Providers and users of guide dogs for the visually impaired say new proposed federal standards for service dog teams disregard their current needs and could pose barriers to future access.
The Canadian General Standards Board issued draft guidelines meant to serve as best practices for a wide range of people with disabilities and their canine service partners.
The standard, which is not finalized, proposes a vetting system to determine if someone is suitable for a dog, scrutiny into the team’s home life and stringent restrictions on the types of equipment and commands service teams can use.
But guide dog users and the schools that train them say the Canadian standard was shaped without regard to international guidelines that have served the industry well for decades.
They argue the proposed rules would force schools to either change their time-tested training programs or possibly stop serving Canadian students altogether.
The standard, they say, ignores the unique needs of guide dog users and the specialized tasks their dogs need to perform.
Yvonne Peters, a human rights lawyer and long-time guide dog handler, described the current version of the standard as a one-size-fits-all approach to disabilities ranging from deafness to epilepsy.
Much of the language, she argued, is not applicable to people with visual impairments.
“There are things within the standard that are totally irrelevant, totally unnecessary, and totally onerous that would be imposed on us as dog guide users,” Peters said in a telephone interview from Winnipeg.
The standard, for instance, suggests service dog teams should avoid hazards such as hot pavement, winter conditions or broken glass.
Seasoned handlers and trainers said that’s unrealistic, since blind people rely on their service animals to navigate through and around those exact conditions.
Advocacy group Guide Dog Users of Canada said they raised such issues during the shaping of the standard, but said their concerns are not currently reflected in the document.
The national standard was shaped with input from groups across Canada and funded by Veterans Affairs Canada, whose interest in the issue was driven by the growing presence of dogs to treat post-traumatic stress disorder.
Jacqeline Jodoin, the senior director of the Canadian General Standards Board, stressed that the standard is still in draft form and is not a certification or licensing program, though it could become the basis for one down the road if it is adopted in regulations or legislation.
She said having standard in place could limit the presence of poorly trained dogs.
“The goal and the scope of this standard is really to focus on service dog teams, . . . safe public access for service dog teams, and making sure that persons with disabilities wishing to train their own service dogs have information on how to do that.”
Guide dog users and trainers say the standard is too blunt an instrument to tackle those issues and undercuts systems that are already in place elsewhere.
The draft standard suggests all applicants should be evaluated by a third-party to determine whether someone has a disability and if they’d benefit from having a dog, duplicating protocols already in place at accredited schools.
The standard also proposes to forbid training methods at the heart of programs that Canadians have been using for decades.
For instance, it states that only positive reinforcement techniques such as food or affection-based rewards would be acceptable when working with any kind of service dog.
The standard lists all negative reinforcements as “unacceptable,” including verbal reprimands or physical tugs on the leash to focus the dog’s attention.
“There are times that our dogs do need to be corrected while in public, no matter how seasoned they may be,” wrote guide dog user Robert Fenton in a submission to the Standards Board speaking out against the draft.
“Removing the ability of a handler to correct their dog verbally or through the use of a leash correction, solely to satisfy the public, may ultimately put our safety at risk.”
Fenton said the board should allow exemptions for teams trained at schools that are already accredited by global organizations such as the International Guide Dog Federation or Assistance Dogs International, arguing they have developed standards that have served both the visually impaired community and the public at large well for years.
The Seeing Eye, one of the world’s most prominent and acclaimed guide dog providers, said failing to do so could make it difficult to serve Canadian students if the standards ever become law.
Greg Thompson, president of Guide Dog Users of Canada, said the International Guide Dog Federation rules were developed by people in the industry to regulate themselves, speculating that may be why the Canadian Standards Board chose not to reference them at all in the document.
Still, he said the organization has provided strong oversight and should be acknowledged in future Canadian rules.
Some certified Canadian schools agree.
“We don’t feel the need for our schools and our graduates to have any further standards defined for them because they’re already achieving really high standards,” said Sandy Turney, executive Director of Lions Foundation of Canada Dog Guides in Oakville, Ont.
Similar sentiments came from Ottawa-based Canadian Guide Dogs for the Blind, who raised concerns that today’s voluntary standards could become tomorrow’s policies that limit accessibility for the visually impaired.
“An industry standard is not a law, but may be used by national regulatory bodies such as Transport Canada, who may choose to adopt the standard as a requirement to travel via aircraft, etc,” the school said in a statement to graduates.
Peters agreed, saying the Board’s ongoing public consultation process is key to raising awareness of concerns with the current draft.
“There may be a role for standards . . . but when those standards start impairing and undermining hard-won rights, we need to stop and rethink this whole thing.”
The board is currently accepting online submissions until July 14.