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Comments on the Proposed National Service Dog Standard

Date: 
Thursday, July 13, 2017

The AEBC submitted these comments in response to the proposed Service Dog standard developed by the Canadian General Standards Board (CAN/CGSB-193.1 - Service Dog Teams / 11.180.99).

Introduction

The Alliance for equality of Blind Canadians is pleased to be submitting our comments on the proposed National Service Dog Standard. As we are a consumer organization comprised of people who are blind, partially sighted or deaf/blind, our comments will mainly focus on the concerns of those who use guide dogs. We do not have enough knowledge to comment on the use of other service dogs in a significant fashion. Since many of our comments are of a general nature, we will only refer to specific sections of the proposed standard where we have specific issues with specific clauses.

For nearly 90 years now, guide dogs have been trained in North America since The Seeing Eye trained their first dog to guide a blind person in 1929. Since this time, several guide dog training schools have been developed and guide dogs have been in Canada for nearly 75 years now. Because of this long history, the training standards have been evolving to the point that guide dogs are probably the most highly trained and cared for service dogs.

Over the years, guide dog training institutions have been working more closely together. As a result, they now have an international certification body called International Guide Dog Federation. The role of this body is to ensure the highest standards are maintained for its members. The standards ensure that all guide dogs are trained in a humane fashion, and that the schools assess the guide dog users to which they are applying. This is to make sure that having a guide dog is right for them. The application process looks at all aspects including a medical assessment and assessing the living conditions that the dog will be returning to as well. Also, all IGDF member institutions ensure that the welfare of the dog is always the number one priority. In addition, it is a top priority to ensure that the client receiving the dog receives as much training and support to ensure their ongoing success with a guide dog. Scope:

Generally, our organization is concerned with the overall scope of the proposed standard. We find this standard covers many areas that are quite paternalistic and intrusive on the lives of people who are blind, partially sighted or deaf/blind. For example, the requirement to evaluate the amount of play time is making a broad assumption that people are not completely cognizant of the responsibility of caring for a living animal.

because this proposed standard covers many areas that are already part of the application process for a guide dog, and guide dog users learn the skills for ensuring that their dogs are well cared for and perform their work in a confident manor, we believe that guide dogs should be exempted from this standard. Since all training schools for the most part in Canada and the United States are IGDF members, this should be the only requirement for guide dogs.

When looking further at the proposed scope of the standard, we feel that since section 1.5 of this standard may have language that involves overlapping jurisdictions, we feel that it may make things more confusing for all intended users of the standard. Section 1.3 of the standard may have some validity with service dogs that people train on their own, but in the case of guide dogs, even institutions that are not members of IGDF have training standards that in many ways achieve the objectives of this proposed standard.

Definitions

We have general concerns about this section. Many of the definitions appear to be quite limited and could pose problems when the standard is implemented. For example, the definition of disability in section 3.4 is unclear to us because of the reference to past dependence on drugs or alcohol. How would the disability be assessed by an independent assessor if they are not aware of how long the person may have been drug or alcohol free. We would suggest finding a more appropriate definition of disability to use for a service dog standard. Also, section 3.12 includes several examples of service dogs. Since we feel guide dogs should not be part of this standard, guide dogs should have a separate definition that also clearly indicates they are exempt from this standard.

Simple Service Dog Teams

As our organization reviewed the standard, we found this section of the standard perhaps the most concerning part of the document. As guide dog teams could fall under this portion of the document, we found many of the assumptions being made quite intrusive into the personal lives of people who are blind, partially sighted or deaf/blind. We have highlighted a few examples in subsections 4 and 5 that we will expand on now.

4.1.1.1.2 If the training institution is a member of ADI and IGDF, the person should not be required to find an independent assessor. The only external assessment that may be required would be the medical report forwarded to the training institution by the person's doctor. Also, a government assessor should not have to review this or any other documentation forwarded to the guide dog training institution as part of the person’s application, training, and qualification to have a guide dog.

4.1.2.2 It is unclear what would be required in the fir staid plan. Is this a written plan the person with a disability would prepare prior to an assessment? Also, many people who are blind may not be aware of danger at first but still can take the necessary steps to ensure the welfare of their dogs. As the job of a guide dog is to navigate sometimes hazardous situations, the person who is blind may not be aware of issues like broken glass until they are within the area. But as stated before, the welfare of the dog is what is promoted by all guide dog schools.

4.1.2.3 It should be generally assumed that if the service dog is from an IGDF or ADI institution that legislative protection guaranteeing public access is available and that other person’s rights should not override the rights that the user has with their service dog. The goal should always be that when there is conflict that any policy look at all issues and ensure that the guide dog team have full access as a priority and that any conflicting concern like dog allergies does not impede the full freedom of guide dog users.

4.1.2.5 Does this really need to be said in a policy statement? If the service dog is trained at a recognized training institution, there are already expectations that the dog user is expected to insure the dog's needs are recognized and met. The human animal bond is a key focus of all training programs and this includes what should not have to be in any standard such as assessing if people play with their dogs.

4.1.2.7 Guide dog users are aware of situations that cause stress and can find ways to relieve the stress. This is just one example of the issues why we feel guide dogs should not be included in this standard. Managing stress is a crucial part of guide dog training.

4.2.1 IGDF members and other guide dog training schools already have strict criteria and programs to ensure dog suitability for working in public areas. We suggest that government bodies should not require IGDF members at least to submit any documents on how they determine dog suitability.

5.1.1.3 This section has many issues. Many of the situations mentioned in this section are generally expected by training institutions who train guide dogs and people who are blind using guide dogs. Also, in the notes, specifically note 3 there should be nothing that states that access is only granted if there is no undue hardship. Undue hardship should not be mentioned when talking about public access rights for those being accompanied by a service dog. Undue hardship is such a vague concept and as a result, if it is in a standard, could increase the level of public access refusals for guide dog teams.

5.1.2.2 As training guide dogs is a detailed process and covers many essential areas for movement and mobility, the level of first aid knowledge required by this proposed standard would require the guide dog user to acquire this knowledge outside of their training program. As the number of accessible training programs is limited, this would be very difficult. Also, who would cover the cost of this type of training?

5.1.3 In the case of guide dog training, the handler is assessed and reviewed by the training institution and should not be required to prove this knowledge for public access as they have already been tested prior to finishing their training. this is true of any schools that are members of IGDF and ADI.

5.2.1.1 Would this list of equipment include items like slip chains and gentle leaders? These tools are used by IGDF training institutions and guide dog users are given specific instruction on how to safely use these tools to ensure the best working conditions for their dogs. Each dog is assessed to ensure that they receive the most appropriate equipment for their temperament.

5.3.1 In the case of guide dogs trained at IGDF schools, this matching process is done by the school and is not needed to be done again by an assessor. This section may not need to be part of a standard.

5.3.4.3.1 Instead of making it entirely the responsibility of the user, Legislation or standards should require penalties for the public when they intentionally interfere with a service dog and their handler. Some of the proposed solutions required to deal with distractions and aggressive dogs also would put the handlers’ safety at risk. For example, requiring a blind guide dog user to body block is not even part of any guide dog training.

Markings

in the case of guide dogs, all schools issue their own ID cards. this should be the only requirement for dogs trained at IGDF or ADI institutions. Also as each province issues some sort of provincial ID as well, having to carry another ID card is unnecessary. Furthermore, it would pose problems for people visiting from other countries like the United States. Finally, the information recommended to be placed on the dog is a violation of a person’s privacy rights.

Inspection

No guide dogs trained at IGDF or ADI member institutions should be required to complete a government inspection. All schools that are Members of IGDF and ADI complete their own annual inspections that look at the handler’s abilities and condition of the dog. Also, because the assessment is provided by a third party, the guide dog handler or user should not have to cover the costs of any additional assessment after they have graduated from their training program. Many of the proposed tasks in the assessment are assuming that the person who is blind, partially sighted, or deaf/blind lack knowledge and skills. In Addition, people who are blind should not be expected to be separated from their guide dogs in public places. this is one thing that would cause unnecessary stress on the dog.

Testing

The only time a guide dog may need to be tested by an external body is if the dog was either self-trained or trained by a school that is not a member of IGDF or ADI. Guide dogs are usually tested by the school prior to the client being qualified to use the dogs after a minimum number of hours of training.

9.1.2 If this testing is done, the training institutions will have to ensure their clients are aware of what may be expected. Frankly, some of the expectations may be unrealistic in a public situation. The key is that if the dog is well behaved, some of this proposed testing should not be an ongoing requirement. Expecting the dog and handler to be separated in a public place is unrealistic and should never happen even in some emergency situations. Also, they are still dogs and sometimes like humans, dogs have bad days and may need more guidance to ensure proper behaviour in public.

Conclusion

We have commented on the areas of the standard we feel are the most problematic and detrimental to people using guide dogs. As guide dogs have been around for so many years, their training standards are far superior to the training of many other service dogs and should be handled in a different manor. This proposed standard should focus on the role of service providers and ensuring they are responsible for producing well trained dogs in a humane manor. Just because we are dealing with people with disabilities, we should not put complete responsibility on them to prove they can manage a dog. We don’t expect this of parents caring for children until the authorities are informed of issues. This should be the same with guide and service dogs. The fact the standard focusses so much on the user is why we think it needs to not refer to guide dogs and why we think it is paternalistic and patronizing. It does nothing to promote the equality of people with disabilities.

Thank you for the opportunity to comment on the draft standard. We look forward to continued ongoing Dialog with the Canadian General Standards Board to ensure guide dogs are looked at in a manner that respects their uniqueness of their role in providing assistance to people who are blind, partially sighted or deaf/blind.