Hi I know this isn't strictly speaking research and development but I thought I' send it on the net anyway for whatever help it may be.
to all Dog guide users and interested
persons especially Randolph-sheppard vendors:
I am a Seeing Eye graduate, with a ten-year-old female Golden
Retriever named Sunshine, who took training to be a vendor in the
Randolph-Sheppard program in La. in 1993. . Below is
the new regulation for dog guides in federal Randolph-sheppard
vending facilities. This regulation which the government claims is
drawn up in conjunction with the Americans with Disabilities Act,
(A.D.A.), is far too restrictive and gives building managers far
too much latitude in determining where, how and what securing
method we will use for our dog guides. I want everyone to know
about it as I am trying to get all interested parties to work
together to change this regulation as there are dangers in it.
1. While I have no quarrel with keeping my dog guide clean,
groomed or out of food prep or serving areas as I do not want dog
hair in my food any more than anyone else does nor do I wish either
an employee or my dog guide hurt by an employee moving quickly to
serve a customer and tripping over her, this regulation in its
present form gives us no grievance procedure in the event we are
wrongly treated by an operator, B.E.P. staff person or building
manager.
2. An operator hiring or training an employee or trainee can under
this regulation simply declare the entire area behind the counter
a food prep or serving area so as not to have anywhere to place the
dog, and if the building manager agrees then the dog guide user has
no leg to stand on to fight any determination of this type.
3. As this regulation is being interpreted, a building manager can
arbitrarily declare that a dog guide user in a given facility must
use a certain securing method for his or her dog or even whether or
not there can be a dog guide in the facility at all. He or she can
say to the operator that a dog guide must be kennelled, be leashed,
or not be permitted in the facility at all if he or she thinks it
would be in violation of this regulation. Why should a building
manager who does not use a dog guide and is not faced with the
mobility needs of a blind user determine whether or not a dog can
be present and what method is best to secure the dog? This, in
effect, gives them the right to choose our mobility method for us
as dog guide users are forced to leave their dog guides at home,
accept inferior training in lower volume facilities because of
their dogs or not take training at all rather than submit to this
kind of legalized blackmail. This takes the fundamental right of
the owner to determine how best to care for his or her dog guide.
And why should anyone including a building manager or a facility
operator have anything whatsoever to say about something the law
already entitles us to have everywhere that is open to the public
including the work place which is not open to the public but is
clearly specified in the law?
I am not exaggerating as all these things happened to me when I
took training in Louisiana and the B.E.P. staff personnel including
the director herself and her crew of supervisors known as
B.B.M.A.'s backed the building managers and operators at every turn
even when I tried to show them how the regulation could be complied
with.
Dog guides have been present in vending facilities long before
A.D.A. and if there were problems they were dealt with on a case by
case basis; that's the way it should be now.
If anyone wishes to comment, they may direct email to my internet
address: hheagy@delphi.com hheagy if you are on Delphi already, or
netmail me through my fidonet address: 1:396/1 or post
in Blink Talk, Blind Talk, or N.F.B. Talk. I also have a
resolution which I have sent to Ramona Walhof which should be
proposed and considered at our convention in Detroit next week.
Please get behind it! Thank you.
Sincerely,
Harvey Heagy
CONCESSIONS MANAGEMENT HANDBOOK
U.S. GENERAL SERVICES ADMINISTRATION
WASHINGTON, DC 20405
PBS P 5815.2A
CHAPTER 5
OCTOBER 7, 1988
O. Accommodating dog guides. Some blind persons use dog
guides to assist them in traveling. GSA must make every
reasonable effort to accommodate dog guides within the confines
of Randolph-Sheppard Vending Facilities during the period the dog
guide's master is working in the facility. (See 41 CFR 101-
20.311.) Dog guides must be allowed to remain within the vending
facility if the following conditions are met:
(1) State and local laws are adhered to regarding dog
guides.
(2) Dog guides are inoculated for rabies as frequently as
required by applicable State and local laws and regulations. In
the absence of such local laws and regulations, dog guides must
be inoculated at least once a year. Satisfactory evidence of
each inoculation must be displayed by the vendor at the request
of the buildings manager.
(3) The dog guide is restrained within the vending facility
by one of two methods, at the discretion of the master and deemed
to be most practical for the specific location:
(a) By the use of a leash in a designated area when
not being used by the blind person as a mobility aid and shall
remain secured in that area while in the vending facility.
(b) By the provision of a "crib-like" enclosure. The
dog guide shall be placed in the enclosure immediately upon
arrival and remain confined there while in the vending facility.
The guiding harness and/or leash may be removed while the dog
guide is in the compartment.
(c) Regardless of which method (a or b) is used, the
dog guide shall be located away from the serving/preparation area
and, if possible, in line-of-sight of its master. The location
shall be of adequate size to restrain the dog comfortably, permit
free circulation of air, and be kept clean at all times. A clean
pad, covered with waterproof material, may be provided.
(4) The area selected for restraining the dog guide shall
be mutually agreed upon by the buildings manager and the licensed
blind vendor, and if necessary, in consultation with the SLA.
PBS P 5815.2A
October 7, 1988
(5) Dog guides shall be housebroken, well groomed, clean,
and free from odor at all times. The dog and the vending
facility shall be kept free from fleas and other vermin.
(6) The dog guide should be exercised regularly outdoors
during the day as required.
(7) Satisfactory housekeeping conditions must be maintained
at all times. Any unsatisfactory condition resulting from the
presence of the dog guide shall be corrected immediately.
Harvey Heagy
in New Orleans
`[1;36;45mRainbow V .99 for Delphi - Registered
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