CNIB's response to the Canadian General Standards Board's draft standard for service dog teams

7/10/2017

The Canadian General Standards Board (CGSB) is developing a set of standards for service dog teams in Canada, with a view to ensuring a high degree of quality and safety. CGSB recently invited individuals and organizations to provide feedback on their latest draft of these standards.

After carefully reviewing this draft, CNIB has a number of concerns relating to the standard's appropriateness when it comes to guide dogs for people with sight loss – a unique category amongst service dog teams. Our official response can be found below.

CNIB encourages guide dog users and other interested stakeholders to review the standard and participate in the feedback process, which is open until Friday, July 14.

Official response

As the leading organization that serves and supports the more than half a million Canadians who are blind and partially sighted, the Canadian National Institute for the Blind (CNIB) commends the Canadian General Standards Board (CGSB) for taking the initiative to review standards for service dog teams. Ensuring a high-quality working team is essential for the safety and quality of life of people with disabilities in Canada.

However, we must take this opportunity to voice our serious concerns about the draft standard for service dog teams recently released by CGSB for public input.

In particular, we are gravely concerned that the draft standard does not take into account the internationally recognized, highly rigorous International Guide Dog Federation (IGDF) standards for the breeding, training, placement, care and handling of guide dogs for people with sight loss. Established more than 25 years ago through a collaborative, peer-reviewed process and regularly reviewed and updated, the IGDF's standards account for the specific considerations that come into play when the disability in question is blindness, and the handler's safe mobility is at stake.

The IGDF standards demand an unparalleled degree of quality at every stage of the guide dog process in order to maximize the safety and success of working teams. These standards call for rigorous screening of applicants to ensure their readiness and ability to work and care for a guide dog, and require accredited organizations to provide ongoing support and supplementary training to graduates throughout the working life of the dog.

We understand and support the need to ensure that service dog teams across all categories are properly trained; however, in the case of guide dog teams specifically, teams graduating from IGDF-accredited organizations meet if not surpass the requirements of the CGSB draft standard. Requiring these teams to undergo the additional scrutiny set out in the draft standard is both unnecessary and intrusive.

It is therefore CNIB's recommendation that the Canadian General Standards Board amend the draft standard to create a separate section for guide dogs for people who are blind, which utilizes existing International Guide Dog Federation standards in place of those proposed – and that all guide dog teams trained by IGDF-accredited schools be explicitly exempted from the associated assessment process, and automatically recognized as certified.

More than 90 organizations internationally are members of the IGDF – among them, Guide Dogs for the Blind and The Seeing Eye, two highly regarded American guide dog schools. We share the perspectives these schools have expressed in their own submissions to the CGSB, and echo the concerns they express about the potential implications of the draft standard on cross-border training.

By CNIB's estimates, IGDF-accredited American schools have trained more than 75 per cent of the active guide dog teams in Canada today. One of the reasons is that the existing capacity for guide dog production and training in Canada is not sufficient to meet the need. The requirement for American and international schools to train to a country-specific standard risks will create barriers for these schools to serve Canadians – barriers we simply cannot afford as long as the domestic guide dog supply falls so short of demand.

We understand that the draft standard was brought about, in part, to increase the availability of properly trained service dogs. But for the reasons above, we fear it could have precisely the opposite effect for our community.

At this time, CNIB has not provided in-depth commentary on the draft standard in light of our pervasive concerns. However, if our suggested amendments are not incorporated, it will be essential for CNIB and other accredited guide dog organizations to execute a clause-by-clause review and propose specific edits to ensure the standard is both reasonable and appropriate when it comes to guide dogs for people with sight loss.

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