A Failed Process – Executive Summary
Now that we have completed all six chapters of our report, “A Failed Process”, we are providing this executive summary for ease of reference. We understand that the CGSB and its Committee on Service Dogs is meeting this week to consider feedback that they have received. However, it is important for advocates to keep this issue in the public eye, keep in touch with your Member of Parliament, the Ministers responsible, and the Prime Minister’s office to ensure that this failed process is stopped.
- Canadian General Standards Board (CGSB)
- Service dogs, guide dogs
- Veterans Affairs Canada (VAC)
- Post Traumatic Stress Disorder (PTSD)
- Assistance Dogs International (ADI)
- International Guide Dog Federation (IGDF)
CGSB was asked to develop a standard related to PTSD dogs; however, they expanded their scope to include all guide dogs and service dogs in Canada. They released a draft standard for public comment and there was a significant negative response. Advocates want the draft standard withdrawn and the standard development process stopped.
Background – Chronology of Events:
Starting in 2005, American service dog schools started placing dogs with veterans returning from Iraq and Afghanistan. Many found that their dogs not only mitigated physical disabilities, but were also helping them cope with PTSD.
Since that time, ADI, the global service dog accreditation organization, spearheaded efforts to develop standards and accreditation processes specifically for PTSD dogs. Once the standards are ratified by the ADI membership, any service dog organizations seeking accreditation for programs to place dogs with handlers who have military-related PTSD will have to meet these standards. This includes the eight ADI-accredited schools in Canada.
In Canada, beginning in 2013, VAC began responding to advocates regarding PTSD dogs for Canadian veterans. At the same time, a private sector organization asked CGSB to develop standards in this area.
In May 2014, Parliament’s Standing Committee on Government Operations and Estimates was advised of CGSB’s intention to pursue a standard for PTSD dogs. By the Spring of 2015, after a series of meetings and consultations, CGSB and VAC had signed an agreement for CGSB to develop a National Standard of Canada for service dogs. It is not clear why VAC and CGSB chose to ignore the relevant developments in the United States.
In October 2015, CGSB held the first meeting of its newly-formed Committee on Service Dogs to develop the standard. During this first meeting, the scope of the project was changed from a focus on PTSD dogs to include all guide dogs and service dogs in Canada. No effort was made to retain the existing scope, nor was an effort made to advise additional stakeholders of the change, or to reconstitute the committee to reflect the new interests that had been incorporated.
From May to June 2017, CGSB’s Public Enquiry stage for the draft service dog team standard was opened. However, there was no broad public announcement, so those additional Canadians who had been incorporated into the scope remained largely unaware of the draft standard. It was only when two American guide dog schools alerted their Canadian graduates that alarms were raised.
To make matters worse, appeals needed to be made through the Canadian Human Rights Commission and Members of Parliament to force CGSB to make their documents and processes accessible to blind Canadians who were being impacted.
Concerns Expressed by Advocates:
CGSB and its Committee on Service Dogs started with a mandate to address issues related to PTSD dogs, but quickly changed the scope to incorporate all guide dogs and service dogs in Canada.
They ignored existing international accreditation and standard-setting bodies. On the PTSD front, they ignored significant developments and progress regarding PTSD dogs in the United States, resulting in PTSD dog standards in Canada being delayed years longer than they needed to be, more veterans suffering longer, and more unaccredited trainers victimizing veterans and funders.
CGSB and its Committee on Service Dogs did not merely intend to develop a voluntary standard, as they have stated to the public; they intended to develop public policy that would become mandatory. In this effort, CGSB failed to apply good public policy principles, failed to use good public policy processes, and did not develop any implementation plan.
CGSB and its committee ignored existing provincial laws and federal government initiatives; they strayed from statements made before a committee of Parliament, and ignored broad policy direction from the Prime Minister.
Their policy has been positioned in a way that would violate the human rights of vulnerable Canadians.
CGSB has no legal jurisdiction to make public policy related to human services, and they proceeded to develop the draft standard without the participation of those who hold responsibility – the provinces.
The process that CGSB and its committee followed lacked transparency and accountability, and the committee itself was constituted in a way that severely under-represents impacted people, and over-represents organizations and individuals who have conflicts of interest.
To make matters worse, each committee member and all participants are required to sign a nondisclosure agreement that places the proceedings in a state of secrecy. Even now, advocates are reticent to meet with the committee because their subsequent advocacy efforts would be hampered by the secrecy oath they are required to sign.
Stop the Current Process
Stakeholders have lost trust in both the process and the participants; no amount of fixing will win that trust back. So, the most effective first step to get back on the right track is for the Minister of Public Services and Procurement and the Minister of Veterans Affairs to withdraw the draft standard and abandon the current process.
Introduce Accountability and Acquire Policy Development Expertise
Stakeholders have lost faith in both the process and the participants; it is not possible for CGSB to continue to lead. It is also difficult to provide a recommendation to the Government of Canada when they do not have jurisdiction for this policy area. If policy work continues at the federal level, it must be led by the Minister for Sport and Persons with Disabilities. Whatever processes unfold in the future at any level of government regarding guide dog and service dog issues, it is recommended that clear accountability for policy development and implementation be established at the beginning of the process and communicated publicly. Further, the policy development must be undertaken by those with appropriate expertise.
Introduce Transparency and Open Up the Process
Because of a lack of communication, many affected stakeholders are still unaware that this draft standard was developed and would have affected their lives. Again, it is difficult to provide a recommendation to the Government of Canada when they do not have jurisdiction for this policy area. Whatever processes unfold in the future at any level of government regarding guide dog and service dog issues, it is recommended that users are placed in a strong position to influence policy outcomes, those who might experience cross-impacts or unintended consequences are engaged, and existing accreditation organizations are represented (ADI, IGDF) so that existing accreditation and standards are used. Parties must ensure there is open communication to all those in the public that are interested at every step of the process.
Create a Three-Pronged approach to Reflect the Three Policy Problems
Recognizing there are three distinct policy problems at play, there will be different needs and different participants for developing a solution to the problems associated with 1) addressing the growing demand in the new field of PTSD dogs, 2) ensuring access rights are addressed, and 3) dealing with the variety of legal approaches across Canadian jurisdictions. It is recommended that no jurisdiction attempt to address all three issues together in one process.
In Addressing Growing Demand, Seek to Regulate Industry, Not Individuals
CGSB’s draft service dog team standard would have required assessments of every dog user in the country; this runs counter to the precepts of human rights. It is recommended that any regulatory approach focuses on regulating the dog training industry through existing, established accreditation bodies. For those who find that training their own dog is best for them, and thus there is no third-party accreditation to ensure quality, there needs to be an appropriate assessment that gives legitimacy for these dog / handler teams.
In Addressing Public Access Concerns, Build on Success
It is recommended that there be two areas of focus to enhance public access rights. First, all governments, dog users, trainers, schools, advocates, and allies have a shared responsibility within their own spheres of influence to educate the public. Second, there are jurisdictions in Canada that already have successful legislation, and policy developers must build on those approaches, rather than inventing new ones.
In Addressing Differences Across the Country, Strong Advocacy Will Win the Day
It is recommended that the Government of Canada encourage and facilitate individual Canadians, advocacy organizations, and provincial governments to work together to harmonize provincial requirements for guide dogs and service dogs to ensure legal protections are in place in every province, that those protections are consistent, and that each province recognizes dog / handler teams from other provinces without creating hurdles that become barriers to travel.
James L Menzies
The views contained in this report are those of the author, who is responsible for and owns the content. If there are material errors or omissions, the author would appreciate hearing from you, and will make every effort to issue corrections. This report may be shared in whole or in part, but credit must be given to the author. (Contact the author at www.canadianguidedog.wordpress.com/)