Part of a Whole

My name is Nicolas Steenhout.
I speak, train, and consult about inclusion, accessibility and disability.

Comments on Canadian proposed Service dog team standards

There is a proposed Canadian standard for Service dog teams and comments are due by or on July 14, 2017. There is not much time to comment, and yet it is extremely important that everyone who will be directly affected by this standard does make a public comment. In this post, I’m going to state my position on the proposed Canadian Service dog team standard.


10 service dogs sitting or laying down
Service dogs resting after during a training session
Photo by Beverly & Pack. CC By 2.0

TL;DR

New service dog standards have been proposed in Canada. Public comments are open until 14 July, 2017. The intent of the standards is good. The text is overly vague, unrealistic and at times problematic. If adopted as written, the standards are likely to cause problems for established service dog schools as well as the human parts of service dog teams.

Contents


Background

Let me start with some background about me and service dogs. As a disability rights advocate, over the past 20+ years, I’ve had the opportunity to meet many service dog teams, including guide dogs, mobility dogs, seizure dogs, autism dogs, and hearing dogs. I met these teams in Canada, the United States, New Zealand, Australia, the United Kingdom, and France. I was involved in New Zealand with the ammendment of the Dog Control Act 1996, as well as local dog control bylaws in Palmerston North, NZ – to improve the language and text of the clauses surrounding service dogs. I also work with a service dog. He is a mobility assistance dog that primarily pulls my wheelchair and picks things off the floor on demand for me. I recently wrote about my relationship with hmy service dog. He was trained by Mira, the first Canadian school to have trained guide dogs (as per the draft Standard). He is my second service dog. My first service dog was trained in Chicago and we worked together for nearly 10 years.

I salute the idea of developing a standard for service dogs because the situation can be tricky. The text of the standard states:

The need for this Standard arose due to long waiting lists for service dogs and a growing concern that those training the dogs may not have any formal education or experience working with persons with disabilities or their families. These gaps and weaknesses prompted many people to train their own dogs either with, or without, the assistance of a dog trainer. Further, some people began using online resources to purchase corresponding ID cards and dog vests, even though there is no way to determine if the team is authentic or safe to work together in public spaces. For these reasons it is extremely difficult for service dog teams to establish their legitimacy within this turbulent environment.

It was over 2 years from the time I applied to get a service dog to the time I went home with him. I’ve heard of people who have had to wait 3, 4 or even 5 years sometimes (though that was in the United States). It is undeniable that the waiting to get a service dog is long. And I’ll admit that I explored other option than going with an accredited school – but in the end, preferred to wait. I understand how other people opt not to wait.

I have had the misfortune of encountering people working with self-trained dogs. I remember one in particular, a man with low-vision who had decided to train a big brute of a German Shepherd as a service dog. His dog was aggressive and barked and lunged at me and my old service dog. I never felt safe when I saw him on the University campus where I worked.

I have also had people ask me where they could get an ID card or a vest for their dog. This from wheelchair users who had pet dogs that they wanted to be able to “take anywhere”. Pet dogs that did not perform specific services for them, other than companionship. I’m not making light of the importance of constant companionship, particularly for people with disabilities who can get very lonely. But a companion dog, as important a function as she may be conducting, is not a service dog.

And I’ve had a long string of issues getting taken legitimately. To name a few: We have been refused access to hotels; We have been told we couldn’t go into restaurants; We have been refused access to taxis; We have even been kicked out of a motel in the middle of the night!

So that opening paragraph of the draft standard resonates with me and reflects a true, and problematic, situation. It goes downhill from there.

Verification of disability

4.1.1.1.1 Verification of disability

It shall be confirmed that, under the jurisdiction’s statues for persons with a disability, the handler has a disability.

This is raising quite a few flags. Of course, a service dog is intended to help people with disabilities, and it should be established that a person has a bona fide disability. But who is to verify it? What is their credential? What is their experience? How onerous will that process be on the individual with a disability seeking, or operating with, a service dog?

Where is the information going to be kept? Will it be a centralized database? If so, who will have access to it? How is it going to be kept secure from hacking? How is the individual’s privacy going to be protected?

Need for a service dog

4.1.1.1.2 Need for a service dog and ability to manage

The handler shall have a review of their disability and an assessment of their need for a service dog. An independent assessor having knowledge of the use of service dogs and with competence in the area of handler’s disability shall complete this assessment. If the assessor determines that there is a need for a service dog, a report of assessment shall be issued.

Again. Who is to conduct assessment. Will there be a shortage of assessors, causing long waiting lists again? Who is the report going to be issued to? All the privacy concerns stated in “Verification of disability” apply.

Handler’s canine knowledge

All of section 4.1.2 Handler’s canine husbandry knowledge and application should be covered by the training school or trainer. It certainly was covered during my training at the Mira foundation. And with the school that trained my previous service dog.

Humane training

This is a topic that has a lot of people upset. I am in favour of humane training, and I treat my dog humanely. I understand that the authors of the draft have the dog’s best interest at heart. But I can’t help feeling like they are not aware of real life.

4.1.3 Handler’s knowledge and application of humane training

The handler shall apply humane care, training and treatment that address the individual needs of the service dog.

I’m sorry, but… “Well D’oh!” Of course we want to provide humane care, training and treatment to address the needs of our dogs. Even if we were to see them as merely a tool, and I don’t know anyone who sees their service dog that way, the better we treat them, the longer they work with us.

I guess it comes down to the perception of what is, and isn’t, humane. I’ll get back to this later as it is a mission critical point in the standards.

A.1.2.3 Unacceptable methods

• Negative reinforcement: Withdrawing an aversive stimulus when the desired behaviour occurs in order to increase the probability that the behaviour will occur in the future

• Positive punishment: Delivering an aversive consequence in response to the undesirable behaviour in order to reduce the probability that the behaviour will occur in the future

Reminds me of the well meaning law in New Zealand that made it a crime to “smack” children. On the surface, this was intended to protect children from physical abuse. In practice, it means that some parents faced prosecution for slapping a child’s hand when it was about to do something dangerous, such as putting a hand in the fire, or sticking a fork in a power outlet.

The fact of the matter is, if my dog is about to do something that endangers my safety, or his, I may need to give a sharp tug on his leash. I certainly often say “no” to stop him from doing something unacceptable. Sometimes that “no” has to be very firm and somewhat loud.

The way I handle my dog is not inhumane. It may be unpleasant at times, both for him and for myself. But it is necessary for both our safety.

Appropriate equipment

4.2.1 Service dog attributes

In order to be an effective team member and to be safe to work in public, the service dog shall be:

Be outfitted with appropriate equipment and permanent identification

And

5.2.1.1 Appropriate equipment

The service dog’s equipment shall:

• Clearly identify it as part of a service dog team

There are a myriad of types of harnesses and vests out there. Each country, each province, each school, has different practices and techniques. Mira has a semi-standard leather harness stamped with the logo of the Foundation, and the harness is adapted depending on the use of the dog (guide, mobility, autism, etc). We are provided with a blue scarf, but that scarf isn’t mandatory to the “uniform” – even though it’s not unusual to be told that we can’t go into a building because we’re not using the scarf. My previous dog had a red vest, but no leather harness. Guide dog harnesses vary tremendously in style.

Even when something seems clear, people don’t see it, don’t know it, don’t acknowledge it.

Permanent identification

4.2.1 Service dog attributes

In order to be an effective team member and to be safe to work in public, the service dog shall be:

Be outfitted with appropriate equipment and permanent identification

And

5.2.1.5 Permanent identification

The service dog shall have an operating microchip that is a Full Duplex type conforming to ISO 11784 and ISO 11785.

Section 4.2.1 is vague. Precisions are brought in 5.2.1.5 but there could be confusion. If someone goes only by 4.2.1, ear tattoos could be sufficient for permanent identification. On the other hand, tattoos are painful at application and could be perceived as not being humane.

Undue hardship

5.1.1.3 Category A requirements

Note: 3. Facilities have an obligation to accommodate, but only to the point of undue hardship

What constitutes hardship? I can easily imagine a supermarket claiming undue hardship if I go into their premises because they have a staff member who is allergic to dog, or a restaurant claiming undue hardship because another patron is afraid of dogs. I can imagine it because it has happened to me in the past.

While I understand it is difficult to define undue hardship, and that it varies from situation to situation, this text is vague and will be abused. It’ll be a major loophole.

Records

5.1.2.8.2 Ownership and proxy records

It is recommended that the following information be readily available:

• Contact information for the professional used in situations where professional assistance with service dog behaviour is needed

• Records of vaccination/immunity testing

• Physical needs of the service dog

• Provision of food type, quantity and rate

• Grooming

• Exercise

• Skills and ability acquisition and maintenance

• Humane training methods and use

• Problem behaviours and the humane training plan in place to address these behaviours

What, exactly, does “readily available” mean? Does it mean have the information at home? Or is it something I’m supposed to carry with me at all times? If the later, it would be quite onerous.

Mitigation of disability

5.3.3 Team—Mitigation of handler disability

The service dog’s acquired individual tasks include, but are not limited to tasks, guiding, alerts or detection. Any task shall exclude an aggressive behaviour. These tasks shall be demonstrated to occur reliably and promptly when cued. At least one task shall mitigate the disability in a public setting.

To whom shall these tasks be demonstrated to? How often?

Safety from human hazards

5.3.4.3.1 Human hazards

The handler shall endeavour to protect their service dog from members of the public who intentionally or unintentionally would cause undue stress/fear/anxiety or harm to their service dog. The handler shall be able to protect their service dog in a manner that does not create a risk to the safety of other members of the public or to themselves.

The handler shall endeavour to respond to members of the public who intentionally or unintentionally would cause undue stress/fear/anxiety or harm to their service dog. The handler shall have a plan to safeguard their service dog in a manner that does not create a risk to the safety of other members of the public or to themselves. The plan will be suitable to the handler and the service dog and could include items such as obtaining assistance.

So if I understand this correctly, my responsibility is to protect my dog from other humans. Ok. Of course I’ll do what I can to protect my dog from other humans.

But the way I read this standard, there is absolutely no responsibility put on the aggressing party. The entire burden is placed on the dog handler.

Safety from environmental hazards

5.3.4.3.2 Environmental hazards

The handler shall endeavour to protect their service dog from environmental hazards that exist in public spaces as well as in private spaces such as the home. These hazards include, but are not limited to: pet dogs, hot pavement, winter conditions, spilled hazardous materials, or broken glass. The handler shall be able to proactively identify and take steps to avoid environmental hazards that may pose a risk to the safety of their service dog in public. In situations where these hazards are unavoidable, the handler shall either take steps to minimize the hazard (such as putting boots on the dog) or navigate the situation in a manner to proactively minimize risk to their service dog.

This is an interesting clause in that, on the surface, it makes sense, but when examined closer, it may actually stop people going out and about.

The reason people have service dogs is to help them going out and about – including in winter and in summer. I don’t stop needing to go to work or to do grocery shopping because it’s -25 C or + 30 C. In fact, without the assistance of my dog pulling my wheelchair on icy or snow-covered sidewalks, I could not get out and about.

To suggest that we need to avoid these kind of situations is akin to suggesting that we remain at home. The sarcastic part of me wants to add “stay where we belong, hidden and at home”, but I’ll refrain.

The clause offers mitigation solutions, such as putting boots on the dog. I do have boots for my dog, and he wears them whenever appropriate. But it’s not always appropriate. On icy sidewalks, he has no grip with boots on. Boots are actually not safe for him, not if he’s expected to do the job he’s been trained for.

Not to mention that many people are unable to put boots on their dog (think someone using a mobility assistance dog because they are paralyzed “from the neck down”, for example).

Safety from other dogs

5.3.4.3.3 Attacking dogs

The handler shall endeavour to avoid any dog that is not under the control of a human whether the dog is leashed or not. Action includes but is not limited to crossing the street, body blocking or asking for the dog in question to be restrained. The handler will familiarize himself or herself with the safest way to intervene or to escape in the case of an attacking dog while avoiding danger.

Ok, so once again, the onus is placed on the individual with a disability to deal with a situation caused by someone else.

Of course I’ll do what I can to protect my dog from other dogs. But there are many situations where crossing the street or body blocking is not possible. I’m sorry, but if there’s a problem dog on the sidewalk, I cannot just cross the street – because of the curb, parked car, moving cars, etc. Body blocking would prove to be a very interesting dance, as a wheelchair user. It would also place me at huge risk. If an aggressive dog is attacking, as a wheelchair user, my face and throat is within easy reach of a lunging dog.

Then there are the issues for guide dog users that may not even know there’s a lose dog coming at them.

As for asking the dog in question to be restrained… If he’s not restrained in the first place, I’m not convinced this would work “in the real world”.

I was recently at a pet shop. As we came in the door, a woman paying for her purchases at the cash station held her own dog on a leash. She saw her dog come towards us. I said to her that my dog was working and that her dog was impeding our ability to function (among other things, he was blocking our way out of the path of the closing automatic door). I asked her to control her dog and call him back to her. She said “he’s under control, he’s not dangerous”, then tried to pull back on the leash, but she wasn’t able to get her dog to move.

Training

A.3 Behaviour and training

Training times will vary depending on the breed and maturity of the dog, skill level of the trainer and complexity of the training regime.

While it is true that training time will vary, this portion of the standard doesn’t seem to take into account the International Association of Assistance Dog Partners who recommends a minimum of 120 hours of training http://www.iaadp.org/iaadp-minimum-training-standards-for-public-access.html

The standard also makes no reference to the standards put forth, and used the world over, by Assistance Dogs International (ADI). ADI is recognized as the accreditation organisation worldwide. Instead of reinventing the wheel, we could align ourself to their standards.

First aid

B.2.2 First aid kit

It is good practice for the handler at all times to be in possession of a first aid kit when with the service dog.

Err, what? I’m supposed to carry, at all times, a first aid kit for my dog with me? Are parents required to carry, at all times, a first aid kit for their children? Are other dog owners required to carry such a kit also? Why the extra burden on people with disabilities?

Of course, I want my dog to be safe and healthy and be able to respond to emergencies. But the burden of having to carry a first aid kit seems somewhat… burdensome.

Bond

B.4 Bond

The handler’s bond with their service dog may be evaluated in the areas of dog–handler interaction, perceived emotional closeness, and perceived costs

Evaluated by whom? How often? How? What kind of a burden will this place on service dog handlers?

Service dogs

C.3 Mobility assistance dogs (referred to by some programs as service dogs)

This heading reflects a poor understanding. Service dogs is an overarching term that encompasses guide dogs, mobility assistance dogs, hearing dogs, seizure dogs, autism dogs, etc. This heading, in a standard, will greatly increase the confusion that already exists out there.

The standard itself doesn’t follow its own classification, as per “C.6 Autism service dogs” or “C.7 Psychiatric and post-traumatic stress service dogs”. What’s more, the title of the standard itself (Service dog teams) doesn’t follow the classification in the text.

Conclusion

The idea of putting together a Canadian standard for service dog teams is most excellent. But such a standard should align itself closely to existing international standards, such as that of Assistance Dogs International. Such a standard should also take into account the real experience of people with disabilities using service dogs. The standard should avoid making the process too onerous on people with disabilities. The process should further take into account the experience and knowledge of service dog schools that have a successful track record and who have been providing dogs to individuals with disabilities for decades already.

What about you? What do you make of this proposed standard? Leave a comment please!

Before you move on, here are some links of interest:

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