Doc No: 96-0139

Margaret Ager
Canine Companions for Independence
Southeast Regional Office
Orlando, Florida

Marilyn Baldwin, Commissioner
Florida Commission for the Transportation Disadvantaged
Tallahassee, Florida

Valerie Barber-Simpson
Casselberry, Florida

Marion Gwizdala
National Federation
of the Blind of Florida
Brandon, Florida

Carala Jewell
Tampa, Florida

Catherine Kelly
Florida DOT
Tallahassee, Florida

James P. Liensenfelt
Space Coast Area Transit
Cocoa, Florida

Anne N. Schwarz
KETRON Division of
The Bionetics Corp.
Malvern, Pennsylvania
Kelly Shawn
Community Transportation Association of America
Washington, DC

Project Manager

Robert Carlson
Project ACTION
Washington, DC

REVIEWERS:

Federal Transit Administration

Arthur Lopez
Office of Civil Rights
Washington, DC

Service Animal Organizations

Alison Schultz
Canine Companions for Independence
Southeastern Regional Office
Orlando, Florida

Susan Duncan, RN
Delta Society
National Service Dog Center
Renton, Washington

A wide variety of animals are now being trained to assist individuals with disabilities. In addition to guide dogs, which assist persons who have vision impairments, dogs and other animals are being trained to assist persons who have hearing impairments, mobility limitations, seizure disorders, mental impairments, and other disabilities.

Recognizing the important role that service animals play in helping persons with disabilities to be more independent, the Americans with Disabilities Act of 1990 (ADA) and its implementing regulations include provisions specific to their accommodation. Included in the ADA regulations is the right of a person traveling with a service animal to enjoy equal access to public and private transportation programs.

This project represents nearly two years of research into service animal training policies and practices, public transportation policies and practices, and a review of pertinent laws, regulations, and literature. The Center for Urban Transportation Research (CUTR) contacted a variety of service animal training centers for information. Canine Companions for Independence, Inc. (CCI) and the Delta Society National Service Dog Center provided invaluable advice throughout the project. Southeastern Guide Dogs provided additional assistance.

Two documents were produced: Assisting Passengers Traveling with Service Animals: Final Report and Assisting Passengers Traveling with Service Animals: Training Module. The Final Report documents the project and describes the issues relating to service animals and the ADA. The Training Module is a self-contained guide for public transportation personnel to use to train their employees on how to assist passengers traveling with service animals.

Every effort was made to describe clearly what is required by the ADA and what is not. Nonetheless, because this is an evolving topic, not every issue is completely clear, nor do the "experts" agree in every case on how to handle passengers traveling with service animals. One thing is clear, however: "If it looks like a service animal, and the handler says it is a service animal, then welcome the service team aboard."

Introduction   1
Overview of the Issues   3
Training Instructions   5
Training Slides   7
Trainers' Script   15
Sample Transit Policies   39

This training module was developed for Project ACTION by the Center for Urban Transportation Research at the University of South Florida in Tampa.

The goal of this training module is to provide useful information to assist public transportation providers on how to transport persons who have disabilities traveling with service animals. It may be used alone or with other passenger assistance and sensitivity training materials.

The materials included in this training module are based on information gathered from service animal training centers and users, transit and paratransit agencies, and the Federal Transit Administration. A Final Report also was prepared and is available through Project ACTION.
 

The Americans with Disabilities Act of 1990 (ADA) is civil rights law that prohibits discrimination against persons with disabilities. The law applies to a variety of issues including employment, access to services (including transportation), access to facilities and public accommodations, and access to telecommunication systems.

According to Title II of the ADA regulations:
 

• Public and private entities providing public transportation shall permit service animals to accompany individuals with disabilities in vehicles and facilities.

This means that transit, paratransit, and taxi operators must permit service animals to ride on their vehicles at no extra charge to the passenger.
 

What is a service animal?

Service animals are not pets. They are working animals that are specially trained to provide assistance for individuals who have disabilities.

According to the ADA regulations:
 

• Service animal means any guide dog, signal dog, or other animal individually trained to work or perform tasks for an individual with a disability, including, but not limited to . . .

(continued on next slide)
 

- guiding individuals with impaired vision

- alerting individuals with impaired hearing to intruders or sounds . . .

(continued on next slide)

- providing minimal protection or rescue work

- pulling a wheelchair or

- fetching dropped items.

49 CFR 37.3

The term "service" (or "assistance") animal is somewhat generic and may be used to describe all types of animals individually trained to assist persons with disabilities. Most--but not all--service animals are dogs:
 

• Guide dogs (or dog guides) provide assistance for persons who have visual impairments. Do not use the term "Seeing Eye Dog." This term refers only to dogs trained at The Seeing Eye, Inc., in Morristown, New Jersey. There are many other guide dog schools.

• Assistance or mobility dogs assist persons using wheelchairs and others who have mobility limitations. They may pull a wheelchair, fetch dropped items, handle money, carry briefcases, open doors or perform other tasks.

• Hearing or signal dogs assist persons with hearing impairments by alerting them to sounds such as alarms, horns, crying babies, telephones, and doorbells.

• Seizure-response/alert dogs assist persons with epilepsy or other seizure disorders. They may alert the person to an oncoming seizure, provide assistance during and after the seizure, seek help or perform other tasks. Because a person may not have an obvious disability, it may be hard to recognize a seizure-response/alert dog team.

• Emotional support dogs and other animals such as cats, assist persons with mental disabilities (e.g., autism or severe psychological problems), who use the assistance of a service animal to function independently. Because it may be difficult to tell the difference between a pet and an emotional support animal, you may need to ask: "Is this a service animal?"

continued . . .

• *In contrast, therapy animals, facility animals, and other social animals are not specifically trained to perform a function for a particular person with a disability and, therefore, are not considered to be service animals. These animals would not be afforded access rights under the ADA.

Note: Remember, access rights depend on whether the person has a disability and is protected by the Americans with Disabilities Act AND whether the animal meets the definition of a service animal.
 

• There also are specialty and combination dogs, which are trained to perform tasks for a person with multiple disabilities. For example, a dog may be trained both as a guide dog and a service dog for a person with a vision impairment who uses a wheelchair.

.

Not all assistance dogs look alike!

Although many service dogs are Labrador Retrievers, Golden Retrievers, or a combination of the two, there are many breeds used as service animals.

Some training schools prefer to use one breed over another, which may account for regional differences in which breeds of dogs are seen most often locally.

In addition to Retrievers, assistance dogs may be Pembroke Welsh Corgis, Dalmatians, Poodles, Collies and Shelties, Shepherds, mixed breeds or others.

Don't be surprised to see virtually any type or size of dog used as a service animal.
 

For example, this Pembroke Welsh Corgi is a puppy-in-training. He is about to start being trained as a hearing dog. Shown here with a Canine Companions for Independence (CCI) Trainer, he is taking its first ride on a Lynx transit bus in Orlando, Florida.
 

Many other types of animals also may be trained as service or assistance animals.
 

• Cats are sometimes used as hearing or seizure-alert animals. Cats also may be trained to provide emotional support for persons with mental impairments, preventing them from having serious anxiety attacks. Service cats should wear a collar or harness and leash, or be carried in a carrier. Service cats are covered under the service animal provision of the ADA. Pet cats are not covered by the ADA.

• Capuchin monkeys also are sometimes trained to provide assistance for persons with quadriplegia or who have other mobility limitations. They may assist with opening jars, handling money, working a computer, operating switches or fetching dropped items. If a service monkey accompanies a passenger, it should be on a leash or in a carrier. Service monkeys are covered under the service animal provision of the ADA.

• Pot bellied pigs are quite intelligent and are sometimes trained as service animals. One such service pig rides the bus in New York City. Pigs are sometimes an alternative for people who are allergic to dogs. Pigs should be on a leash with a collar or harness. Service pigs are covered under the service animal provision of the ADA.

• Birds and other animals are sometimes used as seizure alert or therapy animals. These animals are somewhat fragile and are not often seen on public transportation vehicles. If someone is traveling with a service bird, it should be in a carrier.

If in doubt, ask: "Is this a service animal?"
 

Under the ADA, public entities (including public transportation operators) may not require proof that an animal is a service animal.

Some service animal training programs provide photo ID tags, training certificates or equipment with logos. However, there is no universally accepted training certification process and you cannot demand to see proof that an animal is a service animal.
 

• Some transit and paratransit systems ask for the animal to be included in the passenger's ID photo. While this practice certainly makes it easier for drivers to identify a service animal, a passenger should not be required to be photographed with his or her service animal.

Service animal puppies-in-training are not explicitly offered protection by the ADA; however, many states do have laws permitting puppies-in-training to have access to public entities, including public and private transportation.

Although there may be a few people who try to "beat the system" by bringing pets on board public transportation vehicles, most persons claiming to have service animals really do have service animals.

The best advice is to avoid a confrontation.
 

If in doubt, ask: "Is this a service animal?"
 

If it looks like a service animal, and the handler says it's a service animal, then welcome the service animal team aboard your vehicle.
 

If you are still uncertain, contact dispatch for assistance.
 

There are no uniform requirements for equipment used for assistance animals. However, all service animals should be on a leash held by the handler or in a carrier at all times.

Guide dogs often have harnesses with stiff handles, which are used to help their handlers maintain a fixed position relative to the dog and to better feel when the dog stops, starts or changes direction.

Service animals sometimes--but not always--wear a backpack or cape with the logo or name of their training school.

Some service animals have identification tags; however, an ID is not required.

Some dogs wear a head halter that might look like a muzzle. This halter helps to provide directions to the dog and is not an indication that the dog is going to bite.

Although by definition a service animal is trained to perform certain tasks that assist its human partner, there are no standard criteria for training service animals.
Training may be done by a training school or independent trainer; some people even train their own service animals. Training can take several months or even years to complete.

Several training programs are working to develop a standard proficiency test to certify service animals; however, there is no agreement within the service animal training community about what minimum standards should be required.

This lack of a certification program creates obvious problems for transit agencies (and other public accommodations) trying to tell the difference between a service animal and a pet.

Some service animal training schools do provide their service animal teams with a certificate upon successful completion of training. Again, while a certificate may be helpful for transit agencies trying to identify whether an animal is a service animal, a certificate from a service animal training program cannot be required as proof the animal is a service animal.

Because access for persons with disabilities traveling with service animals is a civil right covered by the ADA, it is better to err on the side of permitting access than to deny access to a person with a legitimate right to use the service.

If in doubt, ask: "Is this a service animal?"

Service animals should be under the full control of the handler at all times. That means the animal should be on a leash or in a carrier.
 

(An exception to this may occur when boarding and alighting at which time the animal might be left onboard while the passenger maneuvers on or off the vehicle. In this case, the handler would ask the driver to hold the leash.)
 

All service animals should be clean and well groomed. They should be free from ticks, fleas, and other pests. Some van and sedan operators carry a sheet or towel for the animal to sit on if they are concerned about animal hair and dander.
 

If a particular service animal appears to be dirty or poorly cared for, notify the local animal control board or the service animal training school (if known).

As seen in this photograph of a service dog riding on a Lynx transit bus in Orlando, Florida, service animals are trained to sit under the passenger's seat or at their handler's feet. The aisle should remain clear so that the animal is not stepped on and does not trip other passengers.

In some cases, small service animals may ride on a passenger's lap; however, service animals should never ride on bus or van seats.
 

Some public transportation providers are concerned about carrying service animals in their vehicles.

Service animals are trained to behave well in public. A service animal should not growl, bark or bite other animals or passengers.

If the service animal poses a threat to other animals or people, you have the right to deny it access. However, do not deny access because of past experiences with a particular breed or type of dog. Denying access must be based on an individual situation and immediate concern for public or personal safety.

If a driver feels a particular animal poses a threat or is afraid of a service animal, he or she should contact dispatch for assistance.
 

Many people with service animals can board and alight without assistance. Always ask if the passenger needs assistance before helping. Because there are no standard training practices, riders may have been taught different techniques for boarding and alighting with service animals.

Never touch a service animal or take its leash unless asked to do so by the passenger. Likewise, never give the animal commands unless asked to do so by the passenger.

Remember. Some passengers with service animals may have "hidden disabilities" such as epilepsy.
 

• Paratransit operators may have eligibility information relating to functional disabilities and that will make it easier for them to identify a passenger with a hidden disability riding with a service animal. When booking trips on paratransit, persons traveling with service animals should be identified on the driver's log.

• Fixed route and taxi operators may have a more difficult time deciding whether a person who has a hidden disability is traveling with a service animal because they do not have eligibility information.

Also, some passengers may have multiple disabilities. For example, a person who uses a wheelchair may have a hearing impairment and be traveling with a hearing dog, rather than a mobility dog. Or, a person who uses a wheelchair may have a visual impairment. The service dog could be providing mobility assistance AND be functioning as a guide dog.

Again, it is better to err on the side of allowing access. If in doubt, ask: "Is this a service animal?"
 

There is no one "correct" way to board and alight from a transit vehicle when traveling with a service animal.

The best advice is to ask the passenger how you can assist them with boarding or alighting.

Some points to remember:
 

• A service animals might board and alight with the passenger if the passenger is ambulatory.

• A service animals might board first and alight after the passenger if the passenger is using a wheelchair.

• Because of safety concerns, service animals should not be allowed to ride on wheelchair lifts. Their tails, paws, heads or equipment may catch in the lift mechanism, causing severe injury to the animal. An exception might be a standee traveling with a service animal who boards using a lift.

In this photo the service animal was left in a "sit-stay" position on the bus while the passenger rode down on the lift.

Once the lift was on the ground, the passenger turned around to call the dog to her.

If the passenger asks you to hold the dog's leash while he or she rides down on the lift, be sure the leash will not catch on anything when you release the dog and it jumps off the vehicle. Some passengers may ask you to let the animal board and alight using the steps.

Points to remember:
 

• Always ask the passenger how he or she would like to board before helping.

• Do not distract the service animal or give it commands while the passenger is boarding or alighting from the vehicle. Only take its leash if asked to by the passenger.

• If necessary, remind other passengers the service animal is working and not to touch or distract it.

Slide No. 19
Photo: Guide Dog Boarding Van
Trainers' Script

In contrast, this slide shows the guide dog was left outside the van while its handler boarded the paratransit van first.

When boarding a van, there may not be enough room for the passenger to maneuver with the animal in the vehicle. Likewise, the animal may get off the van first and wait for the passenger.

Once the passenger was seated in the van, he called the dog to him. The dog rode on the floor at the passenger's feet.

Points to remember:
 

• As with fixed route, the driver should ask how the passenger wishes to board and alight from the paratransit vehicle, and how the driver can assist.

• A service animal should not be allowed to ride on a vehicle seat. It should ride on the floor of the vehicle (or on the passenger's lap if the animal is small).

Slide No. 20
Remember
Trainers' Script

Service animals should be welcomed on public transportation vehicles not just because it is a passenger's right to travel with a service animal, but because it is the right thing to do.

If in doubt, ask: "Is this a service animal?"

Always remember:
 

• If it looks like a service animal . . .

• And the handler says it's a service animal . . .

• Welcome the service animal team aboard.

• Animals on Board... Do not allow passengers accompanied by animals to board your bus. Only small caged animals are allowed aboard, accompanied by their owner. Seeing-eye and Hearing-ear dogs will be allowed to accompany their owners aboard the coach.

This statement is incorrect. All service animals must be allowed to accompany their handlers, not just guide dogs or hearing dogs.

• Pets... Small pets are permitted if enclosed in a proper carrying cage no larger than 21" x 13" x 9". Large animals are prohibited on trains with the exception of service animals, which are animals trained to assist individuals with a disability as defined in the Americans with Disabilities Act of 1990. However, animals which may be unsafe to other customers may be denied passage aboard the train.

Technically correct; could be improved by stating what is allowed first (i.e., service animals must be transported) before stating what cannot occur.

• No Animals on Board Buses... Operators shall not allow animals aboard any bus operated by the Transit Authority, except for Seeing Eye Dogs for the blind, or small animals confined to portable cages. Any pet owner who insists on bringing his/her uncaged pet aboard the bus should be informed to remove himself/herself and the pet from the bus immediately.

If a problem results, contact a Supervisor at once and do not enter into any further discussion with the passenger.
Do not forcefully remove either the passenger or the pet from the bus. This could result in your arrest, so it is best to let the police officer do this if this measure is required.
 

• Passengers Are Permitted to Travel with Assistance Animals Trained to Assist Them... Coach operators shall permit assistance animals to accompany passengers with disabilities.

Although technically correct, this statement does not really say anything and does not help the driver to know what an assistance animal is.

• Guide Dogs... The visually impaired passenger may travel with a guide dog. The only assistance this passenger may require will be an indication as to where to sit. Seating should provide ample space for the dog in which to lie down where he will be out of passenger traffic.

Only addresses guide dogs. Further, some persons with visual impairments may need to know more than just where to sit (e.g., where to get off the bus).

• Animals... Seeing-eye dogs, hearing-aid dogs, and other special-assistance dogs are allowed aboard buses. Once aboard, dogs must remain on a leash, under the complete control of the owner and remain in the "down" or "sit" position for the remainder of the ride. The dog may ride on the passenger lift with the passenger. For your safety, (the transit agency) recommends that the dog not occupy the bus aisle or bus seats.

Intent is correct, but terminology is not correct ("seeing-eye" and "hearing aid" are incorrect terms). It is not safe for service animals to ride on lifts unless absolutely necessary. Also, dogs should not block aisles nor should they be allowed to occupy a seat.

• Assist Animals Are Permitted on Our Buses... Assist animals include but may not be limited to seeing eye dogs, hearing dogs and monkeys. All assist animals require some official authorization. You may request to see this authorization if is not apparent that the animal is an official assist animal.

This statement is incorrect. The system cannot require "official authorization" and the driver may not request to see any.

• Carriage of Small Animals... Small animals may be carried free of charge, provided they are securely enclosed in a box or basket sufficiently small enough to be carried without danger or offense to other passengers.

Also permitted are trained service animals used by disabled individuals. In those circumstances where it may not be obvious that a particular animal is a trained service animal, individuals shall provide written assurances, in response to a request by an employee and as a condition of admission to the transit system, that the animal is, in fact, a trained service animal. Examples of written assurances include a letter from a doctor, a letter from the service animal's trainer, or a certification of training.
 

• Discount Cards... Qualified individuals who travel with a certified signal, service, or guide dog should include the dog in the photograph for the card. This will assist you in boarding with your dog.

Generally all right; however, could imply discount cards require photo. Also, dogs are not the only kind of service animal.

• PCA... Individuals accompanying an ADA paratransit individual as a Personal Care Attendant (PCA) must be designated at the time of certification (this includes service animals). On paratransit trips the PCA must have the same origin and destination as the eligible passenger.

When scheduling trips...Inform the scheduler if you are in a wheelchair, use a walker, etc., and of any persons (including PCA or a service animal) traveling with you.
 

• Service Animals... Service animals shall always be permitted to accompany their users in any...public transportation vehicle...One of the most common misunderstanding about service animals is that they are limited to being guide dogs for persons with visual impairment. Dogs are trained to assist people with a wide variety of disabilities, including individuals with hearing and mobility impairments.

Other animals (e.g., monkeys) are sometimes used as service animals as well. In any of these situations, the entity must permit the service animal to accompany its' user.
 

• Assistive Animals--July 7, 1994 Operator's Bulletin... Operators are reminded that assistive animals, accompanying customers with visual, hearing, or mobility disabilities, ride free. Also, if a customer states that he/she uses the animal to assist with a disability, treat the animal as an assistive animal. Customers with assistive animals usually prefer to sit in the securement area so the dog can rest out of the aisle. Please accommodate this request, unless a wheelchair user needs this area.