*** UPDATE: As of April, 2018, the proposed standard has been withdrawn and the CGSB is not planning any meetings at this time.

We’ve all seen the news stories about people bringing their pets into public spaces and pretending they are service dogs. We’ve all been angry at the dishonesty, the danger to ourselves and our legitimate service dog teams, and have various ideas on how to combat this. Some propose service dog registry and identification; others place the burden on businesses to exercise the rights they do have (notably to ask the handler of an aggressive or disruptive dog, service dog or not, to remove it from the premises), rather than the people with disabilities who depend on service dogs to live fulfilling independent lives. Still others want governments to take action.

In Canada, an organization in the Public Works and Government Services (not a government committee) – made up of representatives from service dog training organizations, veterinarians, advocacy groups, regulatory bodies, and individuals – has been hard at work for two years to create a national standard for service dogs. Their stated objective is to provide a universal standard for service dog teams. Over the past month, many friends and advocacy groups have sent the draft standards to me, advising me that there is a public consultation phase that ends on July 14. As I know several groups and members who have helped draft this proposed standard, I chose to take my chances and hope for the best. But as emails and facebook posts flooded my phone and computer this past weekend, I realized that I couldn’t bury my head in the sand anymore. I had to figure out just why my phone was going crazy.

I read the standard, beginning to end, and will be submitting my comments to the board.

What The Committee Is Not

This is not a bunch of egotistical, evil people out to make life harder on service dog teams and handlers. While training programs had voting power, other advocates, professionals and owner trainers had votes in the meetings as well. This is a large group of people, all of whom have valid concerns and objectives: to make sure service dogs, handlers, and the general public are safe. If you choose to comment on this post, please be forewarned that I will delete any personal attacks against the committee or disrespectful talk about how you will never visit my country. If you can’t offer anything constructive (be it praise or criticism), keep it to yourself.

What this Document Is Not

This document is not current legislation. Even if it passed as is tomorrow, it is not law. While it may be used to create universal legislation across the country (so that someone in BC won’t undergo stricter scrutiny when they travel to Saskatchewan), legitimate service dog handlers can wake up on July 15 (after the open consultation period) and go about their lives, hopefully with no public interference.

This document is not a declarative statement on where a Canadian can train for a service dog. I’ve seen a ton of fear-mongering on this topic, that the board is saying Canadians can’t train in the States, and no where is this stated or implied. Guide and service dog programs may be concerned about their ability to serve Canadians due to the standards, but the standards themselves, as written, do not restrict location of training. There are enough legitimate concerns in this document without creating more.

This document is not permanent. That’s why it’s called a “draft”. For future readers of this blog, anything written below is paraphrased from the draft standards published on May 2, 2017. It’s a living document; it will change. We as Canadians can make our voices heard by providing feedback through the Web site. We have an opportunity to push for change, to offer suggestions, in a way that is seldom available. Take it!

What They Got Right

This document is thorough. Whether you agree with it or not, it’s a long comprehensive document. People with a wide variety of disabilities are represented, along with a non-exhaustive list of tasks their corresponding service dogs can perform. It touches on everything from training and behavior to realistic expectation, equipment fit, first-aid… I could go on and on. No one can accuse the standards board of not considering any situations. The needs of both service dog and handler are referenced throughout, with great emphasis being placed on the biological and emotional needs of the dog. The rights of persons with disabilities to access public spaces safely with their service dog are well-documented.

Unreasonable Intrusions

But while it’s clear these standards indicate that handlers should have realistic expectations about their service dogs performing learned tasks or learning new ones, their expectations of obedience are higher and, frankly, not as realistic. According to the draft standards, a service dog must respond immediately to obedience commands, on or off-leash,  in all conditions and circumstances. While later in the draft, there is mention of intelligent disobedience (when a dog disobeys a direct command when it is unsafe), the words “under all” do appear related to obedience (Section 4.2.2).

But what is not specified anywhere in this document is who can assess – and how frequently – whether the handler has “enough” knowledge on any of these things, or when the dog is obedient “enough”, even off-leash, in the home? It does appear that an assessor will at some point enter the home of a person with a disability, just because they wish to use a service dog, and I do wonder about an intrusion of privacy that no pet dog owner has to undergo.

There is also particular concern about the equipment used by a service dog team. Based on the current draft, any slip collars, E-Collars, prong collars, or muzzles would not be considered appropriate equipment (section 5.2.1.1). While I personally have strong opinions on my dog with equipment, it is not my place to judge another handler’s appropriate use of tools; even a flat-buckle collar can be used in an abusive manner. I have used a head halter (frequently mistaken for a muzzle, even though my dog can fully open her mouth while wearing it) to re-shape behavior; this standard does not address that at all. If we are responsible enough to handle service dogs in public, we should be treated as responsible enough to use appropriate tools humanely to mitigate behavior or receive tactile feedback.

A brief note about identification: several people think identification is a good way to weed out the fakes. Section 7 addresses the information that would be made available on identification (on a service dog’s harness/leash, or ID card carried by the handler). It does not appear to provide provision for those who wish or need to make their own equipment or buy from manufacturers whose equipment fits their unique needs as a service dog team, but does not readily identify “service dog”. These draft standards do not – nor can they – address who can ask for service dog team identification, under what circumstances.

One of the many other concerns I have is statements regarding separating dog and handler. Section 5.2.3.3 states that the service dog will “tolerate” removal from the handler (by whom?) when required by circumstance. The draft indicates this will be inspected (section 8.2.2.3) by having a person unknown to the dog promptly remove the dog from the handler and walk away a minimum of 6 meters. While I understand this is to test for aggression, as a visually impaired person who has had her dog forceably removed from her, this is traumatic, and does not show compassion and understanding (as stated in the goals of the inspection). As an aside, my dog might be tolerant of being separated from me, but I wouldn’t be! It would be like someone driving a car and the passenger just ripping off their glasses.

Other Concerns/Questions

A few questions I pondered while reading the standards. At what stage of the service dog’s working life these inspections are administered. What do owner trainers do? Where are the inspections held? How frequently? Who pays for travel? Does the handler have the right to access public spaces before the inspection? Does a Canadian who receives their dog from an American source have to undergo additional testing? So many more questions about the logistics that the standards themselves cannot address. They are only the first step in a complicated process which will need regulatory and legislative bodies to implement and enforce. Many (myself included) have grave concerns about the implementation of the standards. These concerns are not without merit. But at the end of the day, these standards can provide a foundational framework in which all service dogs, handlers and the general public can feel safe alongside each other.

So where do We Go from Here?

I will not throw the baby out with the bathwater. I have had friends whose service dogs have had to retire because of attacks by overly stressed legitimate service dogs or encounters with out-of-control pets in vests. Standards, by themselves, are not a bad thing, and I do see some value in these proposed standards of behavior by both handler and service dog. However, I think there needs to be much more clarity about the inspection process and the access rights of a person with a disability using a service dog. If someone owner-trains their service dog and/or uses third-party equipment without “service dog” markings, are they still protected by each province’s Human Rights legislation? If so, then there needs to be more education of service providers about when a disruptive or aggressive service dog team can be asked to leave, and more teeth to penalties for impersonating a person with a disability to take a pet dog into public.

While I believe there is the best of intentions for this standard, I question its enforceability and the potential intrusion it places on the lives of people who already receive strict scrutiny. While the commentary period is open until July 14, raise your voice in constructive ways. Don’t only point out what’s wrong, but how it could be better. And above all, don’t forget to indicate what was done right.