Are the rules governing service animals on airplanes about to change? The US Department of Transportation’s advisory committee on accessible air transportation met recently to consider refining the presents rules for Emotional Service Animals. Ever since 2003 when the DOT revised its policy on service animals to include emotional-support animals, there have been no restrictions for these animals and no real definition of a service dog. As Jenine Stanley, who serves on the committee and is with the Guide Dog Foundation, has noted there are no real rules as to what is a legitimate service or support animal.
“Once you board your plane with your animal and you say ‘I am coming with a service animal,’ i.e. an animal that is trained to medicate my disability, it’s anyone’s guess as to whether it’s true or not,” she said. Which is why the U.S. DOT wants to change the rules.
There have been numerous complaints from fellow travelers about the wide assortment of species, from miniature horses, pigs, boas, cats, and of course, dogs, that have been accorded the status of ESA and who usually have scant training about how to behave on an airplane. Some of the complaints have also been generated by people who have highly trained and skilled service dogs, such as seeing-eye dogs. Many of the ESA pets on planes can also distract (to put it mildly) a service dog from doing her job.
One key issue the committtee looked at was: Should specific species be defined? If so, what are they? The group suggested only dogs be listed as service animals, and dogs, cats and rabbits qualify as emotional support animals.
Another complication surrounding ESAs are the legal ramifications to the mental health professionals who are providing certifications. The University of Missouri recently conducted a study about the possible conflicts this presents to psychologists. Cassie Boness, a graduate student in clinical psychology, says these requests for certification for emotional support animals present several potential conflicts for mental health professionals.
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“There are no standards for evaluating the need for an emotional support animal, whereas there are concrete rules to determine if someone is eligible for a service animal. These emotional support animal letters are formal certifications of psychological disability, and the psychotherapist is stating, by writing such a letter, that the person needing the emotional support animal has such a disability and that the presence of the animal addresses that disability.” Jeffrey Younggren, professor of clinical and forensic psychology, believes that the evaluation process should address the specific psychological issues that are going to be improved, and not just that the owner wants to be with their pet. They also noted that the lack of scientific guidelines regarding emotional support animals would make it difficult for the psychologist to defend this certification letter in court.
Younggren noted that "the study recommended was two fold: First, that these letters not be written by treating therapists for ethical issues but that they should be written by forensic evaluators/psychologists who do not have a dual role with the client. Second, we stated that, since these are disability determinations, there needs to be some type of comprehensive psychological assessment of that disability and that assessment should directly assess how the presence of the animal ameliorates the disability."
The working group committee members include representatives from American Airlines, Psychiatric Service Dog Partners, National Alliance on Mental Illness, Guide Dog Foundation for the Blind and America’s VetDogs. Key issues about service animals can be found here.
Stanley said she expects the new rules to be out for public comment within the year and to be set within three years.