Dear Prime Minister Trudeau, Minister Qualtrough, and CGSB,

The Canadian Federation of the Blind is an organization composed of blind individuals, including many who work with guide dogs. We in the Canadian Federation of the Blind believe the approach taken by the Canadian General Standards Board in developing service dog standards is in direct conflict with the push for equal access implicit in the development of a new Canadian accessibility law. The underlying premise of this process also conflicts with the principles of the United Nations Convention on the Rights of Persons with Disabilities.

Rather than setting incredibly detailed and draconian requirements for every aspect of the training and behavior of a guide dog team, we believe the greatest need is for increased enforcement of access legislation.

The overwhelming majority of people who use guide dogs acquire them from training schools, most affiliated with the International Guide Dog Federation (IGDF). IGDF already monitors industry-wide compliance with an accepted set of standards. There is no need for Canada to initiate additional excessive rule making, since schools, handlers, and the public are generally satisfied with the quality of IGDF school trained guide dogs.

The numbers of privately trained dogs are so small as to be insignificant, and there has been no serious concern expressed by the community about the quality of training or the behavior of privately trained dogs. Standards should not be promulgated for a group that constitutes far less than one per cent of the total.

The proposed standards place an unnecessary barrier between blind people and access to independent travel. In addition to graduating from an IGDF school, blind people could be asked to undergo an additional rigorous and irrelevant test before being granted access rights. Other citizens are not forced to undergo testing in order to gain the right to be mobile. In addition, experience with guide dog certification in British Columbia has shown that publicity concerning certification has led to harassment of guide dog users who are attempting to go about their business. Many have experienced repeated demands to show certification cards before being permitted to access public places.

Guide dogs have performed a well-known and widely understood function for at least 75 years in Canada. In reality, blind individuals have been working with dogs to help get around since the beginning of recorded history.

The problem has never been with the adequacy of the training of the dogs; the problem has been, and continues to be, denial of access even when laws clearly prohibit exclusion.

These proposed standards will make exclusion and harassment more, not less, likely. They’re excruciatingly detailed, open for interpretation, and most have little connection with the successful function of a guide dog team.

We strongly urge the Canadian General Standards Board to abandon this poorly conceived foray into regimenting the independent travel of blind Canadians. Laws already permit the removal of dogs not kept under acceptable control. In circumstances where behavior is a problem, the remedy is clear: Ask the owner to remove the poorly behaved animal.

That approach works. Writing more and more detailed standardized requirements doesn’t work.

Blind adults working with guide dogs should be thought of more like parents taking charge of their children than like consumers purchasing electric blankets. It is reasonable to promulgate standards about blankets because consumers don’t know whether an electrical circuit is constructed correctly. It is not reasonable, in fact it would be an intolerable invasion, to produce detailed standards about how parents are supposed to raise their children. As it is for parents, so it should be for guide dog handlers. Canadian policy should assume that guide dog handlers are adults capable of taking full responsibility for the behavior of their dogs.

Because of the essential service performed by guide dogs and the generally high standards of guide dog training, we strongly urge that guide dogs be specifically eliminated from inclusion in these proposed standards.

Sincerely,

Mary Ellen Gabias, President
Canadian Federation of the Blind
www.cfb.ca
250-598-7154