Assisting Passengers
Traveling with
Service Animals
Final Report
January 1997
Prepared by:
Rosemary G. Mathias
Center for Urban Transportation Research
College of Engineering
University of South Florida
4202 E. Fowler Ave., ENB 118
Tampa, Florida 33620
Tel: 813-974-3120
Prepared for:
Project ACTION
700 Thirteenth Street NW, Suite 200
Washington, DC 20005
Tel: 202-347-3066
Doc No: 96-0138
This document is disseminated under sponsorship of Project ACTION of the National Easter Seal Society in the interest of information exchange. Neither Project ACTION, National Easter Seal Society, nor the Federal Transit Administration assumes liability for its contents or use thereof. The contents of this report reflect the opinion of the author.
The author thanks the following individuals from the Center for Urban Transportation Research (CUTR), who participated in the preparation of this report: Lisa Argiry, Julée Green, Sheryl Stire, and Vicki Zambito. Thanks also to R. Benjamin Gribbon, for proposing the project, and to Robert Carlson of Project ACTION, who provided assistance throughout the project. Special thanks to Alison Schultz of Canine Companions for Independence (CCI) Southeast Regional Training Office, and Susan Duncan of the Delta Society National Service Dog Center, for their insight and advice relating to training service animal teams. Finally, thanks to the many transit agencies and service animal training schools that provided materials for this study.
This document is disseminated under sponsorship of Project ACTION of the National Easter Seal Society in the interest of information exchange. Neither Project ACTION, the National Easter Seal Society nor the Federal Transit Administration assumes liability for its contents or use thereof. The contents of this report reflect the opinion of the author.
Service Animal Project Steering Committee
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
FTA 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
Executive Summary
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 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."
Table of Contents
Introduction 1
Applicable Laws & Regulations 5
Service Animal Capabilities 11
Transit Policies & Procedures 25
Conclusions 35
References Cited 37
Appendices
Appendix A Commonly Asked Questions About Service Animals in Places of Business
Appendix B Glossary of Terms
Appendix C Service Animal Organizations & Training Schools
Appendix D Assistance Dogs International (ADI) Member Programs Minimum Training Standards
Appendix E Assistance Dogs International (ADI) Member Programs Standards and Ethics
Appendix F Sample Service Animal Policies
Appendix G Sample Driver & Client Directions
Appendix H Resources
Introduction
With passage of the Americans with Disabilities Act of 1990 (ADA), persons who use service animals gained new access rights to public and private accommodations, among them the right to use public transportation provided by public and private entities (49 CFR 37.167). The purpose of this report, and its companion Training Module, is to clarify the issues related to public transportation access rights for persons traveling with service animals including dogs, cats, pigs, monkeys, and other animals.
Service animals are not pets. They are individually trained to perform specific tasks for their human partners such as guiding someone with a visual impairment, fetching dropped items, pulling a wheelchair, providing signals for persons with hearing impairments or alerting their partners of an oncoming seizure. For convenience (and as a function of their jobs) many service animals wear a harness, cape, or backpack, often with some form of identification. Nonetheless, service animals are not required to be certified or registered, which can make it difficult for drivers to distinguish between a pet and a service animal.
The impetus for this study came from anecdotes about transit and paratransit drivers who were afraid of transporting service dogs or simply did not want to transport passengers traveling with service animals. After reviewing training materials provided through several public transit training programs, it became clear that there were virtually no training materials available on this topic. The materials in these documents will help to fill that gap.
This project was conducted by the Center for Urban Transportation Research (CUTR) at the University of South Florida in Tampa. The study was sponsored by Project ACTION, part of the National Easter Seal Society, and funded through a grant from the Federal Transit Administration (FTA).
The Final Report includes a description of relevant legislation and regulations at the federal and state levels with respect to access rights for persons with service animals. It also includes a description of various types of service animals and information about the scope of training they receive. Further, the Final Report includes examples of service animal policies gathered from transit agencies around the country, some of which are "good" and some of which are "bad."
The Appendices include a Department of Justice memo responding to frequently asked questions, a glossary of terms, a list of service animal training schools, a sample standards and ethics statement, sample recommended minimum training standards, sample service animal policies from transit systems, sample driver directions, and a list of related resource materials.
At a minimum, the Final Report should be read by managers, supervisors, and trainers who are responsible for ensuring that their transit and paratransit personnel understand and comply with the requirements of the ADA with respect to transporting passengers traveling with service animals. The Appendices will provide resource documents to support public transportation agencies in developing better service animal policies and procedures.
The Training Module (a separate document) includes materials that may be used by public transportation providers to teach their personnel how to assist passengers traveling with service animals. It includes a trainers' script and 20 slides. The Training Module may be taught alone or in conjunction with other passenger sensitivity or assistance techniques training courses and may be used toward satisfying the training requirements of the ADA (49 CFR 37.173). Trainers should read and be familiar with the Final Report prior to teaching the course.
Applicable Laws & Regulations
Americans with Disabilities Act of 1990
The ADA is civil rights legislation. Among other things, the ADA mandates that:
No entity shall discriminate against an individual with a disability in connection with the provision of transportation service. . . . an entity shall not, on the basis of disability, deny to any individual with a disability the opportunity to use the entity's transportation service for the general public, if the individual is capable of using that service.
- 49 CFR 37.5(a)(b)
Included in the ADA regulations is the right of a person traveling with a service animal to have equal access to public transportation accommodations:
(Public and private entities providing public transportation) shall permit service animals to accompany individuals with disabilities in vehicles and facilities.
- 49 CFR 37.167(d)
The ADA defines service animals in the following way:
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, guiding individuals with impaired vision, alerting individuals with impaired hearing to intruders or sounds, providing minimal protection or rescue work, pulling a wheelchair, or fetching dropped items.
- 49 CFR 37.3
Although references to services animals comprise a relatively small part of the ADA overall, in practice the regulations pose some significant operational issues for public transportation providers. For example, the definition of a service animal is somewhat vague; there are no adopted certification standards by which to know whether an animal truly is a service animal or simply a pet.
Further, the ADA does not specifically mention requirements for service animal identification, training, animals in training, or penalties for interference with a service animal team. The identification issue is compounded when a person has a hidden disability (e.g., epilepsy) and travels with a service animal (such as a seizure-response/alert dog or cat). In such cases it could be very hard for a driver to believe the service animal is not a pet. Likewise, service animal trainers are not "certified" and may be independent or affiliated with a service animal training school. In addition, individuals with disabilities sometimes train their own service animals. These issues and others will be discussed more fully in the section on Service Animal Capabilities and in the Training Module.
Because the ADA is civil rights legislation, suits may be filed directly in federal court should an individual believe he or she has been discriminated against under the provisions of the ADA. An individual also may file a complaint directly with the U.S. Department of Justice (DOJ), which handles complaints regarding claims of discrimination under Titles II and III of the ADA.
State Statutes & Regulations
Although many access rights are covered by the ADA, state statutes may grant additional rights to persons with disabilities. A booklet published by Assistance Dogs International, Inc. (ADI), includes a list of federal and state statutes pertaining to service animals (Roche 1994). For example, some state statutes further define issues such as what constitutes interference with a service animal team and what the associated penalties will be if someone interferes with the access rights of a person with a service animal.
In 1996, the U.S. Attorney General's office prepared a statement responding to frequently asked questions about access rights for service animals. The statement was localized and reissued through state-level attorneys general. A copy of that document, "Commonly Asked Questions About Service Animals in Places of Business," distributed in Florida in July 1996, is included in Appendix A. Similar documents should be available from the attorney general's office in each state. The Florida version includes answers to the following questions (see Appendix A for complete text):
1. What are the laws that apply to my business?
The answer lists applicable federal (ADA) and state statutes and regulations. In Florida, for example, a violations of access laws incurs a second-degree misdemeanor, which may lead to incarceration and/or a criminal fine. Civil penalties for mental anguish, loss of dignity, and other tangible injuries are covered. Florida law provides for punitive damages of up to $100,000.
2. What is a service animal?
The memo describes a service animal, as defined by the ADA, and clarifies that they do not have to be "certified" service animals.
3. How can I tell if an animal is really a service animal and not just a pet?
This section points out that some, but not all, service animals have certification or identification papers. It also states that you may not insist on proof of certification, even if some states have certification programs.
4. What must I do when an individual with a service animal comes to my business?
Service animals must be permitted in all areas where customers may go.
5. I have always had a clearly posted "no pets" policy at my establishment. Do I still have to allow service animals in?
Yes. Service animals are not pets.
6. My county health department has told me that only a seeing eye or guide dog has to be admitted. If I follow those regulations, am I violating the ADA?
Yes. Any type of service animal must be allowed. The ADA takes priority over local or state laws or regulations.
7. Can I charge a maintenance or cleaning fee for customers who bring service animals into my business?
No. However, a public accommodation may charge a customer with a disability if his or her service animal causes damage, as long as it is the regular practice of the entity to charge non-disabled customers for the same type of damage.
8. I operate a private taxicab and I don't want animals in my taxi; they smell, shed hair and sometimes have "accidents." Am I violating the ADA if I refuse to pick up someone with a service animal?
Yes.
9. Am I responsible for the animal while the person with a disability is in my business?
No.
10. What if a service animal barks or growls at other people, or otherwise acts out of control?
Any animal, including a service animal, may be excluded when the animal's behavior poses a direct threat to the health or safety of others. However, you may not assume that a particular animal is likely to behave badly, based on experience with other animals.
11. Can I exclude an animal that doesn't really seem dangerous but is disruptive to my business?
There may be a few circumstances when a public accommodation is not required to accommodate a service animal if it would fundamentally alter the nature of the business. An example would be a dog that barks during a movie. (See Question No. 10.)
Summary
This section provided a brief overview of applicable laws and regulations pertaining to access rights of persons with disabilities and their service animals. Although service animals are defined in the ADA, there are no criteria requiring identification or certification of a service animal. Further, public entities are prohibited from requiring certification of a service animal for the purpose of access. This lack of universally recognized standards has made it difficult to distinguish between service animals and pets in some cases. The next section describes service animals and their capabilities, which may help to make it easier to distinguish between a pet and service animal.
Service Animal Capabilities
Background
Service animals are used to assist persons with disabilities including those with visual impairments, hearing impairments, mobility impairments, epilepsy, rheumatoid arthritis, and other physical disabilities. Service animals also may be trained to assist persons with mental disabilities. This section presents an overview of service animals (sometimes called assistance animals) and their capabilities. It includes a description of types of service animals and the training they receive.
Types of Service Animals
There are many types of service animals including:
- Guide dogs (or dog guides) for persons who have visual impairments.
- Service animals (e.g., dogs, cats, monkeys, pigs) for persons who have physical disabilities.
- Hearing and signal animals (e.g., dogs and cats) for persons who are deaf or have hearing impairments.
- Seizure-response/alert animals (e.g., dogs, cats, birds) that alert individuals with seizure disorders to oncoming seizures and/or help the individual during and following the seizure.
- Emotional support animals (e.g., dogs and cats) that provide assistance for persons with severe emotional impairments or mental disabilities.
Dogs are by far the most common type of service animal. However, cats, pot bellied pigs, monkeys, and birds also are trained as service animals. Some dogs also are cross-trained to provide a combination of assistance, such as guiding a visually impaired person while pulling his or her wheelchair.
Guide Dogs
Most people are familiar with dogs that have been trained to guide persons who are visually impaired. The first guide dog in the United States was trained in the 1920s at The Seeing Eye, Inc., in Morristown, New Jersey. For many years The Seeing Eye was the only training school for guide dogs in this country, which is why is it common (although incorrect) to hear guide dogs called "seeing eye dogs." The correct term is "guide dog" (or "dog guide") (see Appendix B for a glossary of terms). In fact, now there are many schools that train guide dogs for people who have visual impairments (see Appendix C for a list of service animal training schools).
Guide dogs are trained to lead their handlers around obstacles and to protect them from dangerous situations. Guide dogs are taught what is sometimes called, "intelligence disobedience"; that is, a guide dog will refuse to carry out a command that puts its handler in danger (e.g., crossing in front of a car).
Many breeds are used as guide dogs including Labrador Retrievers, Golden Retrievers, German Shepherds, Australian Shepherds, Collies, mixed breeds, and others. Most guide dogs are outfitted with a collar, leash, leather harness, and stiff handle. Verbal commands (e.g., "forward" and "find the door") are given to instruct the dog. Handlers use both a leash and harness to maintain control of the dog. No one other than the dog's handler should instruct the dog, unless asked to do so by the handler. Because the public is fairly familiar with guide dogs, they are generally easily recognized and readily admitted to public facilities, including public transportation vehicles and facilities.
Service Animals
In this context, service animals refer to dogs, monkeys, pigs, and other animals that are trained to assist persons with mobility limitations including persons who use wheelchairs. Many different types of dogs, including mixed breeds, are used as service dogs, depending on the functions they will perform.
Service animals provide assistance in a number of ways. They may be taught to retrieve dropped items, pick up papers, pull their partner's wheelchair, and carry items. For example, a service dog may carry a worker's briefcase in its mouth, placing it within reach upon arriving at the destination. Service animals also are trained to push elevator buttons, turn light switches off and on, open doors, and to retrieve groceries from a store shelf. Service animals may provide several types of assistance, particularly if the human partner has multiple disabilities such as a visual impairment and a mobility impairment.
Although there are no legal requirements for service dog certification or identification, Assistance Dogs International (ADI) has developed minimum training standards for its member organizations to follow (see Appendix D). Assistance Dogs International requires that a service dog trained by its member organizations carry a laminated ID card with its picture and the names of the dog and its handler. ADI also requires that a service dog trained by its member organizations wear a collar, leash, and cape or backpack, which must bear the logo of the training center and clearly state the animal is a service animal.
When questioned about whether public transit providers can require service animals to carry identification and wear capes, harnesses, backpacks, or other identification, the Federal Transit Administration responded that such a requirement may be in conflict with the ADA, citing 49 CFR 37.5(d) of the regulation, which states: "an entity shall not impose special charges . . . on individuals with disabilities." Thus, although many service animals will bear this type of identification, not all will. Given that identification is not required, it is illegal to require a person with a service animal to provide proof that the animal is a service animal; however, you may ask, "Is this a service animal?"
Monkeys also are sometimes used as service animals. They are taught to perform many of the same functions as service dogs, such as retrieving dropped items, and can also be taught to open packages and jars, and to provide assistance with eating and other tacks of daily living. Monkeys are seldom seen on transit vehicles, although a bus system in Florida reports that it has a passenger who travels with a monkey, who deposits the fare into the farebox. As with service dogs, a monkey should have a harness or leash (or be kept in a carrier) so that it is under the control of its handler at all times.
Pigs are very smart and are sometimes used as service animals. Pot bellied pigs are small and favored as service animals by persons who are allergic to dogs. The New York City Transit Authority has a passenger who travels with a service pig (TD Safety & Access Report 1995).
Hearing or Signal Animals
Hearing animals are usually dogs; however, cats also have been trained as hearing animals. Hearing animals are trained to respond to sounds their human partners cannot hear. For example, a hearing dog can be trained to respond to telephones, doorbells, alarm clocks, crying babies, fire alarms, car horns, sirens, and other sounds. Hearing animals alert their partners by physically contacting them and/or leading them to the source of the sound.
As is the case with other service animals, a variety of breeds are used as hearing dogs, often not fitting the stereotype Labrador Retriever or Golden Retriever some people may expect to be used as a service animal. For example, Canine Companions for Independence (CCI) sometimes uses Pembroke Welsh Corgis and, in the past, has trained Border Collies and Shelties. Other schools use Poodles or Terriers. The San Francisco SPCA (Society for the Prevention of Cruelty to Animals) Hearing Dog Program rescues dogs from the animal shelter to train as hearing dogs. In the past 15 years, that program has trained more than 450 hearing dogs (Eames and Eames 1995).
Although there are no legal requirements for hearing dog certification or identification, Assistance Dogs International, Inc., has developed minimum training standards for its member organizations to follow (see Appendix D). Assistance Dogs International requires that a hearing dog trained by its member organizations carry a laminated ID card with its picture and the names of the dog and its handler. Assistance Dogs International also requires that a hearing dog trained by its member organizations wear an orange collar, leash, and cape with the words "hearing dog" stitched or printed on them. Although many hearing dogs will have this type of identification, not all will. Given that identification is not required, it is unlawful to require a person with a hearing dog (or cat) to provide proof that the animal is a service animal.
With respect to cats, their use as hearing animals is a more recent innovation. Public transit drivers should expect to see hearing cats on their vehicles. Cats either are carried in a carrier or harnessed on a leash.
Because persons with hearing impairments may not be readily recognized, people with hearing dogs and cats have faced tremendous obstacles concerning access, which is compounded by communication problems associated with their hearing impairments. You may ask, "Is this a service animal?"
Seizure-response/alert Animals
A seizure-response/alert animal senses when its human partner is about to have a seizure. No one is exactly sure how some animals know that a seizure is imminent. It may be a change in scent, behavior or something else. In addition to alerting its owner about an oncoming episode, seizure-response/alert dogs may be trained to stay with the person during a seizure, seek help, help the person become reoriented following the seizure or provide mobility assistance. Seizure-response/alert dogs also may be trained to fetch medication or press a medical alert button if the person is unable to do so him or herself. Sometimes other animals are used as seizure-response/alert animals including cats and birds. There also is evidence that some snakes or iguanas may be capable of detecting someone about to have a seizure; however, it is not clear whether these animals would really qualify as a service animal.
Seizure-response/alert animals are among the most difficult for a transit driver to identify, particularly because their handlers often have hidden disabilities (e.g., epilepsy).
Emotional Support Animals
Probably the bigger discussion point concerning service animals has to do with whether emotional support animals are service animals or social animals/pets. This is an important distinction because service animals have access rights under the ADA, but social animals and pets do not. Emotional support animals are used to assist persons with mental disabilities (e.g., autism or severe psychological problems), who use the assistance of a trained service animal to function independently.
In contrast, therapy animals, facility animals, and other social animals typically receive obedience training; however, they 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 types of animals would not be afforded access rights under the ADA.
Some transit systems (e.g., Chicago Transit Authority) have elected to allow therapy animals onboard buses and trains, if they have proper identification from local training facilities. (Although service animals may not be required to have an ID or certification document, therapy and facility animals not covered by the ADA can be required to have this type of proof, if desired.)
The question to ask is whether the animal is a service animal. If the answer is yes, then the service animal team must be transported. For now, until further guidance is offered by law or regulation, it is better to err on the side of the ADA and allow access.
Typical Assistance Dog Training
There are no universally accepted methods for training or certifying assistance dogs. However, Assistance Dogs International has developed minimum training standards for its member organizations to follow (see Appendix D). In addition to the training requirements, ADI has developed a Code of Standards and Ethics for its members and is creating minimum requirements for assistance dog partners and assistance dog trainers (see Appendix E). Although there are no set training criteria, service dogs, guide dogs, and hearing dogs trained by assistance animal schools do go through a similar pattern of training, as described below.
Puppy Raisers
Puppies are given to volunteer puppy raisers, who will care for them until they are old enough to begin advanced training. During this phase, the puppies might be taken to obedience training to learn basic obedience commands such as sit, stay, heel, down, and come here. At the same time, they are socialized with other dogs and people. Some puppy raisers take their puppies with them to school or work. Throughout this phase the intent is to expose the dog to as many different experiences as possible so that it will be well-mannered and not easily distracted by new sights, sounds, and smells. Play time and quiet time also is included in puppy training. The puppies sleep in the puppy raiser's bedroom.
When in public, these puppies often wear capes identifying them as puppies in training. Some state laws allow puppies in training to have access to public accommodations including public transportation, but this varies by state (Roche 1994). SamTrans specifically notes that 4-H club members serve as puppy raisers and should be allowed access onto SamTrans' vehicles (see SamTrans' Draft Service Animal Policy included in Appendix F).
Training
Puppies are returned to the training school to receive their assistance dog training. They are carefully evaluated to test their temperament and natural abilities. Dogs intended for service animal training are spayed or neutered. Dogs selected to continue in the training program spend additional time learning to perform specific tasks (e.g., guiding a person who is blind, responding to doorbells and telephones, fetching dropped items, pulling a wheelchair). Not every dog makes it through the training program, either because of temperament, health or physical problems.
Placement
After a service dog completes its training program, it is matched with a human partner. Trainers attempt to match skills, physical size, and personality types of both the dog and human. Teams are then trained together for up to several weeks (or longer, if needed) so that they can bond and learn how to work with each other and develop proper public etiquette. During this phase the person also learns about caring for his or her dog, including veterinary care requirements, flea and tick control, grooming, and good nutrition. Once the trainer is satisfied the pair has sufficiently bonded and learned to work together, the team graduates. Some training organizations provide annual follow-up evaluations to ensure that no bad habits have developed and to correct any training deficiencies. At that time they also can retrain the dog or person if a person's functional abilities have changed.
Certification Issues and the Problem of "Fakes"
For the past several years Assistance Dogs International and its member organizations have been working to develop a standardized public access test for assistance dogs. Canine Companions for Independence and other ADI-member training schools have been voluntarily using the test as part of the graduation requirement and follow-up for their programs. Participating programs report the pass/fail rates and test results to ADI as a means of validating the test.
A considerable amount of discussion and debate takes place on the Internet concerning assistance dogs and requirements for training (see Internet and E-mail references in Appendix H). There is a sense of concern among assistance dog users that "fakes" as they call them, will ruin it for "legitimate" assistance animal users by bringing poorly trained pets or therapy animals into public facilities.
Summary
The purpose of this section was to describe service animals and the tasks they can perform. Keep in mind that not all persons with disabilities will be easily identified because of hidden disabilities (e.g., epilepsy or hearing impairments). Also, some service animals may provide assistance to persons who have multiple disabilities. In that case, the service animal may be trained to provide a combination of functions. For example, a person who is visually impaired and uses a wheelchair may depend on a service dog both for guidance and to pull the wheelchair. Likewise, someone who has a hearing impairment and a mobility limitation may have a hearing dog that does not provide functional assistance for his or her mobility limitation.
The discussion in this section has centered on dogs because they are the most common service animals. As stated above, cats, monkeys, pigs, birds, and other animals also are trained as service animals. Their training is somewhat different. Service animals may be trained by training schools, independent trainers, or self-trained by persons who have disabilities. The bottom line is if an animal is trained to perform tasks associated with assisting a person with a disability, it is a service animal and is afforded access rights under the ADA. Animals that are present simply to provide companionship are considered to be therapy or social animals, and do not appear to have access rights under the ADA.
The next section addresses issues of implementing the ADA requirements.
Transit Policies & Procedures
The previous section provided information about service animals, their training, and what can be expected from a trained service animal team. This section describes what public transportation providers can do to implement the ADA requirements for transporting persons with disabilities who travel with service animals. It also suggests ways to address service animals through appropriate agency policies and procedures.
Implementation Issues and Answers
Implementing public policy directives, including the service animal provisions of the ADA, is not always easy. For public transportation providers, a whole host of issues arises: How do I know if it's a service animal? What am I supposed to do when a service animal team boards the train, bus or van? What if a driver is allergic to dogs (or cats)? What if the animal has an "accident" onboard the vehicle? What if the dog leaves dog hair or fleas behind? What if the animal bites someone? What if . . . ?
These issues fall into four basic categories: (1) identification of service animals, (2) health concerns, (3) safety issues, and (4) passenger assistance. Each will be discussed below.
Identification
As stated earlier, the ADA defines generally what a service animal is and does, but fails to address how to identify service animals. As a result, public transportation providers and other public entities have been left on their own to figure out how to identify a service animal. The public advisory issued by DOJ, reprinted in Appendix A, provides some guidance on this topic:
The ADA defines a service animal as any guide dog, signal dog, or other animal individually trained to provide assistance to an individual with a disability. If they meet this definition, animals are considered service animals under the ADA regardless of whether they have been licensed or certified by a state or local government. . . .
A service animal is not a pet. . . .
Some, but not all, service animals wear special collars and harnesses. Some, but not all, are licensed or certified and have identification papers. If you are not certain that an animal is a service animal, you may ask the person who has the animal if it is a service animal required because of a disability . . . Although a number of states have programs to certify service animals, you may not insist on proof of state certification before permitting the service animal to accompany the person with a disability.
Thus, some service animals will have identification and/or certification papers issued by a training program. Although having an ID card may make it easier for drivers to identify a service animal, the lack of an ID card in no way implies the animal is not a service animal. If in doubt, ask: "Is this a service animal?"
Some transit agencies have requested that the service animal appear with its handler in the discount or paratransit identification card photograph. Although this approach would certainly help to verify for the driver that the animal in the photograph is a service animal, it is not clear that public transportation systems can legally require the animal to be photographed with the passenger. This is one of the issues yet to be fully resolved.
As in any unregulated industry, there is a potential for abuse by those who represent themselves as traveling with a service animal when, in fact, the animal is not a service animal. In some respects, this is one of the most talked about issues, not only for public entities, but also for persons with service animals who are concerned that "fakes," as they call them, will ruin it for "legitimate" service animal users. Even if there were regulations in place to certify service animals, abusers would find a way to beat the system.
- If in doubt, ask: "Is this a service animal?" If the person says it's a service animal and the animal is under the control of the handler, then treat them as a service animal team and welcome them aboard.
Health Concerns
During the research for this project, transit personnel expressed a great deal of concern over health and safety issues related to service animals. One set of concerns centers on issues related to "accidents" or damage onboard vehicles; hair and dander; fleas, ticks or other pests; and what to do if drivers (or other passengers) are allergic to animals.
During their training, service animals are socialized and taught not to relieve themselves in public facilities. Occasionally a "mistake" will occur and it is the responsibility of the passenger to clean up any mess associated with a service animal that has had an "accident" onboard a vehicle or in a facility. According to the DOJ Policy Advisory, included in Appendix A:
. . . a public accommodation may charge its customers with disabilities if a service animal causes damage as long as it is the regular practice of the entity to charge non-disabled customers for the same type of damages.
Some training programs teach their students how to care for their service animals with respect to veterinary needs, feeding, and grooming. Flea and tick prevention is taught and with new products available to reduce or eliminate ticks and fleas, service animals should be virtually pest free. Some paratransit operators have service animals sit or lie on a sheet or towel so that hair and dirt can be easily removed after the animal leaves the vehicle (remember, service animals should ride on the floor of the vehicle or be in a secure carrier). In an extreme case, if the driver notices an animal appears to be poorly cared for and poses a health concern, contact the local animal control board or the school where the animal was trained and report the incident.
Allergies generally should not be problematic for fixed route drivers who have little direct contact with service animals. The issue may be more critical for paratransit drivers who come into closer contact with service animals and passengers onboard their vehicles. Paratransit drivers who are allergic to animals should not be assigned to transport passengers traveling with service animals.
Similarly, it appears to be reasonable that when making a reservation, a paratransit passenger should be required to notify the system that he or she will be traveling with a service animal. This practice will avoid problems with drivers who are allergic to animals. It also will allow schedulers to consider space requirements and load factors for vehicles transporting service animals (remember, the animal is to sit or lie on the floor of the vehicle or be in a carrier). Finally, it will help the driver to know that a service animal will be transported if it is noted on the manifest (in the same way a person requiring use of a wheelchair lift is indicated on a manifest).
- The bottom line is that the ADA requires public transportation entities to provide access to persons with disabilities who are traveling with service animals. Minimizing potential problems by training and developing proactive written policies and procedures will help transit personnel (especially drivers) to better assist passengers traveling with service animals and will avoid costly legal fees that might be incurred as a result of wrongfully denying service to someone traveling with a service animal.
Safety Issues
Another set of concerns focused on safety issues relating to liability if a service animal caused injury to another animal or person. Remember: service animals are socialized and trained to interact appropriately with other animals and people. Nonetheless, it is possible that a service animal could be provoked and become aggressive. According to the DOJ Policy Advisory, included in Appendix A:
You may exclude any animal, including a service animal, from your facility when the animal's behavior poses a direct threat to the health or safety of others. For example, any service animal that displays vicious behavior towards other guests or customers may be excluded. You may not make assumptions, however, about how a particular animal is likely to behave based on your past experiences with other animals. Each situation must be considered individually.
The best practice is to develop a written policy regarding service animals that includes directions for drivers on how to cope with service animals if the animal becomes aggressive. Some transit agencies have included this type of information in their operators' procedures (see SamTrans Draft Service Animal Policy included in Appendix F). Again, developing proactive policies and applying them fairly and consistently will aid the driver and the system. Being reactionary in response to a situation without benefit of written guidelines could create serious problems for a transit agency and end up in court.
Keep in mind, too, that control of the service animal is the responsibility of the animal's handler. The DOJ Policy Advisory found in Appendix A states:
The care and supervision of a service animal is solely the responsibility of his or her owner. You are not required to provide care or food or special location for the animal.
If an incident occurs and the public transportation entity has followed proper standard policies and procedures for transporting service animals, then accountability for damages or injuries should remain with the person responsible for the dog. A transit agency may wish to seek its own legal counsel on this point and develop written practices that address this type of occurrence. This is a good example of an item that could be included in a pamphlet on rider rights and responsibilities.
- Remember the old adage, "an ounce of prevention is worth a pound of cure." Proper written policies and procedures, and ongoing training of transit personnel will help to avert problems before they occur. Remember: the goal is to transport all passengers safely to their destinations--including those traveling with service animals.
Passenger Assistance
One of the goals of this project was to develop a set of instructions drivers could use to assist passengers with disabilities who were traveling with service animals. Not surprisingly, there appears to be no one "best" way to assist passengers who have disabilities and travel with service animals. Persons who have disabilities have varying degrees of capabilities. The same is true for service animal users. Some will be very independent and require little or no driver assistance. Others will be more in need of assistance.
Different service animal trainers also teach different methods for boarding and alighting from transit vehicles, often tailored to meet the needs of the individual and his or her service animal. There are a few general rules that should be followed:
- Do not stereotype passengers based on their disabilities. For example, do not assume that all persons with visual impairments require the same level of assistance.
- Ask the passenger what you can do to assist.
- Do not touch or give the service animal any commands unless asked to do so by its handler.
- If necessary, remind passengers that the service animal is working and not to distract it.
- A service animal might board and alight with the passenger if the passenger is ambulatory.
- A service animal might board first and alight after the passenger if the passenger is using a wheelchair.
- In most cases, 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.
- Service animals should sit or lie on the floor. Animals should not occupy a passenger seat.
- Service animals should not block the passenger aisle.
- Remember some people have hidden disabilities, making it hard to know the person has a disability and even harder to identify a service animal. Ask if the animal is a service animal.
- You may not require identification or proof that an animal is a service animal. You may ask, "Is this a service animal?"
- The best advice is common sense and courtesy. Avoid confrontations and call dispatch if there is a problem or question.
Additional information on assisting passengers is included in the Training Module.
Conclusions
This document and its companion Training Module were written to present information on how public transportation entities can better identify and assist passengers with disabilities who travel with service animals. This project was written in response to concerns voiced by transit agencies reacting to the service animal provisions included in the Americans with Disabilities Act. The ADA represents civil rights law, which takes precedence over other state and local laws, regulations or ordinances.
Seven years after passage of the ADA, much remains to be done to make public transportation systems more user-friendly and accessible for all passengers, including persons traveling with service animals. Transit policies still exist that only cite access rights for guide dogs (often incorrectly termed "seeing-eye dogs"). Many transit policies do not acknowledge the variety of animals now used as service animals and the multitude of tasks they can be trained to perform. There is very little information provided in passenger assistance or sensitivity courses dealing specifically with service animals.
The approach taken here is meant to be positive and supportive of providing the best possible public transportation service for persons with disabilities who travel with service animals. The information presented here is intended to serve as a bridge between ADA policy and implementation--not always an easy task!
Rather than being reactive, the purpose of this document is to be proactive. The aim is to educate public transportation personnel about service animals and the persons with disabilities who depend on them for greater independence and an improved quality of life. By understanding how service animals are trained and used, transit personnel will be able to develop a better understanding of how to assist passengers who travel with service animals.
By using these materials and reviewing their own policies and procedures, public transportation entities should possess enough information to develop appropriate policies and procedures that will aid their employees in knowing how to assist passengers traveling with service animals. Remember: Access for persons with disabilities who are traveling with service animals is not only a civil right, but it's the right thing to do.
- If it looks like a service animal,
- And the passenger says it's a service animal,
- Then welcome aboard the service animal team!
References Cited
Eames, Ed and Toni Eames
1995 Partners in Independence. Dog World 80(5):50-52.
Roche, Michael P.
1994 Legal Rights of Guide Dogs, Hearing Dogs and Service Dogs. Lakewood, CO: Assistance Dogs International.
TD Safety & Access Report
1995 Pig Travels as Service Animal on NYCTA Bus. TD Safety & Access Report 3(7):4-5.
Assisting Passengers
Traveling with
Service Animals
Appendices to
Final Report
January 1997
Prepared by:
Rosemary G. Mathias
Center for Urban Transportation Research
College of Engineering
University of South Florida
4202 E. Fowler Ave., ENB 118
Tampa, Florida 33620
Tel: 813-974-3120
Prepared for:
Project ACTION
700 Thirteenth Street NW, Suite 200
Washington, DC 20005
Tel: 202-347-3066
This document is disseminated under sponsorship of Project ACTION of the National Easter Seal Society in the interest of information exchange. Neither Project ACTION, National Easter Seal Society, nor the Federal Transit Administration assumes liability for its contents or use thereof. The contents of this report reflect the opinion of the author.
Acknowledgments
The author thanks the following individuals from the Center for Urban Transportation Research (CUTR), who participated in the preparation of this report: Lisa Argiry, Julée Green, Sheryl Stire, and Vicki Zambito. Thanks also to R. Benjamin Gribbon, for proposing the project, and to Robert Carlson of Project ACTION, who provided assistance throughout the project. Special thanks to Alison Schultz of Canine Companions for Independence (CCI) Southeast Regional Training Office, and Susan Duncan of the Delta Society National Service Dog Center, for their insight and advice relating to training service animal teams. Finally, thanks to the many transit agencies and service animal training schools that provided materials for this study.
Appendices
Appendix A Commonly Asked Questions About Service Animals in Places of Business
Appendix B Glossary of Terms
Appendix C Service Animal Organizations & Training Schools
Appendix D Assistance Dogs International (ADI): All Member Programs Minimum Training Standards
Appendix E Assistance Dogs International (ADI): All Member Programs Standards and Ethics
Appendix F Sample Service Animal Policies
Appendix G Sample Driver & Client Directions
Appendix H Resources
Appendix A
Commonly Asked Questions
In July 1996, the Florida Office of the Attorney General issued the attached public advisory regarding Service Animals in Places of Business. Similar statements were issued in other states.
State of Florida
Office of the Attorney General
SUBJECT: Commonly Asked Questions About Service Animals in Places of Business
CATEGORY: 6 - Public Advisories
DATE ENTERED: 07/25/96
1. Q: What are the laws that apply to my business?
A: Under the Americans with Disabilities Act (ADA), privately owned businesses that serve the public, such as restaurants, hotels, retail stores, taxicabs, theaters, concert halls, and sports facilities, are prohibited from discriminating against individuals with disabilities. The ADA requires these businesses to allow people with disabilities to bring their service animals onto business premises in whatever areas customers are generally allowed.
Under Florida law, the blind and all other physically disabled persons who use guide dogs or service animals are entitled to equal access, without extra charge, to all common carriers, airplanes, motor vehicles, railroad trains, motor buses, streetcars, boats, and other public conveyances or modes of transportation, and at hotels, lodging places, restaurants, places of public accommodation, amusement or resort and other places to which the general public is invited. Violation of this law is a second degree misdemeanor which may result in incarceration and/or a criminal fine. Additionally, violation of this law may result in civil penalties for mental anguish, loss of dignity and any other tangible injuries. Florida law also provides for punitive damages not to exceed $100,000. See Section 413.08, Florida Statutes.
2. Q: What is a service animal?
A: The ADA defines a service animal as any guide dog, signal dog, or other animal individually trained to provide assistance to an individual with a disability. If they meet this definition, animals are considered service animals under the ADA regardless of whether they have been licensed or certified by a state or local government.
Service animals perform some of the functions and tasks that the individual with a disability cannot perform for him or herself. "Seeing eye dogs" are one type of service animal, used by some individuals who are blind. This is the type of service animal with which most people are familiar. But there are service animals that assist persons with other kinds of disabilities in their day-to-day activities. Some examples include:
- Alerting persons with hearing impairments to sounds.
- Pulling wheelchairs or carrying and picking up things for persons with mobility impairments.
- Assisting persons with mobility impairments with balance.
- A service animal is not a pet.
3. Q: How can I tell if an animal is really a service animal and not just a pet?
A: Some, but not all, service animals wear special collars and harnesses. Some, but not all, are licensed or certified and have identification papers. If you are not certain that an animal is a service animal, you may ask the person who has the animal if it is a service animal required because of a disability. However, an individual who is going to a restaurant or theater is not likely to be carrying documentation to his or her medical condition or disability. Therefore, such documentation generally may not be required as a condition for providing service to an individual accompanied by a service animal. Although a number of states have programs to certify service animals, you may not insist on proof of state certification before permitting the service animal to accompany the person with a disability.
4. Q: What must I do when an individual with a service animal comes to my business?
A: The service animal must be permitted to accompany the individual with a disability to all areas of the facility where customers are normally allowed to go. An individual with a service animal may not be segregated from other customers.
5. Q: I have always had a clearly posted "no pets" policy at my establishment. Do I still have to allow service animals in?
A: Yes. A service animal is not a pet. The ADA requires you to modify your "no pets" policy to allow the use of a service animal by a person with a disability. This does not mean you must abandon your "no pets" policy altogether but simply that you must make an exception to your general rule for service animals.
6. Q: My county health department has told me that only a seeing eye or guide dog has to be admitted. If I follow those regulations, am I violating the ADA?
A: Yes, if you refuse to admit any other type of service animal on the basis of local health department regulations or other state or local laws. The ADA providers greater protection for individuals with disabilities and so it takes priority over the local or state laws or regulations.
7. Q: Can I charge a maintenance or cleaning fee for customers who bring service animals into my business?
A: No. Neither a deposit nor a surcharge may be imposed on an individual with a disability as a condition of allowing a service animal to accompany the individual with a disability, even if deposits are routinely required for pets.
However, a public accommodation may charge its customers with disabilities if a service animal causes damage as long as it is the regular practice of the entity to charge non-disabled customers for the same types of damages. For example, a hotel can charge a guest with a disability for the costs of repairing or cleaning furniture damaged by a service animal if it is the hotel's policy to charge when non-disabled guests cause such damage.
8. Q: I operate a private taxicab and I don't want animals in my taxi; they smell, shed hair and sometimes have "accidents." Am I violating the ADA if I refuse to pick up someone with a service animal?
A: Yes. Taxicab companies may not refuse to provide services to individuals with disabilities. Private taxicab companies are also prohibited from charging higher fares or fees for transporting individuals with disabilities and their service animals that they charge to other persons for the same or equivalent service.
9. Q: Am I responsible for the animal while the person with a disability is in my business?
A: No. The care or supervision of a service animal is solely the responsibility of his or her owner. You are not required to provide care or food or a special location for the animal.
10. Q: What if a service animal barks or growls at other people, or otherwise acts out of control?
A: You may exclude any animal, including a service animal, from your facility when the animal's behavior poses a direct threat to the health or safety of others. For example, any service animal that displays vicious behavior towards other guests or customers may be excluded. You may not make assumptions, however, about how a particular animal is likely to behave based on your past experiences with other animals. Each situation must be considered individually.
11. Q: Can I exclude an animal that doesn't really seem dangerous but is disruptive to my business?
A: There may be a few circumstances when a public accommodation is not required to accommodate a service animal--that is, when doing so would result in a fundamental alteration to the nature of the business. Generally, this is not likely to occur in restaurants, hotels, retail stores, theaters, concert halls, and sports facilities. But when it does, for example, when a dog barks during a movie, the animal can be excluded.
If you have further questions about service animals or other requirements of the ADA, you may call the U.S. Department of Justice toll-free ADA Information Line at 800-514-0301 (voice) or 800-514-0383 (TDD). You may also contact Gregory Durden, Director of Civil Rights, Office of the Attorney General, State of Florida at (954) 712-4800.
DUPLICATION OF THIS DOCUMENT IS ENCOURAGED
Appendix B
Glossary of Terms
Glossary of Terms
ADA - Americans with Disabilities Act of 1990 is civil rights law that provides protection against discrimination to persons with disabilities. ADA regulations permit service animals to accompany individuals with disabilities in vehicles and facilities.
ADI - Assistance Dogs International is an organization of assistance dog providers committed to developing standards of training and ethics for the industry. ADI is working to develop a certification test to protect individuals from scam artists who provide poorly trained animals.
Assistance Animals - the appropriate term for all animals providing assistance to individuals who have disabilities (see also service animals).
Facility Dogs - like social animals, facility dogs are used in nursing homes or at other facilities to provide companionship to seniors, children, or persons with disabilities. These dogs do not have access rights under the provisions of the ADA.
Guide Dogs (or Dog Guides) - assist persons who are blind or visually impaired by guiding them safely around obstacles. Note: "Seeing Eye Dog" is a generic term for guide dogs. "Seeing Eye Dog" should only be used in reference to dogs that were trained at The Seeing Eye, Inc., training center in Morristown, New Jersey.
Hearing & Signal Dogs (or Hearing Ear Dogs) - alert persons who are deaf or hearing-impaired to many everyday sounds such as alarms, timers, doorbells, the person's name, crying babies, etc. Some cats also are trained to perform these tasks. These animals have access rights under the provisions of the ADA.
IAADP - International Association of Assistance Dog Partners is a national consumer advocacy group composed of people who are blind or visually impaired partnered with guide dogs, people who are deaf/hearing impaired partnered with hearing dogs, and people with physical disabilities partnered with service dogs. IAADP is the first cross-disability coalition based upon partnership with assistance dogs. Its goals are education, legislation, advocacy, and mutual support.
Intelligent Disobedience - a guide dog will not obey a command that will put its human partner in danger. For example, a guide dog will not cross the street when a car is coming and the dog will block its partner from crossing.
Seizure-response/alert Animals - alert their human partners that they are going to have a seizure before it happens. A seizure dog is trained to take its partner to a "safe" place before a seizure, get help, and protect the human partner during a seizure. These animals have access rights under the provisions of the ADA.
Service Animals - usually dogs, these animals are individually trained to perform specific tasks to assist persons with disabilities. There is no requirement for formal "certification" or "registration" of a service animal, although many training programs provide identification tags and/or certificates. Most service animals are dogs; however, other animals also may be used (e.g., potbellied pigs, monkeys, cats, and birds). These animals have access rights under the provisions of the ADA.
Social Dogs - see therapy animals.
Specialty or Combination Dogs - are trained to assist people with multiple disabilities (e.g., a person who is visually impaired and uses a wheelchair). These dogs have access rights under the provisions of the ADA.
Team, Partner or Unit - is the handler and the service dog together.
Therapy Animals - often dogs, these animals visit hospitals, care facilities, nursing homes, or provide companionship for individuals. These animals are emotionally therapeutic and have received some obedience training. These animals do not have access rights under the provisions of the ADA.
Work or Working - The team is at work or working when the animal is in harness, vest or backpack, etc.
Appendix C
Service Animal Organizations
& Training Schools
Updated January 24, 1997
This is a rapidly changing industry; new programs enter and leave the market often. Most service animal training schools and organizations are very willing to work with local transit agencies.
ASSISTANCE DOGS: NATIONAL CONTACTS
Assistance Dogs International
c/o Freedom Service Dogs, Inc.
PO Box 150217
Lakewood, CO 80215-0217
(303) 234-9512
The Assistance Dog Institute
PO Box 2334
Rohnert Park, CA 94927
(707) 585-0300
Canine Companions for Independence (CCI) National Headquarters
PO Box 466
Santa Rosa, CA 95402-0446
(800) 572-2275 V/TDD / (707) 528-0830
Delta Society National Service Dog Center
289 Perimeter Road East
Renton, WA 98055
(800) 869-6898 / (206) 235-1076 / (800) 809-2714 TDD
International Association of Assistance Dog Partners (IAADP)
PO Box 1326
Sterling Heights, MI 48311
(810) 826-3938
National Education for Assistance Dog Services (NEADS)
PO Box 213
West Boylston, MA 01583
(508) 422-9064
National Hearing Dog Center, Inc.
1116 South Main Street
Athol, MA 01331
(508) 249-9264
Paws with a Cause Corporate Office
1235 100th Street SE
Byron Center, MI 49315
(800) 253-7297 (TDD/V) / (616) 698-0688 (TDD/V)
CAPUCHIN MONKEYS
Helping Hands
Boston University School of Medicine
1505 Commonwealth Avenue
Boston, MA 02135
(617) 787-4419
GUIDE DOGS
ARIZONA
Eye Dog Foundation of Arizona
8252 South 15th Avenue
Phoenix, AZ 85041
(602) 276-0051
CALIFORNIA
Guide Dogs for the Blind, Inc.
PO Box 151200
San Rafael, CA 94915
(415) 499-4000
Guide Dogs of America
13445 Glenoaks Boulevard
Sylmar, CA 91342
(818) 362-5834
Guide Dogs of the Desert
PO Box 1692
Palm Springs, CA 92262
(619) 329-6257
CONNECTICUT
Fidelco Guide Dog Foundation
PO Box 142
Bloomfield, CT 06002
(203) 243-5200
FLORIDA
Southeastern Guide Dogs, Inc.
4210 77th Street E
Palmetto, FL 34221
(813) 729-5665
KANSAS
Kansas Specialty Dog Service, Inc.
PO Box 216
Washington, KS 66968
(913) 325-2256
MICHIGAN
Leader Dogs for the Blind
1039 S Rochester Road
Rochester, MI 48307
(810) 651-9011
NEW JERSEY
The Seeing Eye, Inc.
PO Box 375
Morristown, NJ 07963-0375
(201) 539-4425
NEW YORK
Freedom Guide Dogs
1210 Hardscrabble Road
Cassville, NY 13318
(315) 822-5132
Guide Dog Foundation for the Blind, Inc.
371 E Jericho Turnpike
Smithtown, NY 11787
(800) 548-4337 / (516) 265-2121
Guiding Eyes for the Blind, Inc.
611 Granite Springs Road
Yorktown Heights, NY 10598
(800) 942-0149 / (914) 245-4024
Upstate Guide Dog Association, Inc.
PO Box 165
Hamlin, NY 14464
(716) 964-8815
OHIO
Pilot Dogs, Inc.
625 W Town Street
Columbus, OH 43215
(614) 221-6367
HEARING & SIGNAL DOGS
ARIZONA
Handi-Dogs, Inc.
PO Box 12563
Tucson, AZ 85732
(602) 325-6466
CALIFORNIA
Canine Companions for Independence NW Regional Training Center
PO Box 446
Santa Rosa, CA 95402
(707) 577-1700
Canine Support Teams
PO Box 1329
Perris, CA 92572-1329
(909) 943-3972
San Francisco SPCA Hearing Dog Program
2500 16th Street
San Francisco, CA 94103
(415) 554-3020 / (415) 554-3022 TDD
COLORADO
American Humane Association
63 Inverness Drive E
Englewood, CO 80112
(313) 792-9900
International Hearing Dog, Inc.
5901 E. 89th Avenue
Henderson, CO 80640
(303) 287-3277
Mile High Hearing and Handi Dog, Inc.
PO Box
Parker, CO 80134
(303) 288-7297
Top Dog Rocky Mountain Region
1614 W 6th Street
Alamosa, CO 81101-2929
(719) 589-0652
CONNECTICUT
Connecticut K-9 Hearing Dog Training
239 Maple Hill Avenue
Newington, CT 06111
(203) 666-4646 / (203) 666-4648 TDD
Hearing Ear Dogs of New England Ltd.
420 Groton Long Point Road
Groton, CT 06340
(203) 446-1576
FLORIDA
Florida Dog Guides for the Deaf, Inc.
PO Box 20662
Bradenton, FL 34203-0662
(800) 520-4589 / (941) 748-8245
INDIANA
Access K-9 Co-Workers
PO Box 30142
Indianapolis, IN 46230
(317) 257-3727
Midwest Assistance Dogs, Inc.
3702 W Sample Street
South Bend, IN 46619
(219) 287-7677
MARYLAND
Canine Companions
PO Box 12142
Silver Spring, MD 20908
(301) 460-3040
Fidos for Freedom, Inc.
PO Box 5508
Laurel, MD 20726
(410) 880-4178
MASSACHUSETTS
National Education for Assistance Dog Services
PO Box 213
West Boylston, MA 01583
(508) 422-9064
National Hearing Dog Center, Inc.
1116 S Main Street
Athol, MA 01331
(508) 249-9264
MICHIGAN
Paws with a Cause Corporate Office
1235 100th Street SE
Byron Center, MI 49315
(800) 253-7297 / (616) 698-0688
MINNESOTA
Hearing and Service Dogs of Minnesota
2223 E. 35th Street
Minneapolis, MN 55407
(617) 729-5986 / (617) 729-5914 TDD
NEW YORK
Canine Companions for Independence NE Regional Center
PO Box 205
Farmingdale, NY 11735-0205
(516) 694-6938
Canine Helpers for the Handicapped Inc.
5705 Ridge Road
Lockport, NY 14094
(716) 433-4035
Canine Working Companions, Inc.
7558 Groton Lake Road
Waterville, NY 13480
(315) 861-7770
NORTH CAROLINA
Carolina Canine Companions
1609 Pembrook Road
Concord, NC 28025
(704) 455-3776
OHIO
Assistance Dogs of America, Inc.
29687 Carnoustie Court
Perrysburg, OH 43551
(419) 666-8799
Lions Hearing Dogs, Inc.
290 North Hamilton Road
Gahanna, OH 43230
(617) 471-7397
Lions Hearing Dogs, Inc.
4623 Pleasant Chapel
Newark, OH 43055
(614) 548-4447
OKLAHOMA
Dogs Ears, Inc.
4200 E. Britton Road
Oklahoma City, OK 73132
(405) 478-2303
OREGON
Dogs for the Deaf
10175 Wheeler Road
Central Point, OR 97502
(503) 826-9220
SOUTH CAROLINA
Carolina Canine Companions
1961 White Oak Road
Camden, SC 29020
(803) 432-0004
TEXAS
Texas Hearing & Service Dogs, Inc.
13422 Katy Knoll Court
Houston, TX 77082
(714) 497-2502
WISCONSIN
Okada
W 5634 Stearns Road
Fontana, WI 53125
(414) 275-5226
SERVICE (ASSISTANCE) DOGS
ARIZONA
Companion Animal Association of Arizona
PO Box 5006
Scottsdale, AZ 85261-5006
(602) 258-3306
Top Dog, Inc.
5315 East Broadway #106
Tucson, AZ 85711
(602) 747-4945
CALIFORNIA
Canine Companions for Independence NW Regional Training Center
PO Box 446
Santa Rosa, CA 95402
(707) 577-1700
Canine Companions for Independence Sacramento Satellite Office
7610 Auburn Boulevard, Suite 3
Citrus Heights, CA 95610
(916) 722-4243
Canine Companions for Independence SW Regional Training Center
PO Box 4558
Oceanside, CA 92052
(619) 754-3300
COLORADO
Canine Companions for Independence Colorado Satellite Office
1045-F Garden of the Gods Road
Colorado Springs, CO 80907
(719) 260-6151
Freedom Service Dogs, Inc.
PO Box 150217
Lakewood, CO 80215-0217
(303) 234-9512
ILLINOIS
Canine Companions for Independence Chicago Satellite Office
PO Box 847
Glenview, IL 60025
(847) 559-9346
MINNESOTA
Canine Companions for Independence Minnesota Satellite Office
Minnesota Satellite
938 Prairie Center Drive #187
Eden Prairie, MN 55344
(612) 949-3756
Helping Paws of Minnesota, Inc.
26386 112th Street
Aimmerman, MN 55398
(612) 924-2404
MISSOURI
Support Dogs, Inc.
3958 Union Road
St. Louis, MO 63125
(314) 892-2554
NEW YORK
Canine Companions for Independence NE Regional Training Center
PO Box 205
Farmingdale, NY 11735
(516) 694-6938 V/TDD
Canine Helpers for the Handicapped Inc.
5705 Ridge Road
Lockport, NY 14094
(716) 433-4035
Canine Working Companions, Inc.
7558 Groton Lake Road
Waterville, NY 13480
(315) 861-7770
NORTH CAROLINA
Nanhall Training Center
2206 Martin Luther King Drive
Greensboro, NC 27406
(910) 272-5684
People Animal Linking System (PALS)
716 Charnel Lane
Climax, NC 27406
(910) 674-9220
NORTH DAKOTA
Great Plains Assistance Dogs Foundation, Inc.
PO Box 513
Jud, ND 58454
(701) 685-2242
OHIO
Canine Companions for Independence NC Regional Training Center
4989 State Road 37 E
Delaware, OH 43015
(614) 548-4447 V/TDD
Happy Canine Helpers, Inc.
16277 Montgomery Road
Johnstown, OH 43031
(614) 965-2204
Support Dogs for the Handicapped, Inc.
PO Box 28457
Columbus, OH 43228-0457
(614) 878-2427
OKLAHOMA
TheraPetics Service Dogs of Oklahoma, Inc.
PO Box 701707
Tulsa, OK 74170-1707
(918) 827-6051
OREGON
Kings Valley Collies
39968 Ward Road
Kings Valley, OR 97361
(503) 929-2100
PENNSYLVANIA
Canine Partners for Life
#130D RD2
Cochranville, PA 19330
(610) 869-4902
Independence Dogs, Inc.
146 State Line Road
Chaddsford, PA 19317
(610) 358-2723
New Life Assistance Dogs
PO Box 564
Lancaster, PA 17602
(717) 872-2771
Susquehanna Service Dogs
555 Le Sentier
Harrisburg, PA 17112
(717) 599-5920
VIRGINIA
Caring Canine Companions, Inc.
PO Box 353
Verona, VA 24482
(540) 248-6655
Virginia Canines for Independence, Inc.
PO Box 11441
Richmond, VA 23230
(804) 288-DOGS
WASHINGTON
Prison Pet Partnership Program
Washington Correction Center for Women
PO Box 17
Gig Harbor, WA 98335-0017
(206) 858-4240
WISCONSIN
Wisconsin Academy for Graduate Service Dogs
205 North Main, Suite 103
Janesville, WI 83545-3062
(608) 757-1171
CANADIAN CONTACTS
B. C. Interact
#250 - 167 W 2nd Avenue
Vancouver, BC V5Y 1B8
(604) 879-5991
Canadian Guide Dogs for the Blind
PO Box 280
Manotick, Ontario K4M 1A3
(613) 692-7777
Canadian Guide Dogs for the Blind (B.C. Branch)
PO Box 26074
4440 Colcherster Drive
Richmond, BC V7C 4R4
(604) 241-8828
Key Companions
2148 Mango Street
Oakville, Ontario L6H 3M1
(905) 845-3593
Hearing Ear Dogs of Canada
PO Box 907
Oakville, Ontario L6J 5E8
(416) 842-7344
Lions Foundation
PO Box 907
Oakville, Ontario L6J 5E8
(095) 842-2891
Mira Foundation
1820 Rang Nord-Ouest.
Ste-Madelaine, Quebec J0H 1S0
(514) 467-7524
Pacific Assistance Dogs Society
9048 Stormont Avenue
Bernaby, BC V3N 3G6
(604) 527-0556
Powell River Therapy Dog Club
Dogwood Training Center
7372 Nootka
Powell River, BC V8A 1K6
Appendix D
Assistance Dogs International, Inc. (ADI)
All Member Programs
Minimum Standards for Training
Please note: The following information is offered as an example of training criteria; however, no there are no universally accepted minimum standards for service animal training.
Hearing Dogs
These are intended to be minimum standards for all Hearing Dog centers that want to be affiliated with ADI. All centers are encouraged to strive to work at levels above these minimums.
- A minimum of three (3) months/sixty (60) hours of training must take place at the facility with the facility's trainer. During this time, at least twenty (20) hours of regularly scheduled training must be devoted to city work, obedience, and socialization training during the dogs entire training time.
- Basic obedience skills the dogs must master with both voice and hand signals are sit, stay, come, down, heel, and off leash recall.
- Social behavior skills the dogs must master are no aggression, no nuisance barking, no biting, no snapping, or growling; no jumping on strangers, no begging, and the dog must keep his nose to himself.
- Sound awareness skills - Upon hearing a sound, the dog must make physical contact with the recipient and specifically indicate or lead the person to the source of the sound. All dogs must be trained to at least three (3) sounds.
- The placement of the Hearing Dog must last at least four (4) days/32 hours. By the end of the placement, the recipient will be able to correctly praise and discipline the dog, care for the dog, practice sound work with the dog, control the dog, and enforce obedience skills. During the placement, the trainer will go with the recipient and the dog to do city training and go to stores and a restaurant. Also, during the placement, the trainer, recipient, and dog will practice sound work and obedience every day.
- The training facility must require the recipient to complete a follow-up progress report once a month for the first six (6) months following the placement. A personal contact will be done by a staff member or qualified volunteer within twelve to eighteen (12-18) months after the placement and annually thereafter.
- Identification of the Hearing Dog and recipient will be accomplished by a laminated ID card with a picture of the dog and names of both the recipient and dog. The dog must wear its blaze orange collar and leash, approved by ADI, with Hearing Dog printed/stitched on it and a cape with the program's logo whenever in public.
- The training center must demonstrate knowledge of deafness and hearing impairment. Staff members must know basic sign language and must read at least two of the following books: DEAF LIKE ME -Thomas and James Spadley, OUTSIDERS IN A HEARING WORLD -Paul Higgins, A DEAF ADULT SPEAKS OUT - Leo M. Jacobs, A LOSS FOR WORDS - The Story of Deafness in a family, SILENT VICTORY - and NEVER THE TWAIN SHALL MEET.
- The recipient must agree to abide by the following responsibilities: Practice sound training regularly, practice obedience training regularly, maintain the dog's proper behavior in public and at home, carry proper identification, keep the dog groomed and well cared for, practice preventative health care for the dog, including annual health checks and vaccinations, keep the dog at its proper weight, abide by all leash and license laws, establish proper toileting habits for the dog and clean up after the dog, and follow the training facilities requirements for progress reports and medical reports.
- At the onset of training, every dog will be spayed or neutered and will have a thorough medical evaluation to determine that the dog does not have any physical problems that would cause difficulty for a working dog.
Service Dogs
These are intended to be minimum standards for all Service Dog centers that want to be affiliated with ADI. All centers are encouraged to strive to work at levels above the minimum.
- A minimum of six (6) months/one hundred twenty (120) hours of training must take place at the facility with the facility's trainer. During this time, at least thirty (30) hours of regularly scheduled training must be devoted to field trips and public exposure.
- Basic obedience skills the dog must master with voice and/or hand signals are sit, stay, come, down, heel, and off leash recall.
- Social behavior skills the dog must master are no aggression, no nuisance barking, no biting, no snapping, or growling; no jumping on strangers, no begging, and the dog must keep his nose to himself.
- The Service Dog must be trained to perform at least physical tasks.
- The recipient and Service Dog must be worked with by the facility's trainer for at least thirteen (13) days. This is both public and private instruction. All graduates must be given a solid education in appropriate behavior of the team. The dog should stay as invisible as possible and not interfere with people. Proper toileting habits for the dog and cleaning up after it are a must.
- The training facility must require the recipient to complete a follow-up progress report once a month for the first six (6) months following the placement. A personal contact will be done by a staff member or qualified volunteer within twelve to eighteen (12-18) months after the placement and annually thereafter.
- Identification of the Service Dog and recipient will be accomplished by a laminated ID card with a picture of the dog and names of both the recipient and dog. In public the Service Dog must wear a harness or backpack with a logo that is clear and easy to read and identifies it as a Service Dog.
- The training center must demonstrate knowledge of the handicaps in the clients it works with. Staff members must read at least two of the following books: to be added later.
- The recipient must agree to abide by the following responsibilities: Practice the dog's training regularly, practice obedience regularly, maintain the dog's proper behavior in public and at home, carry proper identification, keep the dog groomed and well cared for, practice preventative health care for the dog, including annual health checks and vaccinations, abide by all leash and license laws, and follow the training facilities requirements for progress reports and medical reports.
- At the onset of training, every dog will be spayed or neutered and will have a thorough medical evaluation to determine that the dog does not have nay physical problems that would cause difficulty for a working dog.
Appendix E
Assistance Dogs International, Inc. (ADI)
All Member Programs
Standards and Ethics
Please note: The following information is offered as an example of standards and ethics; however, no there are no universally accepted standards and ethics for service animal training.
In keeping with our purpose of helping people with disabilities achieve greater independence and/or improve the quality of their lives, the member organizations of ADI believe the following ethical criteria are essential to ensure that this mandate is reasonably and responsibly met.
- Applicants have a right to be considered to receive an Assistance Dog regardless of race, sex, religion or creed.
- Applicants, students and graduates have the right to be treated with respect and dignity at all times in their dealings with the member organization's personnel and representatives.
- The student has a right to receive a sound educational program to learn how to use his or her Assistance Dog effectively at home or in public.
- The student has a right to receive appropriate education on his or her role as a user of an Assistance dog in the community.
- The graduate has the right to receive regularly scheduled team evaluation and follow-up support programs.
- The graduate has a right to receive information on or ask for assistance in the following manner:
- Additional training for the dog that is needed due to a change in the graduate's functional level
- A behavioral management problem with the dog
- A major veterinary problem
- Legal problems pertaining to the use and access of the Assistance Dog as allowed by law
- Applicants, students and graduates have a right to expect that personal files will remain confidential and will not be disclosed unless they have given express prior permission.
- The community has a right to expect an Assistance Dog to be under control at all times and to exhibit no intrusive behavior in public.
- The community has a right to receive information concerning ADI Program Standards and Ethics.
- The community has a right to receive education on the benefits received by a person with a disability through the use of an Assistance Dog.
ADI also believes that any dog the member organizations train to become an Assistance Dog has a right to a quality life. Therefore, the only ethical use of an Assistance Dog must incorporate the following criteria.
- An Assistance Dog must be temperamentally screened for emotional soundness and working ability.
- An Assistance Dog must be physically screened for the highest degree of good health and physical soundness.
- An Assistance Dog must be technically and analytically trained for maximum control and for the specialized tasks he/she is asked to perform.
- An Assistance Dog must be permitted to learn at his/her own individual pace and not be placed in service before reaching adequate physical and emotional maturity.
- An Assistance Dog must be matched to best suit the client's needs, abilities and lifestyle.
- An Assistance Dog must be placed with a student able to interact with him/her.
- An assistance Dog must be placed with a student able to provide for the dog's emotional, physical and financial needs.
- An Assistance Dog must be placed with a student able to provide a stable and secure living environment.
- An Assistance Dog must be placed with a student who expresses a desire for independent living and/or an improvement in the quality of his/her life through the use of an Assistance Dog.
- An ADI member organization will accept responsibility for its dogs in the event of a graduate's death or incapacity to provide proper care.
Member organizations of ADI also believe that the following tenets are necessary to ensure that the member organization will continue to produce a quality product and to protect applicants, students and graduate from feeling exploited or demeaned.
- Any individual holding a major staff position, that requires specialized people/canine skills must have not only the affinity for people and excellent communications skills but also canine knowledge and experience to ensure that the member organizations will be able to maintain established standards of service to people with disabilities through their applicant/student/graduate selection, training and follow-up protocols and their canine production, selection, training and team matching methods.
- All Board members of ADI member organizations must receive orientation and be provided with appropriate educational materials about their respective programs. The materials should include but not be limited to the following:
- History of Assistance Dogs and the history of their respective programs
- ADI's established Standards and Ethics
- Board of Director functions such as funding, resource identification, solicitation and raising of funds
- Ongoing and planned Programs and Services
Appendix F
Sample Service Animal Policies
In 1996, CUTR requested copies of service animal policies from about 100 transit agencies. Some real examples are included here for discussion purposes. A critique follows each statement in italics.
Also included at the end of this section are several longer transit policies that are good examples of transit agency service animal policies.
Pets & Service Animals
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.
This is a badly worded policy. First, it only addresses "seeing eye dogs" and ignores other types of service animals. It puts pets in the same category as guide dogs. Most of the policy is aimed at what to do if there is a problem, resulting in extreme action (i.e., calling the police).
Terminology & Wording Problems
- 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.
Certification/Identification
- 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.
Combines pets and service animals in one policy. Also says there must be written assurances that animal is a service animal, which is illegal.
- 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.
Other
- 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.
This is an interesting approach of combining personal care attendants (PCAs) in the same category as service animals.
Good Statements
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.
- Two additional examples of good service animal policies begin on the next page (SamTrans and Tri-Met).
DRAFT
October 16, 1996
SERVICE ANIMAL POLICY - SAMTRANS
Service animals, such as guide dogs, may accompany persons with disabilities in the facilities of and in the vehicles operated by or for the San Mateo County Transit District, if the animal is on a lead that does not interfere with the other passengers on the bus and the animal is under the constant supervision and the control of the person with disabilities.
A service animal is 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, guiding individuals with impaired vision, alerting individuals with impaired hearing to sounds, providing minimal protection or rescue work, pulling a wheelchair, or fetching dropped items. If the operator has a doubt that the animal is a service animal, the operator may ask the customer if the animal is a service animal. If the customer says it is, the operator must allow the animal to board the bus. If the customer says it is not a service animal, the operator should tell the customer that the animal is not allowed on the bus.
While riding in a vehicle, the animal will be required to sit or stand on the floor of the bus, and may not block the aisle.
If an animal misbehaves, then the passenger will be asked to remove his or her animal from the vehicle. If there are multiple occurrences of misbehavior, the animal's riding or entry privileges may be revoked. Examples of misbehavior include unprovoked growling or attacking passengers, the bus driver, other SamTrans' employees or other service animals.
Young people from the 4-H Club raise puppies in training for Guide Dogs for the Blind. These puppies may board SamTrans buses when in their green coats and with their trainer.
Customers of Redi-Wheels are required to notify the reservationist that the animal will be accompanying them when they book their ride.
December 9, 1995
NOTICE TO OPERATORS
ASSISTANCE ANIMALS
EFFECTIVE IMMEDIATELY
All assistance animals are to be allowed on our system. We cannot require permits or other forms of proof of their being an assistance animal. Refer to Patty Nielsen's Accessible Hot Flash dated December 9, 1993, and Transportation Department's Procedures Manual, section 203.17, Assistance Animals.
Clyde A. Earl, Director of Transportation
cc: Road Operations
Dispatch
0
December 8, 1993
ACCESSIBLE HOT FLASH
by Patty Nielsen
ASSISTANCE ANIMALS
This "HOT FLASH" is an attempt to clarify a rule concerning Assistance Animals on board Tri-Met vehicles.
The Operators' Rule Book (Rule 268) states, "Bringing aboard animals, except for hearing ear dogs for the deaf; seeing eye dogs for the blind; 'Canine Companions' for the disabled (appropriate identification); and small animals fully enclosed in carrying containers;"
The Americans with Disabilities Act (ADA) (effective October 7, 1991) states, "The entity shall permit service animals to accompany individuals with disabilities in vehicles and facilities."
The following serves as clarification regarding this ADA rule: Service animals shall always be permitted to accompany their users in any private or public transportation vehicles or facility. One of the most common misunderstandings about service animals is that they are limited to being guide dogs for persons with visual impairments. 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.
Accessible Hot Flash
December 8, 1993
Page 2
Oregon State Law "Prohibits discrimination against physically disabled person who owns or is accompanied by assistance animal in access to public accommodations. Section 1. As used in this Act: (1) "Assistance animal" means any animal trained to assist a physically impaired person in one or more daily life activities, including but not limited to (a) dog guides; (b) hearing ear dogs; (c) pulling a wheelchair; (d) fetching dropped items; (e) balance work. (2) "Assistance animal trainee" means any animal undergoing training to assist a physically impaired person. (3) "Daily life activity" includes but is not limited to (a) self care; (b) ambulation; (c) communication; or (d) transportation. (4) "Mode of transportation" means any mode of transportation operating within this state.
Section 2. (1) A physically impaired person has the right to have an assistance animal with the physically impaired person, and a trainer has the right to have an assistance animal or assistance animal trainee with the trainer, in any place of public accommodation or on any mode of transportation so long as the physically impaired person or trainer controls the behavior of the animal. (4) A physically impaired person or trainer is liable for any damages done to a place of public accommodation or to any mode of transportation by the assistance animal."
On January 27, 1993, Tri-Met's Board adopted an ordinance which amended Tri-Met Code Section 28.10 and 28.15:
The following definition is added to Tri-Met Code Section 28.10:
"'Assistance animal' means a dog guide, hearing ear dog, and any service animal trained to assist a disabled person in one or more daily life activities including, but not limited to, pulling a wheelchair, fetching, and balance work.
Section 28.15.E of the Tri-Met Code is amended as follows:
"Animals: No person shall bring or carry aboard a District Vehicle any animal not housed in an enclosed carrying container, except that a disabled person, or a person training an assistance animal, may bring or carry aboard an assistance animal, so long as the disabled person or trainer controls the behavior of the animal.
Accessible Hot Flash
December 8, 1993
Page 3
When the Operators' Rule Book is reprinted, Rule 268 will reflect the above Tri-Met Code language. To provide you with further assistance in understanding this ordinance, Tri-Met's legal counsel offers the following:
Assistance animal identification will not always be available. The ADA or Oregon State Law fails to provide guidance on how to identify an assistance animal.
Tri-Met has determined that it is appropriate for personnel to specifically inquire with the disabled individual whether the animal is an "assistance animal". Animals accompanied for personal security do not qualify as assistance animals. Consequently, such guard animals must be in an enclosed container.
Finally, whether the animal's behavior is under control by the disabled individual or trainer shall be determined on a case by case basis. If the animal's behavior is obviously out of control, the operator may in his/her judgment based upon passenger safety refuse to allow the animal to board the bus. Keep in mind, the disabled individual or trainer is liable for any damages done by the assistance animal.
Bottom line, if the customer is a person with a disability and says their animals is an assistance animal, and they have the animal under control, there should be no further debate -- the customer and their assistance animal should be welcomed aboard your vehicle.
I hope this lengthy explanation alleviates any further misunderstandings between you and your customers regarding assistance animals.
Appendix G
Sample Driver & Client Directions
SAMPLE #1
Driver Instructions
for Loading and Unloading a Client and Assistance Dog
(Canine Companions for Independence, Inc. (CCI))
Please note: these are driver instructions prepared by Canine Companions for Independence (CCI). Other organizations may provide different instructions to their clients. The best advice is to ask whether the person needs assistance and how he or she would like to board and alight from the transit vehicle.
Loading
When you arrive to pick up the client, open the door and lower the lift. The client will then let go of the dog's leash and instruct the dog to jump into the vehicle. The dog will wait inside the vehicle. The client will get on the lift and be loaded as normal. Once the client is loaded, he or she will pick up and hold the dog's leash.
Unloading
The client will drop the leash and tell the dog to wait in the vehicle. The client will be unloaded as normal. When the client is off of the lift, he or she will call the dog, and instruct the dog to jump out of the vehicle and come directly to him or her. The client will then pick up and hold the leash.
Drivers
- Please do not pet or talk to the dog; this distracts the dog from its work.
- Do not give the dog any commands unless the client specifically asks you to.
- Do not take the dog's leash unless the client specifically asks you to.
- Some clients may ask you to pick up the end of the dog's leash and hand it to them if they are having difficulty picking up the leash.
What you should do when you meet an assistance dog team in public.
Make eye contact and greet the person first. It is very tempting for dog lovers to greet the dog first.
- Always ask if you can pet the dog. Do not be offended if the person requests that you do not pet the dog.
- If you are speaking to someone who uses a wheelchair for more than a brief conversation, sit or kneel down, and face him or her.
What you should expect when you see an assistance dog team in public.
- The dog will be well groomed and odor free.
- The dog will not shake, scratch or groom itself excessively in public.
- The dog will be quiet and not whine, bark or growl.
- The dog will always be within 12 inches of the owner's leg or chair. The dog will be parallel with the person and not block walkways with body, tail or feet.
- The dog will not initiate contact with someone without the owner's direct permission. The dog will not sniff people, store shelves, restaurant tables or the belongings of others.
- The dog will only toilet on command in appropriate areas outdoors.
SAMPLE #2
Transit Procedures
(The Assistance Dog Institute)
Please note: these are sample transit procedures for persons traveling with service animals, prepared by The Assistance Dog Institute. Other organizations may provide different instructions to their clients. The best advice is to ask whether the person needs assistance and how he or she would like to board and alight from the transit vehicle.
Loading:
With the bus stopped at the loading site, the bus operator is to advise passengers on the bus that a wheelchair passenger accompanied by a service dog is about to board. The operator should request that passengers seated on the two front inward facing seats relocate temporarily to the rear of the bus.
Passengers using wheelchairs should board the bus ahead of other passengers waiting at the bus stop. The operator is to extend the wheelchair lift to street level. The service dog at the command of its owner then jumps aboard the bus and stays at the top of the stairs for its master. Drivers and passengers alike are to be discouraged from talking to or petting the dog unless assistance is requested from the dog's master.
The wheelchair passenger is to back his/her chair onto the lift at street level. Prior to raising the lift, the operator should verbally check to insure that the wheelchair brakes have been set and the person is ready. As the lift begins to rise, it is advisable for the operator to inform the wheelchair passenger if his dog moves from its assigned spot since the passenger may not be able to see his/her dog.
The lift is raised to bus level. At this time, the operator is to ask if he may assist in maneuvering the wheelchair down the aisle to the stowage position.
The owner is to take hold of the service dog and the dog is to back up behind the wheelchair to the stowage position. OR if there is room on the bus the owner can reposition the dog in front of the wheelchair and the dog will follow the owner to the stowage position. Once this maneuver is completed, the wheelchair may be guided down the aisle of the bust to the stowage position.
The wheelchair is to be locked in the securing clamps. Regardless of whether the operator's help is accepted while maneuvering the wheelchair to the stowage position, the operator is to check that the security clamps are engaged. At this time the operator is also to request that the wheelchair passenger utilize the seat belt provided, and if necessary assist in fastening the seat belt. The passenger should be encouraged by the operator to instruct hi/her dog to lie or sit as far out of the aisle of the bus as possible.
Discharging:
The passenger who uses the wheelchair should notify the operator that his/her stop is ahead.
While extending the wheelchair lift to bus level, the operator should request that passengers seated on the two front inward facing seats relocate temporarily to the rear of the bus.
While releasing the wheelchair from the security clamps, the operator is to ask if he/she may assist in maneuvering the wheelchair down the aisle and onto the lift. The service dog should, on its owner's orders, accompany the wheelchair to the top of the stairs, and stay there until the wheelchair is unloaded.
The lift is lowered to street level, whereupon the wheelchair passenger will maneuver off the lift. The service dog is to remain at the top of the stairs until called. The wheelchair passenger should immediately clear the lift and turn to face the dog and call the dog. Once the passenger and/or dog are clear of the lift, the operator is to return the lift to the "steps" position.
Always thank the operator!
Appendix H
Resources
Related Books & Articles of Interest
Donahue, Connie
1996 Training Drivers to Work with Service Animals. Kansas TransReporter, October 1996:8-9.
Drastura, Jenny
1994 Delta Society Bonds People, Animals, Nature. Dog World (November 1994):46-48.
Eames, Ed
1994 From Academic to Advocate. Anthropology of Work Newsletter 15(2&3):30-31.
Eames, Ed and Toni Eames
1994 Partners in Independence. Dog World 79(4):29-30.
1995a Partners in Independence. Dog World 80(2):74-78.
1995b Partners in Independence. Dog World 80(5):50-52.
Flemming, Jim
1996 Transit Personnel Trained in Role of Service Animals. Passenger Transport 54(12):9.
Gold, Gerald
1994 Caretakers in a Miniaturized World: Encounters Between Para-transit Drivers and a Disabled Anthropologist. Anthropology of Work Newsletter 15(2&3):19-21.
Harrington, Paula
1990 Looking Ahead: Guide Dogs for the Blind. San Rafael, CA: Guide Dogs for the Blind.
Medford, Eleanor M.
1992 Bringing Up Baby. Dog World 77(2):36-39.
Pfaffenberger, Clarence J.
1963 The New Knowledge of Dog Behavior. New York: Howell Book House.
Pfaffenberger, Clarence J. et al.
1976 Guide Dogs for the Blind: Their Selection, Development, and Training. Amsterdam, NY: Elsevier Scientific Publishing Company.
Pflaumer, Sharon
1992 Seizure-alert Dogs. Dog World 77(1):42-43.
Roche, Michael P.
1994 Legal Rights of Guide Dogs, Hearing Dogs and Service Dogs. Lakewood, CO: Assistance Dogs International.
Rutenberg, Uwe and Tom Geehan
1994 Provisions for Service Animals on Regulated Carriers. Montreal, Quebec: Transportation Development Centre.
Shaw, Fran Pennock
1994 Guide Dogs Open Road to Independence. Dog World (November 1992):40-44.
Stiverson, Carla and Norm Pritchett
1996 Assistance Dog Providers in the United States. Fairview, NC: N.C. Service Dogs.
TD Safety & Access Report
1995 Pig Travels as Service Animal on NYCTA Bus. TD Safety & Access Report 3(7):4-5.
Uslan, Mark M., Alec F. Peck, William R. Wiener, and Arlene Stern, eds.
1990 Access to Mass Transit for Blind and Visually Impaired Travelers. New York: American Foundation for the Blind.
E-mail/Internet Resources
Internet/E-mail Addresses:
Here are a few of the many E-mail and Internet addresses that may be of interest. New ones are continually being added.
- Canine Companions for Independence
http://www.caninecompanions.org/
info@caninecompanions.org
- Delta Society National Service Dog Center
http://www.petsforum.com/deltasociety/
deltasociety@cis.compuserve.com
- Guide Dog Foundation for the Blind
http://www.guidedog.org/gdfb.htm
- Leader Dogs http://www.leaderdog.org
- The Seeing Eye, Inc. http://www.seeingeye.org
semaster@seeingeye.org
- Southeastern Guide Dogs, Inc.
http://www.guidedogs.org/
Other E-mail Resources:
- The quickest way to find information on the World Wide Web is by asking your browser to search for "service dog," "dog guide," or "guide dog." You will find updated lists of assistance animal training schools, frequently asked questions, etc.
- Service dog discussion group. This discussion group is primarily made up of persons who have or train service dogs. Among the topics of discussion is the issue of certification for service dogs. To subscribe to this discussion group send an E-mail to:
majordomo@acpub.duke.edu
With no subject line make your first text line read:
subscribe service-dogs
Videos
Several videos have been produced by service animal training centers. Most focus on how service dogs are raised and trained, and include promotional information about the sponsoring program. No videos were found that dealt primarily with the issue of transporting service animals; however, Tri-Met in Portland, Oregon, includes a brief spot on passengers traveling with service animals in its driver training video.
- "ADA Operator Video" (10:23 minutes) produced by Tri-Met, 4012 SE 17th, Portland, OR 97202.
- "Courage" (10:30 minutes) produced by Southeastern Guide Dogs, Inc., 4210 77th Street East, Palmetto, FL 34221 (Tel. 813-729-5665).
- "Harnessing Freedom" (22:00 minutes) produced by The Seeing Eye, PO Box 375, Morristown, NJ 07063 (Tel. 201-539-4425).
- "Heart of a Hero" (12:00 minutes) produced by Canine Companions for Independence, PO Box 446, Santa Rosa, CA 95422 (Tel. 707-528-0830).
- "Partners" (20:39 minutes) produced by The Seeing Eye, PO Box 375, Morristown, NJ 07063 (Tel. 201-539-4425).
- "Service Dogs Welcome!" (15:00 minutes) produced by Delta Society Service Dog Center, 289 Perimeter Road East, Renton, WA 98055 (Tel. 800-869-6898 / 800-809-2714 (TDD)).
- "Yaz: The Beginning of Independence" (10:40 minutes) produced by Southeastern Guide Dogs, Inc., 4210 77th Street East, Palmetto, FL 34221 (Tel. 813-729-5665).
Other Resources
- The National Information Center on Deafness at Gallaudet University publishes a fact sheet on hearing ear dogs. The cost is $1.00. NICD, Gallaudet University, 800 Florida Avenue NE, Washington, DC 20002.
- U.S. Department of Justice ADA Information Line may be reached by calling 800-514-0301 (voice) or 800-514-0383 (TDD).
