).

Questions / concerns:

  • What are the actual qualifications for the assessor and who is responsible for the assessment to occur?
  • Who reviews the assessment reports and what are their qualifications?
  • Is there a formal appeals process?
  • Requires the assessor to verify the handler’s disability through a signed statement by a physician that they have a disability that may be mitigated through the use of service dog. How is that determined?  Will the physician be required to assess the functional limitations of the person with the disability (which a dog would mitigate) or just the clinical diagnosis (which may not be relevant)?
  • How often do the assessments need to take place? Does this only happen at the beginning of the team’s life together? What is the frequency of testing?
  • What is the scale for determining whether the team has passed the inspection? How many things have to be passed?  Are any failures acceptable?  How do you determine the appropriate “matching” based on the chart and ratings?
  • How will the assessments even be implemented? Who are the assessors?  Will they work for a governmental agency?  How will the assessors be trained?
  • Is this grandfathered…or do all service dog users in Canada need to be assessed now? How many are in use currently?
  • Will a team that has been successfully working in the field for many years fail because of any ‘simple’ aspect of the test (like taking a food distraction)
  • How is the assessment addressing the actual tasks required of the graduated team? Are those to be graded as well?  Who is working on that?
  • What is the provision for ongoing revision of the standards?
  • How will this affect the organisations that are currently providing dogs to the Canadian market? Will they possibly discontinue training Canadian clients?  This is at odds with the stated objective at the beginning of the standard document.
  • The standard appears to be at odds with disability discrimination legislation around the world, by which guide dog teams are permitted access based upon the high standard of training they receive from, in particular, IGDF member organisations. This proposal will have a likely detrimental impact upon visitors to Canada and, also, Canadian Guide Dog Users wishing to visit other countries.

The proposed standard does not allow for the recognition of any other global standard.  It appears to be an attempt at an outcome standard but inherent with that direction is its focus on the human / dog team’s ability to behave and function in public areas (but in this case, very little focus on the dogs’ ability to perform the required tasks).

IGDF has struggled with the development of a specific outcome standard as it is difficult to find ways to implement an accreditation.

The ultimate outcome in any of our programs is how the handler and dog function together and whether this leads to enhanced mobility and an increase of independence for the individual.  Ongoing follow-up for the working life of a guide dog team monitors and evaluates each case in line with the current standards.

IGDF standards are a code of practice and we have avoided being highly prescriptive to allow for required flexibility in individual application while offering indicative benchmarks.  For example, the requirement of a blind person using a guide dog in a quiet / rural location is very different from someone using a guide dog in a busy / city environment.  IGDF promote best practices learned through all of our shared experiences and providing for standards that can be applied around the globe.  In addition, IGDF standards cover the many aspects of running a guide dog programme that are outside of the outcomes of individual teams (breeding, puppy rearing, training, aftercare, initial and ongoing staff development, etc.) – all important aspects of providing safe and effective guide dogs.

We understand that the Canadian Association of Guide Dog and Assistance Dogs strongly oppose these standards and, it appears, most of those organizations found out about this Board convening well after it had started its work.  To that end, the proposal cannot be considered to be an inclusive endeavour.  The IGDF supports this view.

Much of the “inspection” is unrealistic and would require considerable time and resources.  A good example is the “Behavioural Evaluation” that suggests a different person be involved with as many as nine different tests in areas where the service dog does not reside or normally inhabit.  Many of the other stipulations appear to not take visually impaired handlers into consideration, which, had the Canadian Association of Guide Dog and Assistance Dogs been involved from the outset, could have been avoided.

On top of that, can we imagine the stress and anxiety this would cause consumers?    Why should they be put in the position of having to justify the accommodation of an assistance dog when the majority of them are going about their lives just fine?  Is the Canadian government prepared to withhold the issuance of an identification card legitimizing a team when they have been traveling successfully for years because they failed a few points on the inspection?  Is the test to be repeated periodically during the working life of the dog?

Having said all of that, we do respect much of the work that has been accomplished by the committee around these standards.  I could see incorporating some aspects into our own standards and they do provide a structure for the assessment of clients, the education that needs to be delivered by programs and outcome expectations related to appropriate guide dog behaviour in public areas.

IGDF strongly recommends that the Canadian Standards Board fully recognise the IGDF and their proven, tried and tested, standards and, should the proposed CGSB standard be progressed, there should be no additional testing of graduates from member schools.

IGDF therefore respectfully proposes that the Canadian Standards Board recognises the IGDF standards, with their graduates being exempt from this regulation.  The draft proposal may then be developed to certify (or not) owner-trained teams or non-IGDF member teams – an effective ‘marriage of convenience’, perhaps?  At the same time, this could promote the benefits of IGDF membership to new organisations and, through the detailed accreditation process, encourage higher standards and expectations for all.

Sincerely

Paul Metcalf

IGDF Board Chair

Revised Canadian Service Dog Standard – A Failed Process – Two Versions

Here are two versions of the slightly revised, expanded, and updated version of the Canadian General Standards Board Service Dog Team Standard – A Failed Process (AKA, “The Menzies Report”) in PDF, in text only format and with graphics.

Toronto Story Archive Podcast with Tom Dekker

Mo Waja hosts Toronto Story Archive, a very popular podcast in Toronto and, on August 3rd, interviewed Tom Dekker about the draft service dog standard being considered by the CGSB. The finished podcast was made available earlier this week, although it should be noted that much progress has been made in the month since it was recorded.

 

Supportive Commentary from Canadian Federation of the Blind (CFB)

Review of the history [of this issue] makes one point even clearer than it has been made before.

Instead of using a public policy framework, this process has used a
standards creation framework.  The two are very different because they serve different purposes.

Much of the confusion has been a direct result of the framework.

I am completely convinced that all the people on the committee acted in good faith, did their very best, and were to some degree sucked into a vortex. CGSB does not know much about disability; hence they didn’t consider that they were releasing the document for public comment in an inaccessible format.  No ill intent, but very ill-educated.

All of us have been forced to struggle through a very steep learning curve.
Bravo to all of us for digging in and doing the learning.

Another fact is beyond dispute, unless I’ve missed something important.
Every entity and individual involved with guide dogs has grave trepidation
about these standards.  Faced with that overwhelming sentiment, who did what and why they did it in the past is only valuable insofar as understanding can teach us something useful for the future.

I’m excited about our growing unity on this topic.  Now our task is to get
government to move from a standard setting to a public policy framework.
Canada is writing new access legislation.  Approaching guide and service dog issues from that context could be a win for everybody.

I feel for the veterans who have been waiting for dogs trained for their
specialized needs for so long.  They really hoped setting standards would
help them.  If the government had spent some money contracting with IGDF and/or ADI schools to do proof of concept pilot projects with veterans needing dogs, everybody would know more about how to help the veterans and several individuals would now be partnered with good dogs.  Perhaps we could suggest that possibility to veteran organizations and to government, specifically Veterans Affairs.  It would be a way to say “no” to the standards while saying “yes” to veterans in need.

Mary Ellen Gabias

President, CFB

Update on GDUC representation on CGSB Committee, etc.

Letter sent to Guide Dog Users of Canada members, September 13, 2017.

Dear Members,

As of noon yesterday, Tuesday, September 12, Christine Duport-Switzer
represents GDUC on the Canadian General Standards Board Technical Committee responsible for the development of the service dog teams standard.  The change was made during a teleconference attended by your President, Christine, Alan Conway, and Michel Bourassa.  We commend Michel for the way he conducted himself during what was certainly an uncomfortable situation.

He graciously stepped aside, which enables us to remain at the table with
Christine acting as our spokesperson. Christine will take the lead in
advocating for our position on the standard which is that guide dog teams
trained by IGDF member schools are to be exempted.

Mr. Bourassa confirmed that he was serving several masters with regard to developing the standard.  Not only was he representing us, he was also
acting as lead for working group 3, and spent numerous hours assisting
others, including one of our valued life members in providing feedback to
the CGSB.

At no time since the Technical committee was formed, and up to the present day, has GDUC ever indicated that it supports the standard. Before the advent of the public draft in May of this year, we thought it best to follow the process and focus on the standard itself.  Christine and Alan put
significant time into reading drafts, writing comments, and exchanging vital information with Michel.  All members of the TC were required to abide by strict confidentiality which prevented us from openly sharing what was transpiring.

When the public draft hit the streets, GDUC was all over the fact that it
wasn’t accessible, and did something about it.  You will recall a post on
May 8, only 6 days after the start of the public review, that provided both
an accessible version of the draft standard, and an accessible comment form. In that post, we encouraged you to share that material with other blindness focused organizations.

Eventually, the CGSB did produce the standard and comment form in an
accessible format, but as a result of its tardiness in doing so, GDUC pressed hard for an extension of the draft review period.  We were definitely not alone in voicing that demand, and ultimately an extension was achieved.

During the public review period we put considerable energy and thought into providing comments on the standard itself.  The crux of our feedback
concerned the omission of critical material pertinent to guide dog teams
which the Standards Board mysteriously omitted from the draft.  We also
published a document which was widely misinterpreted, but was intended to explain the complexities of the standard, and to provide some insight into the whys and wherefores of the standards development profession which are extremely difficult to comprehend by us laypeople.  Again, the purpose of that writing was to give you information we thought you needed to make up your own minds.

Our acceptance or rejection of the standard, in whatever form it might take, will be determined by you, as our members, by an open vote at the
appropriate time.  At this point GDUC believes that guide dog teams trained by International guide dog Federation, IGDF, member schools should be exempt from the standard.

So, rumours circulating that GDUC endorses the standard are precisely that, and have no real basis in fact.  We encourage anyone who has questions about our position on the standard, or on any other topic for that matter, to pluck up their courage and contact us directly.  In that way, we can have a meaningful conversation about the real issues, and thus avoid potentially damaging and negative speculation which is not in anyone’s best interest.

In closing, we express complete confidence in Christine’s ability to represent us, and offer our unflagging support as the 3-day session during which the public review comments will be dealt with draws closer.  We will have more to say following those meetings, and as matters further unfold.

Please feel free to distribute this message far and wide.

Sincerely

Greg Thompson

President, Guide Dog Users of Canada

Coalition Conference Call with Canadian Human Rights Commission, September 8

Draft

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

Conference call, September 8, 2017

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