Re: CGSB Service Dogs Team Draft Standard
Firstly, on behalf of the International Guide Dog Federation (IGDF), I welcome the opportunity to comment on the Draft Standard created by CGSB in relation to Service Dog Teams.
In order to advise the CGSB of the credentials that the International Guide Dog Federation has in providing feedback on the proposed standard, we would offer the following background information.
History of IGDF
The idea of the International Federation of Guide Dog Schools for the Blind (IFGDSB) – as it was originally known – stems from conferences held in France (1973) and London (1976). At the conclusion of the third international conference in Vienna in 1983, attendees agreed the formation of a European-based group to consider “the formulation of guidelines and standards for the training of dogs and to teach blind people the use of dogs”.
It was recognised and acknowledged by the professionals producing guide dogs that a blind person had special and very particular requirements of a guide dog. A blind person needed to rely on the dog to safely guide them across a busy road consistently, to safely indicate the beginning and end of a flight of stairs (or an escalator), to avoid dangerous obstacles or trip hazards and not be distracted from the task of guiding. If a dog was inadequate in performing any of these tasks, then the blind person could potentially be seriously injured or even killed. At the same time, the dog had to behave and be presentable in public and not pose a threat to members of the community.
Much work was done from the 1920’s to determine the most appropriate behaviours to select for in breeding and the best training techniques to produce a guide dog that satisfied the requirements. For example, breeding to select for dogs with minimal dog distraction, food distraction or prey instinct reduced the chance that the dog would be distracted while guiding, etc. Training techniques used by trainers of many animals were investigated to develop the most effective way of training guide dogs, from 8 weeks of age, to focus on indicating hazards in a blind person’s path, indicating stairs and hesitating at a road crossing and then crossing in the most direct route when determined safe, etc.
The wealth of over 100 years of accumulated international knowledge by the best experts in the world on guide dogs on the subjects of breeding, training of dogs and training of trainers, dog care, etc., have been embedded into the IGDF standards.
In 1992, formal inspection of member schools began utilising these IGDF standards and, where standards were met, schools were accredited by a trained assessor in line with agreed operational guidelines.
Where standards were not met, action plans were agreed or membership was revoked.
As at the end of 2016, there are 91 member organisations (operating in 29 countries), 4 affiliate organisations and a further 29 organisations working towards achieving the standards set by the IGDF and, thereby, aiming for accredited membership.
Through these organisations, IGDF currently represents around 25,000 guide dog users currently working throughout the world.
In supporting these aims, one of the formal sub-committees of the IGDF is the Development Committee (DC). Through the DC, individual organisations seeking IGDF membership are afforded ‘expert’ advice and guidance in developing their services such that they do, indeed, meet the high standards required.
Collectively, the knowledge and experience of the modern guide dog movement can be traced back for more than 100 years. This knowledge and experience has led to the IGDF, as it stands today, representing the highest level of expertise within an extremely specialised field and with proven standards by which all members are measured.
The International Guide Dog Federation (IGDF) is the industry-elected peak body responsible for the development, monitoring and evaluation of the standards applied within all IGDF-member organisations, in order to ensure equity of high-quality service to guide dog users and handlers around the world.
It can take many years for a new organisation to achieve the required standards which will enable them to become an IGDF Member – and only following in-depth assessment by another of our ‘expert’ sub-committees (Accreditation Committee – AC). All member organisations are then re-assessed on a 5-yearly basis to ensure that the standards are maintained before their ongoing accreditation is approved.
The standards themselves go into great detail and cover the following key areas:
- Standard 1 – Applicant / Client selection
- Standard 2 – Client and Guide Dog Team instruction and follow-up
- Standard 3 – Technical Staff Education and Development
- Standard 4 – Guide Dog Mobility Instructor (GDMI) Education Programme
- Standard 5 – Humane care, training and treatment of Guide Dogs
- Standard 6 – Breeding, puppy raising and veterinary care
- Standard 7 – Guide dog assessment and training
- Standard 8 – Kennel specifications
- Standard 9 – Buildings and transport
- Standard 10 – Administration
These standards are continually monitored, reviewed and updated.
With the re-assurance that comes from a graduated dog / handler team from an IGDF member organisation, comes increased confidence – both for the individual relying upon their guide dog for safe, independent travel and, also, the wider public who need to know that the dog comes from a solid background which includes significant ‘public access’ training / testing and has been raised to the highest standards of health and welfare.
Ongoing assessment – both for the continued accreditation of a member organisation and, also, individual follow-up of each working dog / handler team – ensures that the high standards required are maintained.
IGDF standards are set, evaluated and reviewed such that quality, service and expectation is considered on a worldwide level – thus enabling equal access to international travel for all, regardless of a need to rely upon a guide dog for an individual’s independence.
Review of draft standards as proposed by CGSB
- There is neither acknowledgement, nor recognition of current IGDF (or ADI) standards.
- The proposal lacks clarity on its impact, strategies and governance.
- The printed standard is 61 pages long – a long and difficult document
- Focused on standardisation of the service dog team (which proposes to protect the public, the user and service dogs).
- Posits that wait times led to some trainers now entering the field that do not have the appropriate experience and education, resulting in self-trained teams without assistance and ‘fraudulent’ teams – whereby dogs are passed off as ‘service dogs’ but have had no relevant / formal training.
- Provides a basic benchmark for the performance of a service dog team but this is primarily focused on ‘simple’ obedience and a (one-off?) test for public access.
- Does require comprehensive knowledge on the handler’s part in several areas (a positive)
- The assessments appear onerous (for example – a veterinarian must provide proof that the dog is free from immediate or chronic stress, fear, anxiety, or discomfort, free of conditions that may interfere with their ability to work or may put the public at risk?).
- The proposed standard is voluntary at this time but, presumably, the intent is for regulators to use these standards as a basis for future regulation development.
- There is no focus on efficacy of tasks but it does provide a list of common tasks for different types of assistance dogs.
- Recommends against specific breeds for assistance dog work
- Specifically prohibits “positive punishment” and “negative reinforcement”. This would not allow for leash/collar corrections or the use of the word “no”. In the case of asking a dog to lie down, you would be prohibited from exerting any downward pressure with the collar. This is completely unrealistic as the majority of assistance dog users would not be able to adhere to this (or, crucially, pass the test).
Questions / concerns:
- What are the actual qualifications for the assessor and who is responsible for the assessment to occur?
- Who reviews the assessment reports and what are their qualifications?
- Is there a formal appeals process?
- Requires the assessor to verify the handler’s disability through a signed statement by a physician that they have a disability that may be mitigated through the use of service dog. How is that determined? Will the physician be required to assess the functional limitations of the person with the disability (which a dog would mitigate) or just the clinical diagnosis (which may not be relevant)?
- How often do the assessments need to take place? Does this only happen at the beginning of the team’s life together? What is the frequency of testing?
- What is the scale for determining whether the team has passed the inspection? How many things have to be passed? Are any failures acceptable? How do you determine the appropriate “matching” based on the chart and ratings?
- How will the assessments even be implemented? Who are the assessors? Will they work for a governmental agency? How will the assessors be trained?
- Is this grandfathered…or do all service dog users in Canada need to be assessed now? How many are in use currently?
- Will a team that has been successfully working in the field for many years fail because of any ‘simple’ aspect of the test (like taking a food distraction)
- How is the assessment addressing the actual tasks required of the graduated team? Are those to be graded as well? Who is working on that?
- What is the provision for ongoing revision of the standards?
- How will this affect the organisations that are currently providing dogs to the Canadian market? Will they possibly discontinue training Canadian clients? This is at odds with the stated objective at the beginning of the standard document.
- The standard appears to be at odds with disability discrimination legislation around the world, by which guide dog teams are permitted access based upon the high standard of training they receive from, in particular, IGDF member organisations. This proposal will have a likely detrimental impact upon visitors to Canada and, also, Canadian Guide Dog Users wishing to visit other countries.
The proposed standard does not allow for the recognition of any other global standard. It appears to be an attempt at an outcome standard but inherent with that direction is its focus on the human / dog team’s ability to behave and function in public areas (but in this case, very little focus on the dogs’ ability to perform the required tasks).
IGDF has struggled with the development of a specific outcome standard as it is difficult to find ways to implement an accreditation.
The ultimate outcome in any of our programs is how the handler and dog function together and whether this leads to enhanced mobility and an increase of independence for the individual. Ongoing follow-up for the working life of a guide dog team monitors and evaluates each case in line with the current standards.
IGDF standards are a code of practice and we have avoided being highly prescriptive to allow for required flexibility in individual application while offering indicative benchmarks. For example, the requirement of a blind person using a guide dog in a quiet / rural location is very different from someone using a guide dog in a busy / city environment. IGDF promote best practices learned through all of our shared experiences and providing for standards that can be applied around the globe. In addition, IGDF standards cover the many aspects of running a guide dog programme that are outside of the outcomes of individual teams (breeding, puppy rearing, training, aftercare, initial and ongoing staff development, etc.) – all important aspects of providing safe and effective guide dogs.
We understand that the Canadian Association of Guide Dog and Assistance Dogs strongly oppose these standards and, it appears, most of those organizations found out about this Board convening well after it had started its work. To that end, the proposal cannot be considered to be an inclusive endeavour. The IGDF supports this view.
Much of the “inspection” is unrealistic and would require considerable time and resources. A good example is the “Behavioural Evaluation” that suggests a different person be involved with as many as nine different tests in areas where the service dog does not reside or normally inhabit. Many of the other stipulations appear to not take visually impaired handlers into consideration, which, had the Canadian Association of Guide Dog and Assistance Dogs been involved from the outset, could have been avoided.
On top of that, can we imagine the stress and anxiety this would cause consumers? Why should they be put in the position of having to justify the accommodation of an assistance dog when the majority of them are going about their lives just fine? Is the Canadian government prepared to withhold the issuance of an identification card legitimizing a team when they have been traveling successfully for years because they failed a few points on the inspection? Is the test to be repeated periodically during the working life of the dog?
Having said all of that, we do respect much of the work that has been accomplished by the committee around these standards. I could see incorporating some aspects into our own standards and they do provide a structure for the assessment of clients, the education that needs to be delivered by programs and outcome expectations related to appropriate guide dog behaviour in public areas.
IGDF strongly recommends that the Canadian Standards Board fully recognise the IGDF and their proven, tried and tested, standards and, should the proposed CGSB standard be progressed, there should be no additional testing of graduates from member schools.
IGDF therefore respectfully proposes that the Canadian Standards Board recognises the IGDF standards, with their graduates being exempt from this regulation. The draft proposal may then be developed to certify (or not) owner-trained teams or non-IGDF member teams – an effective ‘marriage of convenience’, perhaps? At the same time, this could promote the benefits of IGDF membership to new organisations and, through the detailed accreditation process, encourage higher standards and expectations for all.
IGDF Board Chair