My Thoughts On The Draft Canadian Service Dog Team Standards

I have said over and over that we need to deal with fake service dogs, mostly because those dogs don’t have the training to behave properly in public. They either make messes or attack others, making it hard for the real service dog teams to go about their business. I have slowly learned that the solution isn’t to make an ID card, because people can make fake ID cards, and it’s not the ID card but the behaviour that matters. I hoped for a set of standards for behaviour that businesses should be educated on so they know a fake when they see one.

Others have been thinking about standards, and are trying to draft one. I can tell they have tried to be very thorough, and they have somewhat done their homework on service dogs and disabilities. But for all the good that is in this standard, there are a lot of problems. I’m not one who frequently comments on drafts and legislation, but one way or another, I’m going to make my voice heard on this one. If the draft standard goes through as is, and is used as a supporting standard for laws, it has the potential to make the lives of at least guide dog teams very hard. If you feel the same, I urge you to comment. Public comment closes on Friday July the 14th.

Here is a news article and a blog post that basically agree with me, and tell me I have valid concerns. Writing my comment is going to be hard, because for the many good intentions I can see in the standard, there are many many things wrong with it, things that to me don’t even need explaining because they’re so obvious, but I know I’m going to have to break it down in a very methodical way.

Here are the overarching themes that keep coming back again and again.

  • The standard feels like overkill for any service dog handler from a reputable school. The standard wants to establish assessment and training criteria that the schools have handled seamlessly for decades. People ask why we go away to train for weeks, up to a month. The very things referenced in this standard, which it appears we are being obligated to prove over and over again, are the things we are being taught, and the things that are being reinforced. We are taught good handling, training, grooming, dealing with the public, knowing our access rights and limitations, dealing with dog health-related things, and on and on and on. Once we leave training, it’s not over. How many times have you seen me write about followup visits? The instructor is coming to check on our teamwork, the health of the dog, the willingness of the dog to continue to work, and the solidity of the training that I received. Why should handlers in my position be forced to submit to an extra layer of scrutiny? If you are training your own dog, then it makes sense to ensure that someone assesses your suitability for a service dog, and makes you aware of what is to come, so you don’t go into this relationship with false ideas. As for the rest of us, we know.
  • I know they were trying for a standard into which they could neatly fit all service dogs, but due to the nature of a service dog, this is doomed to fail. My guide dog’s duties are different than those of a PTSD dog, or a seizure assistance dog, …you get the point. By consequence, interactions are going to be different. For example, I am not always going to know about a distraction until my guide dog, well-trained as she is, gets distracted by it, at which point, I have to react. However, the standards laid out do not allow for such a reaction. I may have to tug on the leash. This isn’t a bodily choking, this is a movement to get her attention. This would not be allowed. Sometimes I put a gentle leader on my dog so I can better feel what her head is doing. This is not a muzzle, but may be perceived as such, and according to the standard, muzzles are not allowed. My dog would have to do off-leash obedience, which isn’t how we do obedience, since of course I have to feel what she’s doing, because, duh, I’m blind, hence the dog! There are so many examples of this, but you can already see that a one-size-fits-all approach won’t work. I think they tried to get feedback from all user groups, but because it was so divergent, they just gave up and this was the result.
  • I cannot stand the tone of this standard, for a couple of reasons. Let me start with the heavy emphasis on shifting the blame for any unfortunate events to the handler of the dog, not the environment or the other people in the environment. For example, if we encounter an aggressive dog, we are to avoid the dog by crossing the street, we are to stop the attack with our own bodies if necessary, tell the owner to get their dog on a leash, etc. How exactly are we to take proactive action when sometimes we are not aware of an aggressive dog until it is upon us? Not all aggressive dogs snarl and growl as warnings. Some of them, if they truly are aggressive, will simply wait until their target is in range and attack. For example, how on earth am I expected to avoid a dog jumping out of a car and latching onto me? How is anyone expected to avoid that, but if I can’t see it coming, I don’t have a chance. How am I supposed to avoid a dog lunging at us as we stand inside an elevator? How am I expected to avoid a dog attacking my dog when I am on icy terrain? How do I avoid meeting a deranged rock-throwing man? Also, how can I be expected to cross the street upon perceiving an aggressive dog if the street is extremely busy and not safe to cross there? How is a person in a wheelchair expected to immediately cross the street upon sight of an aggressive dog if there is no curb cut to cross there? How will I avoid glass if I don’t know of its existence until I have the misfortune of stepping on it? There is a big section of the standard talking about how we should take precautions when walking into roadways where there are cars. Of course we do, most of us don’t have death wishes. But what if we step off at the correct time, only to be cut off by an unobservant driver? Sure, the dog is going to do what he can, but sometimes you can’t avoid a speeding truck. Sighted people get hit, so how are we supposed to be superheroes? Is the default of this standard setting up to blame us for the accident? There is only so much one can do. Sure, we shouldn’t walk into danger with no regard for what may happen, that would be pretty stupid, but the onus shouldn’t be on us to prevent all situations.
  • …This leads nicely into my next point. There is an overall tone that we as service dog handlers need to be micromanaged, that we have no coping or problem-solving skills whatsoever, and should accept needing to provide all kinds of proof of every aspect of our lives to whoever asks for it. NO! It’s simple as that. N…O. If it has been deemed that we are capable of taking care of this animal, then treat us as such. We are being asked to do more than one reasonably does for their children. When you’re out with your kids, do you carry a fully-stocked first-aid kit? Or is it expected that if something comes up, you will ask for help and deal with it to the best of your ability? Are you expected to regularly show proof that you’ve taken your child to the doctor? Or, is this only brought up if your child looks ill or otherwise uncared for? Are you expected to provide proof that you know how to handle every single eventuality? Or are you expected to problem-solve. This is an unacceptable burden to place on people who are already taking exemplary care of their service dogs, and frankly, I find it insulting. Hands off! I am a competent adult and I demand to be treated as such.
  • On one hand, every little thing that the handler must do is detailed, but when it comes to the specifications for assessment, there are gaping holes where details should be. How frequently will these assessments be conducted? By whom? Will they be scheduled or unannounced? There is the description of a test where someone unknown to the dog will walk up and take the dog from you and walk away. Is this going to be done without warning? If so, I will be living in perpetual fear, and as a blind person, I will not know who is kidnapping my dog and who is an assessor. Will I have to go somewhere, taking off work, for these assessments to be done? How long will they take? How on earth will they properly assess play? Playing a game in front of someone is never as natural as what happens at home. What is the difference between testing and inspection? There is so little clarity in this part of the standard that it’s kind of terrifying. Yet, the people who wrote this settled on this as an acceptable way to treat us.
  • There is way too much weight placed on the public’s opinion. As any service dog handler or puppy raiser knows, all of the public have opinions in plentiful quantities, but many of those opinions are uninformed or misinformed. On any given day I can be told
    • that my dog is fat,
    • that my dog is too thin,
    • that my dog looks happy,
    • that my dog looks sad,
    • that my dog is too shy,
    • that my dog is too sociable,
    • that I’m good to my dog,
    • that I’m a mean mean handler (when I won’t let her get pets),
    • that my dog is well-trained,
    • that my dog has never seen a day of instruction in her life.

    I could go on all day. You get the point. If these people can make decisions about whether I can come in a place, I’m in trouble. Of course, if my dog looks like a flea-bitten disobedient mange-covered mutt who craps on the floor and bites people, then the public can say all it wants, but they are far too quick to criticize every little infraction, and to give them power scares me.

I’m sure, on its face, it looks like all these provisions are for the best, but I hope my examples illustrate my point. I am already doing my best to keep my dog’s training up. I do not want to live in constant fear that I will have to prove that to every Tom, Dick and Harry who says he’s an assessor.

I’m tired. I have been writing this for hours, and I’m going to have to reform this into something fit for a public comment. But I will do it, because it means that much to me.

If you feel the same, you can do it in one of two ways. You can submit your comments on this form, or you can write a letter and send it to Jennifer(dot)Jimenez(at)tpsgc-pwgsc(dot)gc(dot)ca
I kind of butchered her address in the hopes that it wouldn’t be spammed, so you’re going to have to rebuild it.

I really hope lots of comments come in and it gets a massive revamp. It’s not totally awful, but I think it needs work or it will try to solve one problem and create four more.

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