Community Law Reform Assistance Animals Final Report 16

Accreditation Standards For Trainers

5.84 Consultees acknowledged the need for stringent guidelines to ensure that assistance animals are trained to recognised standards.³⁵⁸ Such standards should include both technical capacity and experience in assistance animal training along with requirements for ensuring the quality and suitability of dogs.³⁵⁹

5.85 Proper matching of client and dog, including the person's capacity to look after the animal³⁶⁰ along with regular follow up of the partnership once training is completed should be mandatory requirements contained within accreditation standards.³⁶¹ Assistance Dogs Australia explained:

Training organisations have a duty of care to the recipient, general public and the dog. Accredited organisations should have a proper matching and follow up program to ensure quality of service and also quality of life for the dog.³⁶²

5.86 During consultation there was frequent reference to the importance of trainers to understand how to work with people with disability.³⁶³ The commission agrees that "trainers need to be highly sensitive to the needs of people with disability".³⁶⁴

5.87 The particular needs of people with co-morbidities ³⁶⁵were also identified as an area where improved services are required.³⁶⁶ As noted by Blind Citizens Australia it is important that:

The organisation is inclusive and addresses the needs of the individual throughout the training process and during on-going support. This might include tailored one-on-one training, or the provision of Auslan or language interpreters to assist the client to communicate.³⁶⁷

International And/Or Local Standards

5.88 Almost everyone agreed that accreditation standards were necessary. However, there was some divergence of opinion. Some felt membership of an international organisation such as Assistance Dogs International (ADI) or the International Guide Dogs Federation (IGDF) should result in automatic eligibility for accreditation.³⁶⁸ Others were of the view that this alone was not sufficient.³⁶⁹

5.89 Assistance Dogs International (ADI) has operated since 1987. It represents people who train many types of assistance dogs. These include guide dogs, hearing dogs, mobility dogs, seizure alert dogs and psychiatric service dogs.³⁷⁰

5.90 During the commission's consultation process it was noted that there are different standards of membership available through ADI. There was general agreement that membership as an organisation, rather than as a user should be the category of membership required to equate with Victorian standards.³⁷¹ We were also informed that an Australian and New Zealand branch of ADI was being established which requires all current members to have full accreditation by 2010.³⁷²

5.91 IGDF is a UK based organisation that has operated since 1989 as a representative body for dog training schools all over the world. It currently has 84 members worldwide.³⁷³

5.92 To be a full (accredited) member of IGDF, the organisation must have, amongst other things, operated for at least five years, and successfully trained at least 20 guide dog partnerships.³⁷⁴

5.93 GDV and SEDA are members of IGDF.³⁷⁵ Many other training organisations in Australia are members of ADI. Some train to a higher standard than that required for membership.³⁷⁶

5.94 The commission's research indicates that IGDF and ADI membership standards converge around organisational capacity and history; standards of breeding and selection; client and dog matching practice; implementation of a public access test with regular re-testing; the humane treatment of animals and proper client service standards.³⁷⁷ Consultees indicated that these sorts of standards should gain legal force in Victoria.

5.95 Some argued that there is no need to "reinvent the wheel" and international standards should be used as the benchmark for accreditation. ³⁷⁸ Assistance Dogs Australia stated:

ADI accreditation and membership requirements are very comprehensive and would be sufficient for a local scheme. There is nothing you would put in local guidelines that aren’t already in the international standards ... We know we have a premium product.

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5.96 One argument was that the use of international benchmarks would promote consistency of standards across Australian jurisdictions.³⁷⁹

5.97 However, the Human Rights and Equal Opportunity Commission (among others) queried the prudence of making state governments reliant on international bodies for accreditation standards.³⁸⁰ As noted by Anne-Marie Kelly "the system needs to be local to reflect local needs".³⁸¹

5.98 One way this may be overcome is to mandate local standards, broadly equivalent to IGDF and ADI standards in Victorian law. This should be done by regulation so that they can be easily amended as standards progress.

5.99 This avoids having to devise entirely new standards without ceding powers to an international group. Another good reason for spelling our accreditation standards is that local accreditation by ADI (who cover both large and small providers) will not be completed until 2010.³⁸²

5.100 The commission considers that trainers should be regarded as meeting the criteria and therefore eligible for accreditation by the Minister if they can demonstrate that their program is currently fully accredited by either the IGDF or ADI. At least three organisations are fully accredited already.³⁸³ These organisations provide 80% of assistance animals currently working in Victoria.

Recommendation

18. Regulations made under the Act should provide that a trainer or training organization may be accredited by the Minister if they can demonstrate that they:

a. Understand and provide services to people with disability (impairment); and

b. Breed and/or select suitable dogs that are able to meet the needs of persons with impairment and can operate safely in public; and

c. Match individual dogs and persons to form an effective assistance dog partnership; and

d. Train reliable assistance dogs that are able to perform tasks and functions that assist a person with impairment to alleviate the effects of their impairment and are safe and effective in public; and

e. Use humane training methods; and

f. Administer and certify partnerships using the "public access test", including at least annual—re-testing of partnerships; and

g. Provide ongoing and regular support to the assistance dog partnership, including the removal of certification as an assistance dog where required; and

h. Has a transparent complaints process that is available to clients in a variety of accessible formats; and

i. Meet all other Commonwealth and State legislative requirements.³⁸⁴