Service Dogs Rules May Change Soon
Service Dogs - The U.S. Department of Transportation (DOT or Department) has heard from the transportation industry, as well as individuals with disabilities, that the current ACAA regulation could be improved to ensure nondiscriminatory access for individuals with disabilities, while simultaneously preventing instances of fraud and ensuring consistency with other Federal regulations.
The Department recognizes the integral role that service animals play in the lives of many individuals with disabilities and wants to ensure that individuals with disabilities can continue using their service animals while also helping to ensure that the fraudulent use of other animals not qualified as service animals is deterred and animals that are not trained to behave properly in the public are not accepted for transport as service animals.
My comment, "There is a 93-page document that addresses this concern. The current structure increases a high level of bureaucracy that falls on veterans and civilians with disabilities. Added administration for the airlines, veterinarians, and additional personnel and expense to the DOT to handle the additional paperwork and monitor the system that is placed into service.
Additional summary information can be found at https://www.regulations.gov/document?D=DOT-OST-2018-0068-1157 where the full document and be downloaded for review. Before implementing new rules the DOT has asked for comments. What follows are my comments addressing this issue.
COMMENTS ON ID. DOT-OST-2018-0068-4724
Our Veterans and People with disabilities are already under a great deal of stress trying to live a normal life alongside people without disabilities. Those people with “Service Dogs” (SD) have already spent from one year, or as much as two training with their SD. The commitment for this is time and money – Lots of both. The SD can cost from $25,000 to $60,000 dollars depending on the modality they train in for their handler. Our Veterans and people with disabilities are easy to see why they are in need of assistance when it’s physical in nature, such as missing limbs, body braces, etc. There are other conditions that you cannot see such as those caused by Diabetics, Traumatic Brain Injury (TBI) or Posttraumatic Stress Disorder (PTSD) that cause seizures where the SD is critical in helping these people. Handlers with a trained SD are advocates of identifying their partners in life as Service Dogs. However, let's not make it more difficult than it needs to be for the disabled handler.
Service Dog National Registration
Handlers have advocated for a National Registration program so that when the training was performed the training organization could submit the Handler and SD for registration. A card would be provided by the training organization identifying the handler and SD by photos on the card. The required information and photos can fit on a card the size of a Drivers's License or Military CAC card.
Assistance Dog International
The basics for this already exist today. The Federal Government provides financial assistance and veterinary care to Veterans if the training organization used was the Assistance Dog International (ADI) https://assistancedogsinternational.org The average wait time for acceptance is 2 ½ years before training can begin.
American Kennel Club (AKC)
Other training organizations use the structure and certifications provided by the AKC for training and final certification that signifies the handler and SD have passed the courses required for the handler's individual disability. An example of AKC organizations is the American Service Animal Society (ASAS) https://dogs4vets.org and Dog Training Elite https://dogtrainingelite.com/gilbert These organizations use and follow similar training that will mainstream the handler and SD into a stage of life that is once again productive. They provide identification for the handler and SD. While this is positive, any inquires go back to the training organization to establish the validity of the handler and SD. The problem is that it’s not a National Registration that recognizes submittals from certified organizations. This has given way to unscrupulous organizations that deliver fake products for a fee. Because we do not have a Federal National Registry we have FAKE organizations that provide a Doctor’s letter for the airlines or housing, an ID card, a service vest, and sight unseen. The only requirement is a fee. No training validation for the K9 is needed – Just a fee and like magic, the person was validated for an SD or Emotional Support Animal (ESA). Places such as the:
- US Support Animals https://usserviceanimals.org/,
- Federal Service Dog Registration https://www.federalservicedogregistration.org/, and
- USA Service Dog Registry https://usaservicedogs.org/registration.
are culpable in making this an issue. This places the public at risk because the mitigation of risk to the public has not been reduced by appropriate SD training, This has caused the DOT to take this action. The SD and handler recognize the appropriate documentation that is necessary to carry when taking public transportation. It’s part of their training.
- Should a veterinarian certify the SD? No, they are not qualified as SD trainers. They provide shot records and a health certificate within their medical field.
- Should an airline person determine if the K9 is SD certified? No – Unless they have been trained in all the modalities of the requirements for the SD.
- Should the airlines and handlers be required to fill out additional paperwork as a handler of an SD? No – The additional stress over and above a person with non-disabilities is not required.
Do not penalize or make life more difficult for a disabled handler and SD because bogus organizations have found a way to capitalize on this issue that is not trained and may pose a risk to the public. SOLUTION: A Federal National Registry is the better choice, least-cost approach, and advocated by certified training organizations. The handlers that have invested their time and money would also agree. Those with bogus credentials will not agree.
Jeffery Daley, PhD