In January 2017, the City of Toronto enacted an Ban on choke and prong collars. Many individuals including myself sent out letters of opposition regarding this ban. The following is a copy of the second letter I sent to all the Toronto City Councillors, as well as the Mayor:

 

Dear _________,

 

I recently sent you a letter on behalf of the International Association of Canine Professionals regarding the recent amendment to City of Toronto Municipal Code Chapter 349 of Item LS15.1 regarding dangerous dogs. Specifically, pertaining to the addition of section § 349-8.1 which prohibits the use of choke chains, choke collars, pronged collars or any similar devices at any time. Although I did not receive a reply regarding our concerns, several of my associates, who are Toronto citizens, did receive replies and forwarded them to me.


I would like to offer responses to some of the comments in your replies in an effort to help provide additional information and context to this important issue, and find some compromise.  I believe that through careful thought and more precise language, an appropriate addition to the municipal code can be crafted which addresses Councillor De Baeremaeker’s concern for animal welfare, without overreaching and placing restrictions on dog owners and professionals, which will ultimately cause more harm than good. Before I begin, I would like to reiterate that we support the restriction of these tools for the purposes of tethering, but oppose their complete ban.


History


I would first like to state that this is a decades old issue. Since the mid 1900’s there has been healthy discussion over what constitutes “humane” dog training techniques. In the early 1980’s that debate reached a pivotal point when professional trainers began exploring methods which involved only reward-based techniques, and avoided any form of physical manipulation, correction, or pressure. This led to more widespread use of reward-based techniques, but also to a renewed awareness that there are significant limits to what can be accomplished with this reward-only approach. Over the course of the last forty years, this debate has fueled tremendous innovation in the industry. As a whole, trainers are using more positive reinforcement and, when aversive tools, corrections, or pressure are used, it is done in a far more subtle and measured manner than was often the case in the early days of professional training.


While this discussion is far from over, and an overall consensus has not been reached, the overwhelming majority of the industry has moved toward an open and balanced approach to training, which favors taking the least aversive and invasive approach, while leaving the door open for a variety of tools and techniques to be applied when necessary. What needs to be highlighted is that while there are groups who endorse a completely reward-based approach, and denounce any and all forms of physical manipulation, correction, or pressure; these groups are considered extremist, and represent a polar limit of the spectrum. As I am sure you are aware from working within the political sphere, these types of extreme positions are rarely beneficial in the long term and do not represent the interests of the majority of the population


On the “Humane” Usage of Tools


One of the comments that was made in your replies states that while professional dog trainers may be able to use these tools humanely, the general public may not, which opens the door for abuse. This argument is supported by several flawed premises.

  1. While the origin of the prong collar is not entirely clear, it is widely published that their original purpose was to have a collar that was effective, while minimizing the possibility of abuse. In fact, among veterinary chiropractors, the prong collar is often the tool of choice. Take this quote from Dr. Daniel Kamen, one of the most respected veterinary chiropractors in the industry, from his book The Well Adjusted Dog p24-27:

    “The improper use of collars is the number one cause of cervical (neck) subluxations in dogs...The flat collar is the most common type, and can be dangerous if misused...It should not be used for obedience training...a frustrated owner who has difficulty controlling his pet will pull the dog in such a manner as to cause tremendous cervical muscle tightening, thus producing subluxations.”

    About prong collars he writes:
    “Most literature suggests that this is the most effective and least dangerous of restraining collars.The prong collar distributes pressure evenly around the neck, and requires only a small amount of force...Incidence of canine upper cervical subluxations is far less with the prong collar.”

    At this point one might argue that an owner can simply switch to a harness. But, Dr. Kamen continues:
    Although harnesses are normally thought of as being easier on the neck, they can be hard on the chest and forelegs. Harnesses have little training value.”

    The nature of the prong collar is such that it is almost impossible to cause injury to the dog, even if misused. An individual would have to go out of their way to cause physical injury using this tool. It is arguable that any individual who would go through such effort would likely commit the same abuse or worse if a prong were not available. In fact, as Dr. Kamen states, the literature suggests that there is far greater potential for physical harm from the misuse of flat collars and harnesses than from prong collars. Even if used “improperly” the prong collar is designed to be safe, with the only real risk being slightly less effectiveness than when used with professional guidance.

  2. To presuppose abuse by the unskilled owner would imply some amount of intent, or negligence. If any type of intent or negligence were present, abuse would certainly occur regardless of laws restricting collar types. The worst that is often seen when the average owner uses a prong collar without guidance is that they don’t engage in any actual training, but rather they simply rely on the tool to reduce the severity of the dog’s pulling. This is not abusive, and in fact, it is far safer than a flat collar or a martingale. The prong collar is designed to reduce the amount of pressure on the dog’s trachea. Unlike a standard flat collar or a martingale, there is no flat surface that can cut off the dog’s supply of air, or the two major veins on the side of the neck which supply blood to the brain. If a dog is going to pull on any type of collar, harness, or head halter, the prong collar is by far the safest option.

  3. There will always be a need for some amount of negative reinforcement and positive punishment among the dog owning public. While you have made the argument that prong/choke collars are likely to be abused by unskilled dog owners, that sword has a double edge. All it takes is a visit to any reward-only training class and you will see a large percentage of dog owners struggling to achieve anything that resembles reliable control of their dog. The reality is that even when a reward-only approach can work for the dog, it often doesn’t work for the dog-human team. The amount of required technical skill, experience, time, repetition etc. is simply far beyond the reach of the average dog owner. Tools such as prong collars provide immediate relief to the average dog owner, and, as already pointed out, pose negligible risk of any physical harm compared to other options. Take away these tools and owners are left with less safe, less effective tools, or must resort to the primitive concepts of hitting and striking their dogs with rolled up newspapers, belts, shoes, or worst of all, their own hands. The responsible thing to do is provide access to training which allows owners to correct disruptive behavior in a safe way, and to encourage attendance at training facilities that put an emphasis on reward-based techniques, while still teaching the fair and responsible use of negative reinforcement and positive punishment and their respective tools.


Supporting Literature or Lack Thereof


It has been referenced several times that the Councillors have not seen any literature to support the use of these tools. I would be curious to know the extent of their literature review. In addition to the work of Dr. Kamen which I cited above, there are countless books written by actual dog trainers and behavior specialists which elaborate not only on the benefits of these specific tools, but on the value and necessity of an approach to training that involves both positive reinforcement, as well as negative reinforcement and punishment.


Since no references for the Councillor’s opinions were cited, we are left to take educated guesses as to their nature and source. I am aware that the OSPCA has had some influence in this amendment, so it is perhaps a likely presumption that their position statement on training and the references therein were a part of the Councillors’ review. It is worth noting that the OSPCA position on training falls into the extremists category, promoting only reward-based techniques.


Additionally, there are a few immediate red flags when reviewing their position. First, the OSPCA creates their own definition of “Humane” which conveniently matches their exact preferred training philosophy. The implication being that any opinion or viewpoint which differs from their own is by definition “inhumane” which also leads the reader to the ad hominem conclusion that the holder of such a viewpoint is immoral. That’s a clever bit of sophistry, but fortunately any student of basic logic and debate will not fall for it. Secondly, they define “force free training” as:

Training or caring for an animal without using pain, fear, or physical or verbal intimidation techniques”.

Again, this is a sneaky use of semantics. As you will see, equating negative reinforcement and punishment with pain, fear, or intimidation is completely illogical, unscientific, and false.


From there they move on to citing the results of the studies which they list as references. I am not sure if the Councilors have carefully reviewed these studies, but there are problems with using them to support this amendment. First, not a single one of them directly mentions the effects of choke or prong collars, but rather speak of punishment in general. Second, these studies have been widely criticized for being completely biased in some cases, and in others, showing a complete lack of research methods that would resemble anything which one would consider sound science.


As an example, the study titled “Training dogs with help of the shock collar: short and long term behavioral effects.” The authors make an effort to give us every detail of the camera equipment they used to film the dog’s body language, yet they neglect to give any information regarding the make/model of the electronic collar, or the intensity and duration of the stimulation. Surely anyone who has any respect for scientific rigor would be interested in knowing the intensity of punishment involved in a study reporting the effects of...punishment.


I will save you the burden of reviewing each study in detail, but for more information on the nature of some of the current “science” that extremists groups use to support their positions, you may reference these two articles written by colleagues of mine:

https://ruthcrisler.wordpress.com/2010/03/30/remote_control/

https://smartdogs.wordpress.com/2010/01/04/that-dogma-wont-hunt/


What we do know is that there is a gaping hole in the research of modern training methods. However, for a more balanced view of the existing research (not just cherry-picking the pieces that happen to support the narrow viewpoint of a polar extreme), one might look to the three volume Handbook of Applied Dog Behavior and Training, by Steven R. Lindsey, which is a common textbook in animal behavior classes and widely regarded as the most comprehensive review of the existing research of the last century relating to dog behavior.


Unsurprisingly, after studying and reviewing all this research, Lindsey takes a moderate stance toward training tools and methods. He advocates reward-based training, while also giving due praise to tools like prong collars and electronic collars as essential to providing the type of inhibitory control and reliability that reward-based training simply cannot produce.


In Volume Two p300-303 Lindsey comments on the some of the anti-punishment “science”:

“Despite the lingering historical influences already discussed and contemporary efforts to misrepresent its usefulness, the efficacy of punishment is not really in doubt, especially if science is accepted as the final arbiter of the debate. The facts are clear and indisputable: When applied properly...punishment works, it works quickly and, in many cases, the suppressive effects of punishment are permanent.”


Lindsey continues on the topic in general:

“Whenever possible, reward-based instead of punishment based procedures should be used, but sometimes the effects of punishment are simply more expedient, reliable and enduring than the results of positive reinforcement alone. Certainly there are occasions when punishment and other aversive training procedures simply cannot be avoided, where punishment procedures even provide the most effective basis for for humanely achieving social good...Instead of extreme positions, accusatory innuendo, moralizing, and half truths, what is needed is a balanced and informed attitude regarding the practical use, misuse, and abuse of punishment”

In light of Lindsey’s analysis and the abundance of references to relevant research studies in his books which support his view, it strikes me that if there were a literature review in consideration of this amendment, it certainly wasn’t thorough, and was likely informed by suggestions coming only from groups such as the OSPCA which agree with the Councillors’ predetermined conclusion.


If more current data is needed, here is an experiment you can do on your own. Visit Amazon.com and take a look at the top brand of prong collar (Herm Sprenger) and the top brand of head halter (Halti). Scroll down to the reviews and compile some statistics. For integrity, toss out any reviews from people who haven't actually used the products but just want to voice their opinion of them, and you will be left with a decent sample of average, unskilled dog owners. Now, what percentage of those who have used the prong collar report distress or injury? What percentage of those who use a Halti (the preferred tool of “force free” trainers) report distress or injury? I think you will be surprised by the results.


The Dog’s Size/type as it Relates to Collar Choices


Councillor De Baeremaeker was recently quoted in The Star as stating:


“It’s my opinion that if you can’t control a large animal you shouldn’t buy a large animal...Dogs come from the size of a teacup to the size of a small pony so if you’re not able to handle a really large dog you shouldn’t buy a really large dog.”


The issue here isn’t only about having the strength or leverage to physically control a dog. It is about safely and humanely modifying problem behavior. In fact, small dogs receive some of the largest benefit from the prong collar. Their smaller stature makes their joints more susceptible to injury. The prong collar allows the handler to sufficiently motivate the dog when needed, while exerting far less physical force on the dog’s body.


Even if we do presume that Councillor De Baeremaeker’s assessment is accurate, then the City of Toronto ought to be prepared to euthanize a tremendous number of large breed dogs. Is that what he is advocating? Is this the Councillor’s idea of animal welfare? Tearing dogs away from their families, and euthanizing perfectly healthy dogs rather than providing access to proper training equipment?


On Prong Collars Being Inherently Painful and Inhumane


De Baeremaeker was also quoted in the Star article stating:

“I think that certainly pronged collars and choke collars are actually very painful and very inhumane.”


If this is the case, it is curious then why the amendment exempts police service dogs from the ban? The only logical conclusion to draw is that the Councillor supports the painful and inhumane treatment of Police dogs. Of course, we know that this is not actually the case, so the only other plausible explanation is that the Councillor was wrong in his assessment of these tools.


I suppose he may respond to this by asserting that police k9 handlers are professionals and can be expected to use the tools responsibly. However, this is pure speculation, and there is in fact no evidence to suggest it is true. As a professional who has attended police k9 training workshops, I can tell you that the average police k9 handler primarily receives instruction on how to handle their dogs in tactical situations, and receives very little instruction on proper and modern training techniques. Attendance at a police k9 training program will show you that the average police dog handling is more on the heavy handed end of the spectrum. Now, I am not at all condemning police k9 trainers and handlers. They do a great job given their resources and provide a valuable service to society. My point is that if you assert that the reason you have banned these tools is that you have not seen any literature to support their continued use, then please show the literature that states that police k9 handlers are somehow using these tools in a more humane way than the average owner. At the very least, hold yourselves to consistent criteria of judgment.


To further respond to the argument that these tools only work because they cause fear and pain, if that argument were scientifically and logically valid, we would also have to concede that if a martingale were to work (which they generally don’t as training tools, but more on that later),  it would only be because it causes fear and pain. If Gentle Leaders, Haltis, and other head halters work, it is only by fear and pain (after all, they operate using the same mechanisms of operant conditioning as prong collars and choke chains), and if negative punishment works (i.e. the removal of access to a reward) it is only by fear and pain. In fact, all these things work because they are uncomfortable or unpleasant, and the dog learns to avoid that discomfort by making appropriate choices.


To use an analogy, if I were given the choice between having to stand still for 30 minutes, or being able to sit down, I would choose sitting. I am not afraid of standing, nor does it cause me pain, but it does get uncomfortable after a while, and I would choose to alleviate and/or avoid that discomfort by sitting. This is how negative reinforcement and positive punishment work. Pain and fear are not necessary components, and discomfort and pain are not synonyms.


After reviewing the footage of the Council meeting where this addition to the code was voted on, as well as a radio interview with Councillor De Baeremaeker, he has on more than one occasion compared the prong collar to barbed wire. This type of hyperbolizing is both unconstructive, and unprofessional. The prong collar is in no way comparable to barbed wire. Yes, I have placed a prong collar on my own neck and pulled on it. I would never even consider placing barbed wire around my own neck, or the neck of any living being for that matter. Such comparisons only suggest that the Councillor is either completely uninformed and uneducated regarding this tool, or that he is completely unwilling to engage in a realistic, responsible, and healthy discussion of its nature and use. It appears that in the absence of fact, or any attempt to engage in responsible due diligence by pursuing a broad range of viewpoints, the Councillor has chosen instead to paint a caricature of reality in an attempt to misrepresent the truth and mislead the Council and the public.


Can We Use Other Tools Instead?


Now, I would like to move on to the argument that if dog trainers rely on a wide variety of tools, then we should easily be able to use other tools to get the job done (such as the Martingale collar which has not been banned. Again, the argument is supported by flawed premises.

  1. Martingales are not training collars. They were never intended for that purpose and are ineffective to that end. The Martingale is a restraint collar that was designed to prevent dogs with narrow heads such as Greyhounds to back-out of the collar and get loose. To even approach the same effectiveness with a Martingale as one can have with a prong collar would actually require significantly more force, and risk of injury. Remember, the purpose and use of the prong collar is not to produce a more “painful” correction, rather it is a more salient sensation, which means that you can get an appropriate correction with significantly less force, and significantly less risk to the dog's neck. Although a Martingale provides only a limited amount of slip, pulling against the leash still exerts significant force on the trachea (much like the flat collar). The prong collar works such that even if an individual intentionally uses it in an abusive manner, the risk of tracheal or structural damage is less likely than with a flat or or Martingale collar.

  2. The training collars that we use have been refined over nearly a century to allow the modern trainer and dog owner to achieve their goals while reducing the risk of injury and/or abuse. While restricting the availability of these tools may not prevent successful dog training, it certainly makes successful dog behavior training and management less safe for the dog, less safe for the handler, and actually creates the possibility for more abuse as dog owners struggle with frustrating problem behaviors without access to safe, efficient tools for resolving them.

  3. Even if we grant that choke chains are outdated for giving leash corrections, the scope of this amendment is too broad. As stated in my previous letter, trainers, veterinarians, animal control officers, kennel owners, and shelter staff rely on slip leads (similar to choke collars) to safely handle dogs in situations where reaching around their neck with a collar may be dangerous. To quote from my previous letter, professionals regularly use slip leads to
    “safely guide dogs into their respective work spaces...This new legislation now makes the use of slip leads by professionals illegal, and adds a significant amount of risk to their already challenging profession. This small amendment constitutes a massive regulation to an entire industry. Such industry regulation should not be pursued without careful thought and the counsel of professionals in the field. Enacting legislation such as this restricts and negatively impacts an entire field of professional service providers, affecting their ability to successfully and safely operate their businesses. In short, the addition of section § 349-8.1 transformed a piece of legislation that could have been beneficial, and turned it into something that is grossly irresponsible.”

    There is simply no substitute for the slip lead for this purpose. The Martingale collar still requires the professional to reach around the dog’s neck and put their person in harm's way.


Should All Negative Reinforcement and Punishment Be Banned?


What we come to is a conclusion is that the only logically consistent way to maintain an argument to ban these tools, is to argue that all forms of negative reinforcement and punishment should be illegal. This is a very extreme viewpoint, and is an extremely dangerous path to venture.


To illustrate my point, let's use the example of sexual education for teenagers. There is a parallel to our current debate in that there are groups who promote abstinence-only education as the “only way,” and there are more moderate groups who agree that abstinence is ideal, while recognizing that abstinence-only is an unrealistic pursuit, thus also promoting proper safe-sex education involving the proper use of “tools” such a condoms. It is widely publicized and validated that in areas where abstinence only is the chosen approach, rates of teen pregnancy and STD’s are alarmingly higher. See one such study here: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3194801/ . I find one quote from this research to be particularly poignant:

These data show clearly that abstinence-only education as a state policy is ineffective in preventing teenage pregnancy and may actually be contributing to the high teenage pregnancy rates in the U.S.”


Similarly, there is an argument to be made that promoting a completely “force-free” approach to dog training may actually contribute to more inhumane and abusive treatment of dogs. The belief that policies which prohibit negative reinforcement or punishment based training methods or tools such as prong collars would prevent owners from actually using punishment would be naive. As long as the general public owns dogs, you will find people using or attempting to use some form of punishment. The only thing in question is: Will they use negative reinforcement and punishment in an appropriate and effective way, as a part of a well rounded training program (which involves reward based techniques) that is fair to the dog?


Lindsey recognized this same point on page 303 of Volume 2:

Besides misrepresenting and confusing the facts, excessive moralizing about the use of punishment and other aversive training procedures may have a very undesirable effect on the dog-owning public, making responsible owners feel guilty about exercising the necessary aversive prerogatives needed to establish constructive limits and boundaries over a dog’s behavior. Many of the basic facts of life that all dogs must learn to accept (if there are to become successful and welcome companions) are won through the mediation of directive training, combining a balanced application of behavior modification - not just positive reinforcement. Instead of grinding away at a very dull ax, a dog’s welfare is better served by teaching the owner when punishment is necessary and how to use it effectively and humanely.”


If we remove access to proper education on how to integrate all of the quadrants of operant conditioning, we will be left with many dog owners inevitably using punishment inappropriately, likely out of frustration and anger and with a greater potential for real harm and abuse. The only responsible choice is to promote a training philosophy which emphasizes reward-based methods while also providing a well rounded education which includes the safe and humane application of negative reinforcement, positive punishment and their related tools.


Where To Go From Here


The only question which remains is: What might a more balanced policy look like?


We may be able to gain some insight by looking as the cruelty laws of other governments. There is a section in the UK Animal Cruelty Law which appears to handle this issue rather gracefully. Here is a section of the text:

Prevention of harm

4 Unnecessary suffering

(1) A person commits an offense if—

(a) an act of his, or a failure of his to act, causes an animal to suffer,

(b) he knew, or ought reasonably to have known, that the act, or failure to act, would have that effect or be likely to do so,

(d) the suffering is unnecessary.

(2) A person commits an offense if—

(a) he is responsible for an animal,

(b) an act, or failure to act, of another person causes the animal to suffer,

(c) he permitted that to happen or failed to take such steps (whether by way of supervising the other person or otherwise) as were reasonable in all the circumstances to prevent that happening, and

(d) the suffering is unnecessary.

(3) The considerations to which it is relevant to have regard when determining for the purposes of this section whether suffering is unnecessary include—

(a) whether the suffering could reasonably have been avoided or reduced;

(b) whether the conduct which caused the suffering was in compliance with any relevant enactment or any relevant provisions of a license or code of practice issued under an enactment;

(c) whether the conduct which caused the suffering was for a legitimate

purpose, such as—

(i) the purpose of benefiting the animal, or

(ii) the purpose of protecting a person, property or another animal;

(d) whether the suffering was proportionate to the purpose of the conduct concerned;

(e) whether the conduct concerned was in all the circumstances that of a reasonably competent and humane person.

http://www.legislation.gov.uk/ukpga/2006/45/crossheading/prevention-of-harm


How does that relate to our current discussion? Well, take a dog that is on a flat collar or Martingale, and pulling so hard it is choking and is likely to injure its trachea.  The choking and potential injury constitutes suffering, and could be avoided by using other training equipment such as a prong collar. Even if there is still some “suffering” involved (which I believe is debatable), providing that it is less than not taking any action, it is legal and more humane.

Imagine you choose a harness but you find the dog is having its armpits rubbed raw, there's still a level of suffering, maybe still unacceptable.

Or consider a dog who is on a Halti, and in distress, clawing its face trying to get it off. Again, switching to a tool such as a prong collar is not only legal, but safer and more humane (If you haven’t conducted the amazon.com review experiment, please do). If, as is the reality with many dogs, the prong collar is the tool it responds to best, then banning it would have a negative impact on that dog’s potential welfare.

Of course these are not the only possible situations, and there are conceivable contexts where the harness may be the better choice etc. The point is that this legislation moves the emphasis to the individual case being considered, allowing each owner to make a choice that is in their dog’s best interest. Gross abuse with any tool is still illegal and punishable. The law allows for flexibility toward the use of tools while still driving the trend of dog training toward the most effective and least invasive options.

To conclude, the International Association of Canine Professionals holds that it is in the best interests of both dogs and dog owners in Toronto to reopen this issue, and repeal section § 349-8.1 from the Municipal Code. If negative reinforcement and punishment are an unavoidable, and sometimes necessary part of dog ownership and training, and prong collars are one of the safest and most effective forms of negative reinforcement and punishment; then it follows what called for is not a ban of these tools, but rather more emphasis on education which promotes their responsible use.


Respectfully,


Tyler Muto

President

International Association of Canine Professionals

 

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