Canadian Service Dog Standard – A Failed Process – Chapter 3

Chapter 3: “Using the Wrong Approach – Standards versus Public Policy”

There is a lot of ground to cover here, and this chapter is going to be a little bit theoretical and legalistic.

BUT WAIT!

Don’t stop reading – this is important material for a full understanding of what happened when the Canadian General Standards Board (CGSB) prepared its draft service dog team standard, and why it feels so wrong for guide dog users and others.

Guide dog users have been told not to worry because CGSB standards are voluntary. But, disabled people around the world know that voluntary standards can be used to diminish their rights, and it is only a matter of time before they become mandatory. We will explore this idea of voluntary standards versus mandatory public policy.

CGSB operates in a way that is based on the work they were set up to do. We will examine that context and why it does not lend itself to successful public policy formulation.

Organizations that prepare standards and those that undertake public policy development both operate within a set of principles; however, they are each very different. We will compare CGSB principles to good public policy principles to learn more about why the draft standard misses the mark.

Finally, we will look at the idea that CGSB does not have the legal authority to make a standard for service dogs.

So, grab a cup of coffee, or tea (or whatever), and let’s get started.

Standard, or Public Policy? A Question of Intent

CGSB’s draft service dog team standard says, “this Standard does not preclude or override any applicable regulatory or legal requirements”. Therefore, CGSB officials emphasize that the draft standard would be voluntary and does not constitute policy. However, the draft standard goes on to say that, “it may be referenced as a benchmark to support commonality of regulations / legislation for service dog teams across Canada”; and, the draft standard also says that, “this Standard is intended for use primarily by regulators”, among others.

During meetings of CGSB’s Committee on Service Dogs, many references were made about pushing regulators to embed this standard in regulation, and about how much easier it is to have a standard developed than a regulation. The Committee even changed their scope to include the idea that the standard would “facilitate regulations”. The airline industry’s representative talked about different airlines being able to use the standard across Canada; this statement was made without the least worry that such an action would make the standard “policy by default”, place disabled travelers in a state of confusion, and put additional pressure on provinces to adopt the standard into their regulations.

Clearly, it is the intent of CGSB and its Committee to have the standard applied across Canada, and to encourage provinces to adopt it into provincial regulation. Some of the Committee members seem to be using the standard-setting process to achieve their own agendas by doing an “end run” around the provincial regulatory process.

It is noteworthy that there is only one provincial regulator who is a voting member of the Committee on Service Dogs, and that province failed to participate in any of the Committee meetings for which minutes have been made public (NB, minutes for one or two subsequent meetings are awaiting Committee approval before being released, so whether any provincial representatives attended those meetings is unknown). Are the provinces aware that this activity is going on, the implications for their programs and services, and the impact on the rights of people with disabilities?

In the context of making a standard that affects the daily lives of vulnerable individuals – those whose rights have historically been trampled, and who have had to fight long battles to be recognized as full citizens – any indication that a “voluntary” process is being developed by the government will create significant concern. Then, when it becomes clear that the committee developing the standard wants and intends it to become mandatory, it will quickly be understood by disabled Canadians that the “standard” is in fact government policy and is “voluntary” in name only.

Standards versus Public Policy – the Context of Different Approaches

We now understand that this draft standard is a public policy proposal, but it was developed by a group whose role is to develop voluntary standards. So, what’s the difference?

The context for a standard development exercise compared to one designed to develop public policy is significantly different, but because CGSB does not have policy expertise, their process falls short across every aspects of public policy development.

The CGSB standards milieu is technical; the focus is on things (products or services), industries, or technologies. On the other hand, the public policy milieu is fluid, the focus is on people and their interactions in society. As a result, the draft standard has a stronger focus on dogs (i.e., a thing), rather than handlers (i.e., the person).

The CGSB standards approach values uniformity and compliance and recognizes that success can be achieved within predictability. On the other hand, the public policy approach values diversity and uniqueness and recognizes that success can be achieved despite unpredictability. As a result, the draft standard requires onerous qualification and assessment processes that infringe on peoples’ rights rather than giving people agency to make their own decisions in consultation with accredited training schools.

The CGSB standards paradigm requires training, instructions, and best practices to ensure those involved know exactly how to act to achieve success. On the other hand, the public policy paradigm requires education, knowledge, and good principles to ensure those involved know how to think to achieve success. As a result, the draft standard focuses on inputs and through-puts rather than outputs and outcomes.

CGSB is not designed for, or experienced in, developing public policy, especially in areas where human services are involved. The CGSB policies and procedures focus on the economy, trade and commerce, and technical product and process specifications, not human services. This is reinforced when many references in CGSB material are made to “consumers” (i.e., an economic unit) rather than people or citizens. An obvious illustration of this contextual problem is that the newly created CGSB Committee on Service Dogs was given an example of an existing standard as part of their orientation – the closest existing standard that CGSB could find to illustrate the task ahead relates to organic agriculture!

The CGSB standards approach does not reside in a public policy development context; thus, it is inadequate to address the needs of service dog, hearing dog, and guide dog users across the country. Because of these shortcomings, the draft standard will not suit any modern regulatory agency as a jumping-off point for regulations.

Comparison of Principles

To further emphasize the difference between voluntary standards development and public policy development, we need to look at the principles that guide and inform each of these different activities. By comparing the different principles, we will gain a deeper understanding about why CGSB’s scope change in October 2015 is so important.

CGSB Principles

The first stated policy within the CGSB Policy and Procedures Manual says that CGSB bases its standards development process on “ISO Guide 69”. However, the International Organization for Standards (ISO) has withdrawn this standard. It is no longer available for the public to purchase, so it is not clear how, or whether, ISO’s withdrawal of Guide 69 affects the principles that guide CGSB.

There are many principles listed in CGSB’s Policy and Procedures Manual. It is a bit lengthy, but a summary of them is reproduced here for readers’ reference. Some are good statements of principle, but many are process-oriented and tend to be inward-looking:

  • Canadian principles, including:
    • consensus
    • equal access and effective participation by concerned interests
    • respect for diverse interests and identification of those who should be afforded access to provide the needed balance of interests
    • mechanism for dispute resolution
    • openness and transparency
    • open access by interested parties to the procedures guiding the standards development process
    • clarity with respect to the processes
  • Canadian interests, including:
    • Canadian economy
    • Sustainable development
    • Health, safety and welfare of workers and the public
    • Assist consumers by facilitating choice, promoting consistent design quality, and providing consumers with safer, healthier and more environmentally sound products and services
  • Standards should be based on the consolidated results of science, technology and experience, and aimed at the promotion of optimum community benefit
  • Avoiding duplication
  • Timeliness in the consideration for the development of new or revised standards
  • Sufficient and competent staff
  • Documentation retention
  • Standards harmonization with international community
  • Give due consideration to the adoption of relevant regional standards, International Standards, and other regional/international deliverables
  • International and regional co-operation
  • Ensure that standards are not developed to create unnecessary obstacles to international and/or inter-provincial trade
  • Standards should be developed to meet the needs of the marketplace and should contribute to advancing trade in the broadest possible geographical and economic contexts
  • Ensure that standards are not developed to fix prices, exclude competition or otherwise inhibit commerce beyond what is necessary to meet requirements of relevant technical regulations or other legitimate sectoral or local requirements for compatibility, environmental protection, health and safety
  • Ensure that standards are not developed to discriminate among products based on the place of origin
  • Safeguard that the source of the materials for the product of a standard is not prescriptive as to specify one location where they may be obtained
  • Resolve identified instances of unjustified discrimination, and remove the potential for future instances
  • Intellectual property
    • Do not specify the use of trademarked, patented, or patent pending material, products, processes or apparatus, or any constituent thereof, unless there is only one suitable material, product, process or apparatus, or constituent thereof available or a technical justification exists

Public Policy Principles

Principles of good public policy are summarized below (source: Developing Public Policy: A Practical Guide by Bobby Siu; Canadian Scholars Press, ©2014). These are higher-level principle statements than those used by CGSB, and they are all outward-looking ideas:

  • Balance of public interests – are the interests of the diverse and varied stakeholders reflected and well-balanced in the policy
  • Accountability – is an accountability framework well articulated
  • Impact – are the objectives and expected impacts of the public policy explicitly stated
  • Cost effectiveness – is the policy the most cost-effective way to solve the policy problem(s)
  • Justice – is the policy just to everyone affected by its implementation, and does it reflect the hallmarks of social justice:
    • Each person is entitled to the most extensive set of basic liberties compatible with the same liberty for all (liberty principle)
    • All positions of public responsibility or private advantage should be open to all based on fair equality of opportunity (fair opportunity principle)
    • Any inequality in the distribution of resources for a good life is permissible only insofar as it is to the advantage of the worst-off group in society (difference principle)
  • Balance of short- and long-term considerations – is the policy both present- and future-oriented

Commentary on Principles – Impact

Some of the CGSB principles fit with good public policy principles, but there are key areas where the two sets of principles diverge. We will specifically discuss “accountability” in a later chapter; so, setting that aside, we will begin by considering “impact”.

The idea of “impact” is that every public policy tries to solve a problem. A public problem leads to negative impacts, and through the development and implementation of a new policy, the negative impacts ought to be eliminated or at least mitigated. This means that every policy needs to have formal explicit, clear, and consistent objectives. The draft service dog team standard does not.

This requirement to consider impacts is not evident in the CGSB principles; rather, their principles are geared to guide the standards development activity itself, rather than consider any public impacts other than the need to enhance trade. Why would their principles not consider the impact question? The only logical answer is that CGSB assumes the impacts have been analyzed by others. Somebody else does the policy analysis and decides that a standard is the solution to a public problem, then CGSB just develops a standard the best way they know how – some other organization is responsible for implementation and the impacts of the policy.

To put this into focus with the service dog team draft standard, you will remember from Chapter 2 how the Canadian Foundation for Animal-Assisted Support Services (CFAS), Veterans Affairs Canada (VAC), and others were engaged in years of meetings looking at problems related to PTSD dogs. CGSB participated in many of those meetings. If we consider for a moment that those meetings were a type of public policy development process, this puts CGSB’s draft standard in a new light. All the meetings during 2013 – 2015 would have defined a problem, looked at impacts, discussed what options might be suitable to mitigate those impacts, and concluded that a national standard for PTSD dogs was the solution.

Regardless of the flaws in the VAC / CFAS process, it would be logical that CGSB would not see itself as “owning” the impact responsibility; rather, they are just responsible to develop a national standard according to their normal way of doing business to meet the expectations of VAC and CFAS (the originators and owners of the process that drove the “policy decision”).

However, where CGSB becomes culpable is when they allowed the Committee on Service Dogs to dramatically increase its scope. Now, none of the policy analysis that might have been done by VAC has any relevance to the work that was being conducted by CGSB; yet, the process continued. CGSB effectively took responsibility for a public policy development process of massive scope without doing any of the ground work necessary for it to be successful.

Commentary on Principles – Justice

The idea of “justice”, and especially “social justice”, is absent from CGSB principles. In the normal course of their business, CGSB relies on the concept of “consensus”, and would have no need to consider whether the rights of some people (even the majority) may need to be knowingly and intentionally compromised to protect the rights of others. Yet, this is a reality of developing public policy in the disability arena.

CGSB does not have the skills or abilities to tackle issues raised by social justice concerns, nor did it create a Committee on Service Dogs with these skills. What is more, it is not legally positioned to address these questions. By attempting to draft a standard that impacts the daily lives of disabled Canadians, they have naturally bumped into (and glossed over) areas where social justice considerations needed to be addressed, and weren’t.

Jurisdiction – Canada Versus the Provinces

Under Canada’s constitution, provinces are responsible for, among other things, health, education, social services, property and civil rights. The draft standard is firmly embedded within this scope. It deals with the definition of disability, who may access service dogs, hearing dogs, and guide dogs as a result of a disability, what personal and private information must be provided and to whom in order to qualify to obtain and use a dog, how the dog may be used, what places and facilities must allow access, what objections may be valid for disallowing a dog / handler team access, the terms and conditions related to the care and training of dogs, and the processes related to ensuring the well-being of the dog / handler team. This entire draft standard sits within provincial jurisdiction.

Given the clear intention to force these standards across the country, it would seem the provinces should have been well-represented on CGSB’s Committee on Service Dogs, but they were not.

The areas covered by this draft standard fall within the jurisdiction of provincial governments. The Government of Canada does not have jurisdiction to make either standards or public policy in these areas.

Conclusion and What’s Next

We have seen that CGSB and its Committee on Service Dogs intended to develop public policy related to service dogs, hearing dogs, and guide dogs, but they are not qualified to do so. Whatever public policy development process CGSB might be relying on (e.g., VAC), fails to reflect good public policy principles in relation to the expanded scope of the project. Furthermore, the Government of Canada does not have jurisdiction to develop standards or policies in this area without the full participation and agreement of the provinces.

Tomorrow we will continue our look at standards versus public policy, but this time drilling down beyond today’s look at context, principles, and jurisdiction, to look at the processes used by CGSB for standard development compared to the processes typical in good public policy development. We will see areas where CGSB violated their own process requirements. So, please return for the fourth instalment of A Failed Process. Chapter 4 is called, “Non-Compliance – A Look at Processes”.

–James L Menzies

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Canadian Service Dog Standard – A Failed Process – Chapter 2

Chapter 2: Myopia and Disenfranchisement – Background to What Happened

In a report about processes, we need a chapter that covers the sequence of events. This is that. The details have been summarized and consolidated as much as possible to keep the size of this chapter manageable, while still covering key activities.

For those who are less familiar with the world of service dogs, we will start to introduce some definitions and some organizations. This will be helpful in later chapters.

You will see how the Canadian process ignored important developments in the United States that could have moved the ball forward much faster for veterans suffering from Post Traumatic Stress Disorder (PTSD). Also, we will discuss the sudden and unexpected change in the scope of work being done by the Canadian General Standards Board (CGSB) that gave rise to so much trouble for guide dog users and others.

Definitions and Three Organizations to Meet

It is generally accepted that “guide dogs” are for the blind and vision impaired, “hearing dogs” are for the deaf and hard of hearing, and “service dogs” are for people with disabilities other than those related to vision or hearing.

The International Guide Dog Federation (IGDF) is based in the UK and was formed in 1989. It is comprised of 92 organizations in 30 countries (5 Canadian organizations), whose purpose is to serve people who are blind or vision impaired by training and providing guide dogs. IGDF facilitates a sharing of knowledge, experience, high-quality standards, methodologies and help for new or existing schools wanting to improve the quality of their operations. All of this is focused on improving the safe independent mobility of blind and vision impaired people throughout the world. IGDF provides an accreditation and assessment process which ensures that operational standards are maintained and improved in relation to the world benchmark high quality standard.

Assistance Dogs International (ADI) is based in the US and was formed beginning in 1985 when a group of hearing dog organizations began gathering to develop common standards and guidelines. Today ADI has 129 organizations in 21 countries (8 Canadian organizations), which not only provide hearing dogs, but also service dogs for people who use power or manual wheelchairs, have balance issues, have various types of autism, need seizure alert or response, need to be alerted to other medical issues like low blood sugar, or have psychiatric disabilities. ADI establishes standards for the service dog industry ensuring that dogs are treated humanely, clients are treated with respect and dignity, and training is delivered in a professional way. Members of ADI have developed an accreditation manual and accreditation procedures to evaluate the quality standards of service dog programs.

The Canadian Foundation for Animal-Assisted Support Services (CFAS) is a fund-raising, public awareness, and lobbying organization whose mission is to improve the health and quality of life of people with physical, emotional, and social challenges through partnerships with companion and service animals. The organization has a background related to animal-assisted therapy and promoting the emotional aspects of the human-animal bond. They do not produce guide dogs, hearing dogs, or service dogs, and are not accredited by either IGDF or ADI.

The American Experience – A Chronology

In 2005, ADI-accredited schools in the United States began placing service dogs with veterans returning from Iraq and Afghanistan to mitigate their physical disabilities (of the 900,000 American soldiers injured in these conflicts, it is estimated that up to 50,000 may have been able to benefit from a service dog). Many wounded veterans began using the tasks trained to mitigate physical disabilities to help them cope with PTSD.
By 2008, ADI had started to design a program to meet the needs of veterans with PTSD – the Trauma Assistance Dog (TAD) Program. With the success of TAD, in 2010 ADI decided to develop standards for service dogs assisting with PTSD, and a committee was created to develop best practices. This committee’s work was presented at two ADI International Conferences (Barcelona in 2012, and Denver in 2014), and later became the basis for the ADI Provisional Guidelines for the placement of PTSD Service Dogs webinar that is now available for member organizations.

By 2015, ADI had commissioned a committee to take best practices and the provisional guidelines and develop a framework on which standards could be based. By mid-2016, the ADI standards and ethics committee was given the task of developing the framework into definitive standards. Once the standards are ratified by the ADI membership, any service dog organizations seeking accreditation for programs to place dogs with handlers who have military-related PTSD will have to meet these standards.

The Canadian Experience – Ignoring the Americans

Over an extended time, CFAS received concerns related to PTSD service dogs, especially regarding the cost of service dogs and the need for assistance to access public spaces. They decided this problem arose because there were no consensus-based standards for best practices or third-party credentialing processes for service dog trainers. This conclusion seems unusual, given the evidence that work was developing well in the US.

In 2013, responding to issues raised by veterans and lobbying by CFAS and others, Veterans Affairs Canada (VAC) commissioned a report on the use of service dogs to assist individuals with PTSD. The research team at McMaster University found the current international research to be inconclusive and, although there is anecdotal evidence of benefits, further research was required. It is not clear why ongoing work in the US was not considered valid.

In the second half of 2013, CFAS hosted two “Military Assistance Dog Summits” to raise awareness of the PTSD dog issue. They had taken the step of formally asking CGSB to develop a national standard for Canada, and CGSB presented at both summits.

Throughout 2014, stakeholder meetings were held involving VAC, the Department of National Defence, CFAS, and Wounded Warriors – a veterans’ support group. CGSB decided to move ahead with standard development, and in October 2014, convened a meeting to discuss the initial scope of a standard and potential project funding. Again, it is baffling why no organization made use of the work occurring in the US – by this time, ADI best practices had been developed.

In March 2015, the CBC reported that funding provided for PTSD dogs for veterans by many branches of the Royal Canadian Legion had been put on hold due to concerns about poorly trained dogs. This highlights the issue that, given the lack of progress in Canada, many small, unaccredited organizations or uncertified individual trainers had entered the Canadian market – fraud was beginning to occur, further victimizing PTSD sufferers along with funders.

In the Spring of 2015, CGSB signed an agreement with VAC for the Development of a National Standard of Canada for Service Dogs, and that Fall, VAC launched a concurrent pilot study of service dogs to support those with PTSD. (The research team from Laval University expects that a phase 1 report will be complete by November 2017, followed by a final report in July 2018, but it has not been disclosed whether they will reference American experience in this area.)

In October 2015, CGSB held the first meeting of its newly-formed Committee on Service Dogs to develop a “service dog standard”. During this first meeting, the scope of the project was changed by the Committee from a focus on just PTSD dogs to include all guide dogs, hearing dogs, and service dogs in Canada.

The CGSB Committee on Service Dogs continued to meet through April 2017 when a “public enquiry” stage was initiated. From May to June 2017, CGSB’s Public Enquiry stage for the draft service dog team standard was opened. However, there was no broad public announcement or press release from CGSB, so blind Canadians were largely “in the dark”. A few messages were circulated on several small email lists inviting feedback, but the format of the CGSB document and CGSB’s comment form were inaccessible to the blind, so it gained little attention or traction in the blind community.

On June 27, 2017, two American guide dog schools alerted their Canadian graduates to the draft standard, which raised awareness and alarms. At the same time, several people were working through the Canadian Human Rights Commission, their Members of Parliament, and other people in their networks to get the CGSB website made more accessible and to accept general comments in letter form. These appeals to the CGSB gained a two-week extension for comments, to July 14, 2017.

Until late June, when guide dog users received letters of concern from their respective guide dog schools in the US and pressure from advocates through human rights and political avenues had an impact, most guide dog users in Canada did not know that a draft standard was being developed. So, most blind Canadians only had from June 27 to July 14 to understand that a draft standard had been developed which would affect their daily lives, review and discuss the draft, formulate responses, and submit their comments – a process where others had been involved for years.

Why Did We Not Piggy-Back on Existing American Progress?

Veterans in Canada and the United States were experiencing PTSD at the same times, and many were finding that having a service dog was an effective approach to help deal with their PTSD-related issues. Although this was not in a controlled academic environment, real experience, and especially the size and complexity of the American experience, indicated that PTSD dogs were worth pursuing.

No good answer has been given for why Canadian organizations did not avail themselves of the American experience, especially given that ADI has 8 accredited organizations in Canada. ADI is represented on CGSB’s Committee on Service Dogs, but their voice was drowned out. One must ask, what were the motives of other committee members to ignore a solution that was readily at hand?

Then, when the CGSB Committee on Service Dogs increased their scope to include guide dogs, why was no credence given to IGDF standards and accreditation processes? CGSB has suggested that ADI and IGDF standards are not “consensus based”. However, given these organizations’ histories, scope, positive global reputation, and documented process of researching and developing standards, CGSB’s position is hard to swallow. It also seems disingenuous, given the poor quality of CGSB’s public enquiry phase on this draft standard.

Scope Change

In May 2014, Mr. Pablo Sobrino (Associate Assistant Deputy Minister, Acquisitions Branch, Department of Public Works and Government Services) spoke before the Standing Committee on Government Operations and Estimates and said, “CGSB was also recently approached to develop a standard for psychiatric service dogs. These dogs may be used to assist people with post-traumatic stress disorder, for instance.” Senior leadership and Parliament had a clear picture of the scope of work that was to be undertaken by CGSB.

However, at its first meeting, the CGSB Committee on Service Dogs increased its own scope from just PTSD dogs to include all guide dogs, hearing dogs, and service dogs. The Committee was constituted to address an area where standards were newly being developed in America (and did not yet exist in Canada), where small unaccredited training organizations were creating problems, where the rights of dog handlers were unclear and untested, but where some very specific work by ADI could have been brought to the table to realize quick wins for all concerned. Instead, the Committee moved into areas where there are decades of global experience, reputable accrediting bodies, excellent training schools, a solid human rights environment, and mature funding streams. And within this newly expanded scope, the committee seemed intent on ignoring the existing standards, and infringing upon or diminishing the existing rights of dog handlers.

It is important to emphasize the significance of this change in scope. There was no apparent effort by CGSB to pull the group back or re-frame the discussion. Simply put, with this change in definition, the entire project changed, along with the nature of the stakeholder groups that would be affected. An Access to Information request has been submitted to determine whether this increased scope was vetted and approved at higher management levels, and if the Minister was made aware (given that Parliament had been informed of the smaller scope).
With this scope change now affecting many more stakeholders, schools and accreditation bodies began lining up against the draft standard, including ADI and IGDF. Service dog and guide dog users across the country are fearful that their hard-won rights are being withdrawn, and that the draft standard has such onerous and intrusive requirements that they may not be able to access a service or guide dog in the future. Indeed, some American schools have indicated that they may no longer accept Canadians into their programs if the draft standard is put in place.

Conclusion and What’s Next

To the average Canadian, ignoring US developments regarding PTSD dogs seems myopic, and the result of this myopia is that PTSD dog standards in Canada will be delayed years longer than they needed to be, more veterans will suffer longer, and unaccredited trainers will continue to take advantage of veterans and funders.

Between the sudden and unexpected increase in scope, the lack of a meaningful public consultation process, and the unnecessary intrusion into a well-established, accreditation-driven environment, disabled Canadians are feeling they have been disenfranchised by a committee that seems to be accountable only to itself.

Please come back  for the third instalment of A Failed Process. Chapter 3 is called, “Using the Wrong Approach – Standards versus Public Policy”.
–James L Menzies

Canadian Service Dog Standard – A Failed Process – Chapter 1

Jim Menzies has compiled a report about the processes and procedures of the Canadian General Standards Board (CGSB) as they relate to the draft Service Dog Standard. Jim and his wife, Jean, have done as much background research as possible to better understand how this process started, and how it all went so badly wrong.

This six-part report is based on research using the CGSB’s own procedure manual, looking at what they should have done compared to what was done. It presents a contrast between the outcome to date and the original mandate.

Each chapter in this piece will be post separately here and the whole document can be viewed, on completion, on either Hands Off Our Harnesses or the Menzies’s own blog, Canadian Guide Dog.

Chapter 1: Introduction

Background

The Canadian General Standards Board (CGSB) is an arm of the Government of Canada – part of Public Services and Procurement Canada. In their own words, they “offer client-centred, comprehensive standards development and conformity assessment services in support of the economic, regulatory, procurement, health, safety and environmental interests of our stakeholders — government, industry and consumers”. Having a national standard-setting organization is a good idea.

Recently, CGSB released a draft standard for service dog teams in Canada so public comment could occur. There was a significant outpouring of negative commentary, especially from blind people who use guide dogs and their supporters. It was estimated that some 1,000 pages of commentary were received related to this sixty-page draft standard. Letters, phone calls, and meetings continue with elected officials; human rights organizations have been engaged, news outlets have had coverage, international standard-setting bodies have been contacted, and social media commentary is occurring. Every indication suggests that strong advocacy efforts against this draft standard will continue.

How could things have gone so wrong?

It is dismaying that this draft standard was developed by a Government of Canada agency, and landed in peoples’ laps with little, if any, notice. The draft standard itself seems ill-conceived and likely would violate the human rights of disabled Canadians.

There are many people who are advocating against this draft standard based on the content of the document. However, the report that will be posted here, entitled A Failed Process, leaves the content of the draft standard to others, and reviews the process that was followed in the belief that good process leads to good results, and bad results must mean there was a process problem.

Approach

Research for this report has been based mostly on publicly-available information. Discussions occurred with some individuals who are advocating against the content of the draft standard, one conversation occurred with a representative from CGSB, and two Access to Information requests were filed.

Responses to the Access to Information requests have not yet been received; however, there are important time constraints related to the continuing CGSB process. Rather than wait for responses that might not arrive in time, there is enough information already gathered to warrant publishing findings and comments so they can be considered by decision-makers in a timely way. Further insights will be shared as more information becomes available, and as the CGSB process continues.

Looking Ahead

Today’s blog post is simply an introduction. It is the first of six blog posts regarding the process that gave rise to the draft service dog team standard. A new post will be published every day or two.

These documents are being shared publicly with three objectives:

  • To provide an understanding of the process undertaken by CGSB so advocates can see where, when, how, and why things went wrong;
  • To contribute to the broader public discussion regarding standard-setting in the world of service dogs and guide dogs; and
  • To publicly show decision-makers that this standard-setting exercise needs to be stopped, and to provide some thoughts on how a better process might proceed.

Once all six chapters of this report are posted, they will be consolidated with any new information into a formal report which will be shared privately with decision-makers and oversight bodies.

The views contained in these blog posts are those of the author, who is responsible for and owns the content. If there are missteps or errors, the author stands to be corrected, but based on the research to date, remains resolute in the understanding that CGSB’s draft service dog standard is bad public policy.

Please come back tomorrow for the second installment of A Failed Process. Chapter 2 is called, “Myopia and Disenfranchisement – Background to What Happened”.

–James L Menzies