Guide Dogs for the Blind (GDB) Response

Dear Canadian General Standards Board Committee Member:

Guide Dogs for the Blind (GDB), the largest guide dog training school in North America, stands opposed to the proposed Canadian National Standards for Service Dogs.

GDB has been partnering blind and visually impaired individuals with highly trained guide dogs for the past seventy-five years and has been providing these same services to Canadians for the past fifty years. Currently, GDB has over 300 active working teams in Canada.
First, GDB is fundamentally opposed to any regulations that require a person with a disability to experience the undue burden of proving to a government or public entity their need for an accommodation such as a guide dog, enduring testing from a public entity that is not fully knowledgeable as to the appropriate behaviors or training of a service animal for the mitigation of a disability, or the necessity to carry and produce identification at the request of the public. We feel that the requirement to show identification has, and will continue to lead to harassment of those with disabilities. It is our understanding that the reasoning behind the creation of the proposed standards is to protect the public from ill-trained dogs who may place the public in danger. However, this proposal places the burden for controlling this nuisance on persons with disabilities who have well-trained dogs and are operating appropriately in public, which is the majority of guide dog teams.

Over the past seventy-five years, GDB has established internal standards regarding the education and preparation of guide dog mobility instructors, the breeding and training of our dogs, the instruction of our clients, including post- graduation follow-up care, and the provision of veterinary care for our dogs which also continues after the graduation of the team. These standards are industry leading, and we are recognized worldwide for our excellence. We also want to express that the proposed “test” within this standard is highly unrealistic and unfair to the handler and the dog. We urge you to reconsider the elements of these tests and seek out guidance from established organizations with the appropriate expertise.

In addition, GDB is a member of the International Guide Dog Federation (IGDF) which certifies guide dog training programs. We are already required to meet rigorous standards for dog training and client instruction, including respectful treatment of clients and humane management of dogs in order to maintain our certification. We assert that, should you continue on the path of establishing these proposed standards, that guide dog teams who have graduated from IGDF certified programs be exempt from these regulations.

If you would like more information about our program and/or our training and certification processes, please do let me know. I am very happy to share information about our high standards of quality assurance.

Sincerely,

Christine Benninger
President and CEO

Guide Dog Users of Canada Response

CGSB Draft Service Dog Teams Standard, a GDUC Perspective

We offer the following as a means for you to make up your own minds about the standard. We’ve done everything in our power to provide a balanced perspective, aimed at giving you the information you’ll need to arrive at a decision, either for or against.

Introduction

With the CGSB Draft Service Dog Teams Standard in the public review phase, this document attempts to explain what is likely to happen to new guide dog teams as the standard moves forward. It also serves as a frame of reference for our detailed feedback on the standard which will be provided to GDUC members shortly.

GDUC acknowledges the efforts and expertise of retired standards professional Michel Bourassa, whose special knowledge and expertise enabled us to take on this task. The document borrows liberally from Mr. Bourassa’s writings which he has graciously allowed us to use. Joanne Moss, of the Canadian Foundation for Animal assisted support Services also provided significant assistance, guidance, and moral support.

Current Situation

The majority of North American guide dog schools are members of the International Guide Dog Federation , IGDF. Schools which train other types of service dogs have a similar relationship with Assistance Dogs International , ADI. Most Canadian schools also belong to the Canadian Association of Guide and Assistance Dog Schools, CAGADS.

Acceptance of schools as IGDF members is largely based on standards which describe in detail the processes associated with training, or producing, guide dogs, as well as the schools’ dealings with clients. They were developed by the IGDF, for use by the IGDF, and as such are termed private or closed standards. The standards outline such things as qualifications for guide dog mobility instructors, aspects of the initial home visit, ETC. In essence the standards ensure that IGDF schools are operating in such a way as to produce the best possible guide dog teams. In effect, the IGDF member schools have a niche market in the production of guide dogs.

While GDUC is quite satisfied with the way guide dog teams are currently being trained, we recognize the benefits offered by other types of service dogs. We further acknowledge that the increased prevalence of other types of service dogs is problematic, in that there is currently no concrete way for those responsible for public spaces to determine which teams are, or are not, legitimate. We therefore believe that the resulting confusion in terms of access rights needs to be addressed if we are to move forward as a community of service dog handlers, or indeed as an inclusive society.

CGSB Draft Service Dog Teams Standard

Enter the Canadian General Standards Board, CGSB, Draft Service Dog Team Standard which differs from the IGDF standards in several important ways:

What VS How

The intent of the CGSB standard is to set out requirements using performance measures which establish that:

  • The service dog team is legitimate in that the handler has a legally recognized disability, and the service dog assists the handler in their life through mitigation of some aspects of the disability
  • The service dog team is safe in, and safe to, the public
  • The service dog is well cared for

The CGSB standard carefully avoids training requirements for the various tasks that service dogs perform, and leaves them to those doing the training. Annex A of the standard contains information on training methods, while Annex C summarizes tasks associated with different types of service dogs, e.g., mobility, hearing, and autism. This approach does not bind service dog trainers and organizations to existing training methods, but instead encourages the development of new and innovative humane training practices.

In other words, the CGSB standard focuses on the end result, or what, whereas the IGDF standards focus on the processes, or how. In that way, they actually complement one another.

The requirements of the draft CGSB standard cover the knowledge and capabilities of current guide dog school trained teams, and form the basis for other service dog teams on an “as good as” basis.

Successful implementation of the CGSB standard requires other elements, such as regulation, conformance verification, training providers, supporting persons, and organizations.

Testing and Certification

The requirements in the CGSB standard will form the basis for testing new service dog teams. Although the certification (conformance verification) process has not yet been agreed upon, and cannot be until the standard itself is accepted, we feel relatively comfortable speculating that it will likely work as follows for guide dog teams:

The expectation is that CGSB will implement a certification scheme that will include a central registry of certified teams, along with a CGSB certification mark appearing on equipment and ID cards in a manner visible to the public. This will give instant recognition that teams are legitimate thereby helping to clarify rights of access to public spaces.

We expect that there will be more than one stream leading to individual team certification, depending on the approach taken to prepare the team: recognized training school (E.G., IGDF member), independent trainer, or training by the partner handler.

If the team results from a recognized training school, it is the school that will decide that the certification mark is appropriate. Use of the certification mark by the school may only be done through a legal contract between the school and CGSB, known as a certification agreement.

Prior to granting the contract, CGSB will satisfy itself that the school is competent to produce teams that fulfill the requirements of the standard. After awarding the contract, CGSB will perform continuous surveillance to assure itself that all future teams are in compliance. For schools CGSB has no reason to doubt the surveillance will be very light.

For schools where CGSB receives complaints that their teams pose problems, perhaps from persons that manage public spaces, perhaps from the general public, perhaps from regulators, or perhaps from the school’s competitors, CGSB will intensify its surveillance of the school as needed to ensure complying teams. As a last resort, CGSB will cancel the contract. When a contract is cancelled, existing certifications are normally not affected, but the school may no longer use the CGSB certification mark.

The standard was drafted with the certification scenario of a contract with a school in mind, and as written should permit a school to continue its current way of operating while simply indicating to CGSB how it puts the requirements of the standard into practice. One example would be to demonstrate how its intake evaluation uses a knowledgeable person to perform the assessment. A second example would be how the school evaluates the service dog obedience skills as they are acquired during training prior to matching with a handler. In that way the IGDF schools are being accorded complete respect, acknowledged as pioneers, and credited with the expertise and experience gained over the course of many decades.

After talking to some of the guide dog schools, we determined that many of them, particularly those in the U.S., are likely to reject the above certification scenario based on the anticipated surveillance provisions. Rightly or wrongly, they see them as interference by government. The Seeing Eye, for instance, likened the situation to that occurring in California with Guide Dogs for the Blind and the board of oversight. While the proposed certification scenario does involve surveillance, the surveillance will be strictly in accordance with the requirements in the standard, and as such will not represent interference in the schools’ day-to-day operations. Another rejection factor involves the practice in the U.S. of being entitled to accommodations, with no questions asked, based on a person self-identifying as having a disability.

Simply stated, we, as guide dog handlers will not likely notice much difference, and will not have to undergo additional third-party testing, provided we choose to attend an existing guide dog school. As the standard does allow for alternate training streams, it is up to us to make informed personal choices concerning the type of training we receive according to our needs and life styles.

Consensus

The second major difference between the IGDF and CGSB standards relates to the manner in which they were developed. The CGSB standard is being put together on a voluntary/consensus basis by a standards-development committee comprised of a wide variety of stakeholders, including:

  • Regulators – staff from departments of the federal and some provincial government departments
  • Producers – representatives from many of the Canadian guide and assistance dog schools along with some private trainers of service dogs
  • Users – organizations speaking for guide dog handlers like GDUC, CCD, and VIRN
  • General interest

Voluntary consensus standards are founded on balanced representation and knowledge. Standards-development committees are made up of people who not only have specific knowledge about an issue, in this case service dog teams, but also have a special interest in the outcome. These factors help ensure that standards under development are both technically and financially feasible, and acceptable to all parties.

Standards Help Us

Standards are not legislation, and do not constitute governmental oversight. Although the Canadian General Standards Board is in fact part of the Federal government, its role in the development of the service dog team standard is that of an enabler or facilitator.

The CGSB will likely be more actively involved when it comes to the certification process. It is important to understand that the development of the certification process is contingent upon acceptance of the standard itself. Should that occur, please be assured that GDUC will advocate for the development of a certification scheme which recognizes the excellent work being done by IGDF member schools, yet at the same time is fair to all parties.

In general terms, standards ensure that the numerous products and services we use on a daily basis are safe, and function as intended. Until now, the training of service dogs has been left to schools which make their own rules, but perhaps the time has come to bring it into line with mainstream consumer products and services through the adoption of appropriate and relevant standards. Surely this can be achieved without those schools believing that the CGSB standard represents criticism, or threatens their current way of operating, which is definitely not the intent.

Voluntary standards can be used as a tool by regulators, and can serve as supports for public policy. Legislation can reference the CGSB standard as a means of clarifying service dog team access provisions. In this case, access can be granted to public spaces based on the presence of the CGSB certification mark on the team’s id card.

The Standard will be reviewed and updated on a regular basis allowing it to keep pace with changes in the service dog landscape.

One example of how the CGSB standard could be referenced in legislation is the Accessibility for Ontarians With Disabilities Act, AODA. This legislation is perceived as weak by many as the standards on which it depends were not developed before the legislation was implemented.

Conclusion

Guide Dog Users of Canada ultimately believes implementing the CGSB Service Dog Teams Standard will:

  • Tackle the problem of fake service dogs through inclusion of the CGSB certification mark on handlers’ id cards
  • Leave the traditional guide dog school training model pretty much as it is today
  • Offer more choices when it comes to obtaining guide dogs
  • Make Canada an international champion in terms of service dog teams. Once the standard becomes established in this country, it could well be brought forward to the International Organization for Standardization, ISO, which could well lead to the creation of a World-wide standard.

At this point we encourage you to think carefully, and make your decision to accept or reject the CGSB standard on its own merits. We recognize that the standard under consideration is not perfect, but the public review process is specifically designed to make it better through the provision of detailed feedback. That is precisely why we have gone to considerable lengths to comment on the standard, reach out to other stakeholders (training schools and other blindness focused organizations), and generally heighten our awareness of the issues present in the service dog community.

We fully expect that many of you will have questions which we’ll do our utmost to answer, perhaps during a conference call tentatively planned for early July. Ultimately, our organization will have to decide whether it is for or against the standard. It is our hope that this document served to shed at least some light on what the standard means, and does not mean, for us as handlers of guide dogs, and that it assists you to make an informed decision.

Canadian Press Coverage: Proposed Service Dog Standards

Guide dog users, providers say proposed rules disregard needs of visually impaired

TORONTO — Providers and users of guide dogs for the visually impaired say new proposed federal standards for service dog teams disregard their current needs and could pose barriers to future access.

The Canadian General Standards Board issued draft guidelines meant to serve as best practices for a wide range of people with disabilities and their canine service partners.

The standard, which is not finalized, proposes a vetting system to determine if someone is suitable for a dog, scrutiny into the team’s home life and stringent restrictions on the types of equipment and commands service teams can use.

But guide dog users and the schools that train them say the Canadian standard was shaped without regard to international guidelines that have served the industry well for decades.

They argue the proposed rules would force schools to either change their time-tested training programs or possibly stop serving Canadian students altogether.

The standard, they say, ignores the unique needs of guide dog users and the specialized tasks their dogs need to perform.

Yvonne Peters, a human rights lawyer and long-time guide dog handler, described the current version of the standard as a one-size-fits-all approach to disabilities ranging from deafness to epilepsy.

Much of the language, she argued, is not applicable to people with visual impairments.

“There are things within the standard that are totally irrelevant, totally unnecessary, and totally onerous that would be imposed on us as dog guide users,” Peters said in a telephone interview from Winnipeg.

The standard, for instance, suggests service dog teams should avoid hazards such as hot pavement, winter conditions or broken glass.

Seasoned handlers and trainers said that’s unrealistic, since blind people rely on their service animals to navigate through and around those exact conditions.

Advocacy group Guide Dog Users of Canada said they raised such issues during the shaping of the standard, but said their concerns are not currently reflected in the document.

The national standard was shaped with input from groups across Canada and funded by Veterans Affairs Canada, whose interest in the issue was driven by the growing presence of dogs to treat post-traumatic stress disorder.

Jacqueline Jodoin, the senior director of the Canadian General Standards Board, stressed that the standard is still in draft form and is not a certification or licensing program, though it could become the basis for one down the road if it is adopted in regulations or legislation.

She said having standard in place could limit the presence of poorly trained dogs.

“The goal and the scope of this standard is really to focus on service dog teams, . . . safe public access for service dog teams, and making sure that persons with disabilities wishing to train their own service dogs have information on how to do that.”

Guide dog users and trainers say the standard is too blunt an instrument to tackle those issues and undercuts systems that are already in place elsewhere.

The draft standard suggests all applicants should be evaluated by a third-party to determine whether someone has a disability and if they’d benefit from having a dog, duplicating protocols already in place at accredited schools.

The standard also proposes to forbid training methods at the heart of programs that Canadians have been using for decades.

For instance, it states that only positive reinforcement techniques such as food or affection-based rewards would be acceptable when working with any kind of service dog.

The standard lists all negative reinforcements as “unacceptable,” including verbal reprimands or physical tugs on the leash to focus the dog’s attention.

“There are times that our dogs do need to be corrected while in public, no matter how seasoned they may be,” wrote guide dog user Robert Fenton in a submission to the Standards Board speaking out against the draft.

“Removing the ability of a handler to correct their dog verbally or through the use of a leash correction, solely to satisfy the public, may ultimately put our safety at risk.”

Fenton said the board should allow exemptions for teams trained at schools that are already accredited by global organizations such as the International Guide Dog Federation or Assistance Dogs International, arguing they have developed standards that have served both the visually impaired community and the public at large well for years.

The Seeing Eye, one of the world’s most prominent and acclaimed guide dog providers, said failing to do so could make it difficult to serve Canadian students if the standards ever become law.

Greg Thompson, president of Guide Dog Users of Canada, said the International Guide Dog Federation rules were developed by people in the industry to regulate themselves, speculating that may be why the Canadian Standards Board chose not to reference them at all in the document.

Still, he said the organization has provided strong oversight and should be acknowledged in future Canadian rules.

Some certified Canadian schools agree.

“We don’t feel the need for our schools and our graduates to have any further standards defined for them because they’re already achieving really high standards,” said Sandy Turney, executive Director of Lions Foundation of Canada Dog Guides in Oakville, Ont.

Similar sentiments came from Ottawa-based Canadian Guide Dogs for the Blind, who raised concerns that today’s voluntary standards could become tomorrow’s policies that limit accessibility for the visually impaired.

“An industry standard is not a law, but may be used by national regulatory bodies such as Transport Canada, who may choose to adopt the standard as a requirement to travel via aircraft, etc,” the school said in a statement to graduates.

Peters agreed, saying the Board’s ongoing public consultation process is key to raising awareness of concerns with the current draft.

“There may be a role for standards . . . but when those standards start impairing and undermining hard-won rights, we need to stop and rethink this whole thing.”

The board [accepted] online submissions until July 14.

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