The National Coalition of People Who Use Guide and Service Dogs in Canada | National Standards Threaten the Rights of Canadian Guide Dog Handlers: A Call to Action Issued by the National Coalition of People Who Use Guide and Service Dogs (HOOH) and its Al


May 12, 2021 – Coalition/NEADS Webinar link

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Change.Org Petitions – Links of two Complimentary Petitions on this subject. Please sign both from:

National Coalition of Guide and Service Dog Users Petition:

Guide Dog Users of Canada Petition:

The Coalition Plan to Protect the Rights of Guide Dog Handlers against the Standards. 

About the Coalition

The Coalition is a network of individuals and organizations interested in promoting and protecting the rights of guide and service dog handlers. The Coalition was formed in 2017 to protest the development of national standards which threatened to interfere with the rights of guide dog handlers. The force of the Coalition’s protest had an impact and the standards were withdrawn in 2018. Since that time the Coalition has represented the interests of guide and service dog handlers with respect to accessible transportation, the implementation of the Accessible Canada Act and the ongoing promotion of human rights.

Recently the Coalition was approved as a member of the Council of Canadians with Disabilities, a long standing national cross disability organization in Canada. Our current membership is made up of primarily guide dog handlers and we are open and interested in joining forces with service dog handlers.

What’s at Stake

The Coalition recently learned that the issue of national standards is once again on the table and once again has the potential to threaten the rights of guide dog handlers. And so once again, the Coalition intends to vigorously protest such standards in so far as they may apply to guide dog handlers. Below, we explain our reasons for objecting to national standards and call on our supporters to take action.

Why Standards are Back on the Table

In March 2021, the Canadian Foundation for Animal-Assisted Support Services (CFAS) (a non profit organization) filed four notices of intent expressing its interest in developing national standards regarding the production, training, handling and safety of all animals that perform an activity or service for humans in Canada. Further, the notices indicated that all personnel involved with such animals including veterinarians, trainers, caregivers, and handlers would be included in the standards. The CFAS has indicated that guide dogs and their handlers will be included in the standard. To fully understand the Coalition’s concerns, it is helpful to know how standards are made in Canada. Below is a brief summary of this process.

How Standards are Made in Canada

In Canada the Standards Council of Canada (SCC) is responsible for overseeing the development of standards. It is a non profit crown corporation of the government of Canada. Its purpose is to promote voluntary standards  in a variety of areas including the national economy, sustainable development, international trade, and the health, safety  and welfare of workers and the public. The SCC does not actually develop standards. Rather it leaves this task to organizations that have an interest in developing particular standards. Before an organization can begin the business of making standards, it must go through an accreditation process by the SCC. The SCC has accredited several organizations.

Once accredited, an organization is able to partner with members of the public/community and businesses to set up a technical committee for the purpose of developing specific standards. After the technical committee completes its work, the proposed standards are sent to the SCC for approval. If the SCC approves the standards, they are released to the public as voluntary standards which can be adopted by businesses or governments as their official standards.

How the CFAS is Involved in Developing Standards

In 2020 the SCC granted accreditation to the Human Research Standards Organization (HRSO). As an accredited organization, the HRSO was given the authority to propose standards. In 2021, the CFAS filed four notices of intent with the HRSO regarding its interest in developing standards for services/activities performed by animals (see above for further description of the notices). These notices were accepted by the HRSO. The HRSO in partnership with the CFAS is now in the process of setting up a technical committee to begin the work of developing standards. As far as the Coalition is aware, guide dog handlers are not involved in developing this committee.

Why the Coalition Objects to the CFAS Proposed standards

At this point, the Coalition has not pushed for representation on the technical committee. Our goal is to have guide dog teams excluded from the deliberations of the technical committee from the outset. We contend that our objections present a strong and valid case for such immediate exclusion. We have been told by guide dog handlers that they do not have the time, resources or interest in participating in a process that is unnecessary, irrelevant and a blatant disregard of their rights. Our objections to the HRSO/CFAS standard process is as follows:
There is no objective, concrete evidence that additional standards are needed. Furthermore, organizations such as the  CFAS and the HRSO certainly do not have the expertise or mandate to determine the requirements of guide dog teams.

Guide dog teams have been working effectively in North America for over ninety years. Their presence in the public and their capacity to be trained to guide blind people has inspired an expanded understanding of how dogs can be trained to perform several other tasks that can be of benefit to persons with many different types of disabilities. These dogs are commonly referred to as service dogs and the Coalition firmly supports the right of any person with a disability to have access to such trained dogs. We therefore take no issue with the development of standards that will ensure that people with disabilities have access to service dogs and training that is affordable, reliable, and high quality as long as they are consulted and involved in a meaningful way in the process.

We already have effective standards.

Guide dog teams have been following rigours training standards for many years. These standards are regularly monitored and updated by the overarching body of the International Guide Dog Federation (IDGF). The IGDF standards are researched, tested and applied by persons with extensive expertise, experience and education in the safe and effective training of guide dogs. Most guide dog training facilities throughout the world follow these standards.

Guide dog handlers put their trust and confidence in the IGDF standards. It is therefore deeply troubling and catastrophic to learn that an organization with no proven expertise or experience in guide dog training is now proclaiming its authority to impose a new layer of standards on guide dog teams.

At no time were guide dog handlers consulted by the SCC, HRSO, or the CFAS regarding the need for further standards.

The Coalition made several written inquiries to the CFAS to determine who was requesting/supporting the inclusion of guide dog teams in their proposals and what evidence it had that such inclusion was necessary. The CFAS was unable to adequately answer any of these questions. It appears that the CFAS made no attempt to consult with guide dog handlers before filing their notices of intent. Moreover, the Coalition has recently made three requests to meet with the HRSO to discuss our concerns and each request has been met with a refusal.
It is a well developed human rights principle that stakeholders who may be impacted by laws, policies or standards should be consulted with and be given the opportunity to have input in the proposed initiative. The United Nations has adopted the principle developed by persons with disabilities which declares “nothing about us without us.” This principle has influenced the federal government and  thus consultation with stakeholders has been a key component of the Accessible Canada Act and its accompanying regulations. And yet the SCC, HRSO and the CFAS have all ignored this important principle and marched ahead without any input, consultation or inclusion of guide dog handlers. In any other context, such as men setting standards for women, this would be regarded as unacceptable and outrageous discriminatory behaviour.  Thus the Coalition regards the three organizations involved in the standards project to be unscrupulous, unethical, ablest, and violators of Canada’s human rights laws.

Additionally, as indicated above, none of the parties have produced evidence supporting the need to include guide dog teams in the CFAS proposals. Generally when standards are proposed, it is because a problem has been identified which requires a solution. At no time has the CFAS presented any evidence that guide dog teams are encountering training, handling or caregiving problems.

Voluntary standards can easily become mandatory.

It is important to point out that the standards that the CFAS intends to develop will be regarded as voluntary. In other words, they will not be mandatory at the outset. However, it is very likely that the standards will be promoted to governments for adoption. Given the current confusion and concern about the many service animals that are emerging, it is completely conceivable and reasonable to assume that governments would eagerly accept such standards and make them official and thus enforceable.

What the Coalition is Planning

The Coalition has requested to meet with the HRSO to discuss our concerns. Three requests have been made in writing and rejected by the HRSO.

The Coalition will now file a complaint with the SCC regarding the HRSO refusal to meet.

If the Coalition is unable to negotiate the exclusion of guide dog teams from the CFAS proposals, it will consult with a lawyer and consider filing a complaint with the Canadian Human Rights Commission against the SCC, HRSO and the CFAS on the ground of disability for including guide dog handlers in the proposed standards without consultation and without producing specific evidence of a problem.

In addition, the Coalition is circulating a petition calling on the Ministers and the SCC to ensure that accredited organizations comply with human rights laws. It will also carry out an extensive letter writing and political lobbying campaign with federal MPs.

A comprehensive social media campaign is being launched to get the word out.

What you can do

Ask to meet with either the HRSO or the SCC or both to express your concerns regarding the impact of the CFAS proposals on guide dog teams in Canada.

Sign and circulate the two petitions that were developed

Lobby your member of parliament with letters and meetings. And

Do what you can to spread the word regarding the harmful and discriminatory actions of the SCC, HRSO and CFAS.

For further information and to be put on our mailing list, Please contact the Coalition at

Hands off our Harnesses, Hands off our Hounds!!!!.

National Coalition of People Who Use Guide and Service Dogs, Standards Coordinating Committee:

Janet Hunt, Michelle Woolfrey, Katja Newman, Brian Moore, Yvonne Peters, Anne Musgrave and Heather Walkus

Sample Letter

Dear Friends and Supporters:


The National Coalition of People Who Use Guide and Service Dogs is pleased to provide some draft wording which you may wish to use to write or email members of Parliament regarding the concerns of guide dog handlers and the standards proposed by the Canadian Foundation for Animal-Assisted Support Services. We suggest that you send letters to the Honourable François-Philippe Champagne, Minister of Innovation, Science, and Industry (responsible for the Standards Council of Canada) and The Honourable Carla Qualtrough Minister of employment, workforce development and disability inclusion. It is also important to contact your member of Parliament. You may need to modify this wording when writing to your MP as not all members are part of the government.

Sample Letter

Dear Minister (fill in name):

I am writing in support of the National Coalition of people who use guide and service dogs to protest against being included in the current development of national standards pertaining to all animals that perform an activity or service for humans. These standards are being promoted by the Canadian Foundation for Animal-Assisted Support Services under the watch of the Standards Council of Canada. The Coalition has been advised that guide dog handlers and their dogs will be included in these standards. Please be advised that guide dog handlers have not requested such standards and nor do we think they are needed. For the reasons identified below, I am asking you to intervene in this process and ensure that guide dog handlers and their dogs are immediately exempted from these proposed standards.

A similar standards process was attempted in 2015 and with the protest of numerous guide dog handlers, the standards were eventually withdrawn in 2018. Guide dog handlers are beyond frustrated and disappointed that we are once again having to fight this fight all over again. I am asking you to take immediate action to ensure that guide dog handlers are once and for all left out of any one-size-fits all animal standard-making activities. Our reasons are as follows:

1. The Coalition has been advised that guide dog teams will be included in the standards proposed by the Canadian Foundation for Animal-Assisted Support Services. This proposal has been accepted by both the Human Research Standards Organization and the Standards Council of Canada. We want to emphasize that at no time did any of these organizations consult with or include guide dog handlers in this decision. In fact, I understand that the Coalition asked to meet with the Human Research Standards Organization a total of three times to discuss concerns and each time it declined. Your government has a positive history of working in partnership with and consulting with persons with disabilities. It is therefore shocking and perplexing for guide dog handlers to learn that your federal agencies are blatantly ignoring this important principle. Imposing standards on guide dog handlers without our input is a clear violation of our human rights and the well established international human rights principle “nothing about us without us.”.

2. Guide dog teams have been following a rigorous set of internationally established standards for many years. These standards are overseen by the International Guide Dog Federation which has the expertise to determine the appropriate training standards for guide dog teams. These standards are used by training facilities throughout the world and have a long track record of producing safe and effective guide dog teams. Requiring guide dog teams to comply with additional standards is absolutely unnecessary and could potentially subject guide dog handlers to further burdens and barriers.

3. At no time has the CFAS provided any shred of evidence that guide dog teams are in need of further standards. How can your government endorse a standards-making process which hasn’t even identified a problem in so far as guide dog teams are concerned? The previous standards process ended up being a monumental waste of time, energy and most of all monetary resources, so why are you letting this flawed process happen all over again, particularly when it is able-bodied persons deciding what is best for guide dog handlers?

I trust that you will give my concerns serious consideration. I would be happy to meet with you to discuss this matter further. Attached for your further consideration is a background information sheet which describes in more detail the concerns of guide dog handlers in Canada.

Yours sincerely,