Well, Canada’s federal government is once again mounting another attack on guide and service dog handlers.
Now the Canadian Transportation Agency is proposing that all guide and service dog handlers provide documentation and register with all federally regulated modes of transportation if they wish to travel.
They are requesting that an accredited professional service animal training institution certify that our dogs are indeed trained. No definition of what they mean by such an institution.
They also want a vet to provide a up-to-date vaccination record. Okay, maybe to some this sounds reasonable, but the CTA offers no rationale or explanation as to how this will improve passenger service.
I have traveled for about 40 years with my guide dog and never been asked for documentation. My speculation is that maybe people have been trying to pass their pets off as service dogs and causing problems once onboard. So why not go after those fakers? Why put the burden on persons with legitimate guide and service dogs? Such action is contrary to how are society normally addresses crime or wrongdoing.
Maybe we should level the playing field and ask other groups to also register and provide documentation of their ability to travel. For example, doctors could be asked to certify that passengers will not cough and sneeze on fellow passengers; social workers could certify that parents are trained to manage their children while in the air; and an addictions counsellor could certify that passengers are capable of drinking responsibly while flying.
This constant demand to prove legitimacy is getting so tiresome and an erosion of our rights. Traveling with a guide or service dog is not a luxury or life style. It is a human right confirmed by Canadian law.
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.
- Debriefing regarding the withdrawal of the Canadian General Standards Board , CGSB, in continuing with the writing of Standards
- Future steps of the Coalition
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.
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.
- 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.
- 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 email@example.com. 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.
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.
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.
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.
- 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:
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.
- 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.
- 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.
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.
Co-Chair – CGSB Technical Committee on Service Dog Standards
Kristine Aanderson Consulting Services
Co-Chair – CGSB Technical Committee on Service Dog Standards
Executive Director, National Service Dogs
Specialized Services Sector
Integrated Services Branch
Public Services and Procurement
Via email: firstname.lastname@example.org
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.
Greg Thompson Christine Switzer
President TC Voting Member
Guide Dog Users of Canada Guide Dog Users of Canada