Association for the Blind of WA (Inc.)

Response to Discussion Paper

– Assistance Animals under the Disability Discrimination Act

Over many years, the Association has made significant human and financial investment to define its role as the Western Australian guide dog organisation. It has made concerted efforts to build community acceptance of and respect for guide dogs and their handlers. The Association undertakes an ongoing dedicated programme of work to ensure that its guide dogs properly carry out their duties and conduct themselves in a manner appropriate for their integration into the community. The exemplary health, hygiene and overall behaviour of our guide dogs equip them particularly well for any activity that requires their presence amongst the general public.

While the Association has welcomed any legislation that enshrines guide dog entitlements as legal rights, it has serious concerns about the DDA's lack of specificity in Section 9, at 1 (f) and would strongly support the removal of this clause from the Act. 

If this is not feasible, and the Act continues to make provision for "assistance animals", the Association asks how the public can be reassured that:

·        the animal has been appropriately bred and selected; and

·        both the animal and handler have been properly trained; and

·        the animal will behave in a safe and acceptable manner; and

·        the animal is clean, healthy and well-groomed; and

·        the animal's performance and ability to carry out its trained role is regularly evaluated. 

Clearly, if other assistance animals are to enjoy the same status and community acceptance as guide dogs, their provision and ongoing performance demands similarly rigorous regulation, accreditation and monitoring.

In WA, an existing and highly satisfactory regime meets the needs of the Association and its consumers. State legislation recognises Guide Dogs and their rights as well as prescribing that their bona fide status depends on their formal recognition by our organisation. The Association has credibility due to its eligibility for membership of the International Federation of Guide Dog Schools. Furthermore, the general public may be reassured of a guide dog's status by the documentation it carries affirming its legitimacy.

If section 9, 1 (f) of the DDA is to remain, and if it is to specify the recognition and regulation of assistance animals, the Association's absolute preference is that this scrutiny and control occur at state, territory and local government level rather than at a federal level (i.e. Option 2). Our organisation believes this to be the most appropriate model and one that should be adopted across all States and Territories.

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