American Airlines will require all passengers traveling with emotional support animals and psychiatric service animals to provide documentation of proof of health or vaccinations a minimum of 48 hours in advance of the departure of a flight effective as of Sunday, July 1, 2018, according to this article which was released yesterday.

American Airlines Adopts Stricter Requirements for Emotional Support Animals

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In developing the updated requirements, American Airlines consulted with its disability advisory board and disability advocacy groups and organizations — such as My Blind Spot, Incorporated — to ensure that the expanded policy accommodates guests with disabilities. This initiative is all while remaining in compliance with the Air Carrier Access Act.

For new flight reservations which are booked on or after Sunday, July 1, 2018, passengers who travel with emotional support and psychiatric service animals must submit three completed documents via e-mail message or fax to American Airlines:

1. Mental Health Professional Form — Currently required, this is a letter issued by a mental health professional or medical doctor approving the use of an emotional support and psychiatric service animals.
2. Animal Behavior Guidelines Form — A signed affidavit affirming the emotional support or psychiatric service animal is trained to behave in public and that the owner accepts all liability for any injuries or damage to property.
3. Animal Sanitation Form — For flights greater than eight hours in duration, documentation is required stating that your animal will not need to relieve itself or can do so in a way that does not create a health or sanitation issue.

A Trend in the Commercial Aviation Industry

American Airlines follows the lead of Delta Air Lines — and then United Airlines and Alaska Airlines — in being prompted to to strengthen its policies pertaining to passengers who travel with emotional support animals.

Although most animals do not cause problems, the changes were derived by American Airlines to ensure a safe environment for all passengers and were developed based on a number of recent incidents over the most recent few years during which the inappropriate behavior of emotional support animals has impacted and even injured employees, other passengers and legitimate service animals, as caused by what is described as a steady increase in incidents from animals who have not been adequately trained to behave in a busy airport setting or aboard an airplane.

The changes do not apply to the policy of American Airlines pertaining to traditional service animals.

Owners and handlers are required to keep animals traveling with them under their control at all times; and all animals must behave well in a public setting.

Passengers with tickets purchased after Sunday, July 1, 2018 who do not submit the required documentation a minimum of 48 hours in advance will be offered to fly with their pet under existing policies for travel in the cabin or in the temperature-controlled cargo compartment. Existing fleet and breed restrictions — as well as health certificate requirements — will apply.

Animals Which are Not Permitted to Travel on American Airlines

American Airlines does not accept the following exotic or unusual animals to be misidentified as emotional support animals or psychiatric service animals:

• Amphibians
• Hedgehogs
• Ferrets
• Goats
• Insects
• Reptiles
• Rodents
• Snakes
• Spiders
• Sugar gliders
• Non-household birds — farm poultry, waterfowl, game birds, and birds of prey
• Animals which are improperly cleaned and/or has an odor
• Animals with tusks, horns, or hooves — except miniature horses that are trained to behave appropriately

A Reminder of the Definitions of Service Dogs and Emotional Support Animals

The official definition of a service animal — according to the Disability Rights Section of the Civil Rights Division of the Department of Justice of the United States pertaining to the Americans with Disabilities Act, or ADA — is as follows:

Service animals are defined as dogs that are individually trained to do work or perform tasks for people with disabilities. Examples of such work or tasks include guiding people who are blind, alerting people who are deaf, pulling a wheelchair, alerting and protecting a person who is having a seizure, reminding a person with mental illness to take prescribed medications, calming a person with Post Traumatic Stress Disorder (PTSD) during an anxiety attack, or performing other duties. Service animals are working animals, not pets. The work or task a dog has been trained to provide must be directly related to the person’s disability. Dogs whose sole function is to provide comfort or emotional support do not qualify as service animals under the ADA.

This definition does not affect or limit the broader definition of “assistance animal” under the Fair Housing Act or the broader definition of “service animal” under the Air Carrier Access Act.

Some State and local laws also define service animal more broadly than the ADA does. Information about such laws can be obtained from the State attorney general’s office.

Additionally, service animals must be harnessed, leashed, or tethered — unless these devices interfere with the intended work of the service animal or the disability of the individual prevents using these devices. In that case, the individual must maintain control of the animal through voice, signal, or other effective controls.

An emotional support animal is a companion animal which provides therapeutic benefit to an individual designated with a disability — such as depression, bipolar disorder, panic attacks or anxiety as only a few of many examples. While only dogs — and, in a separate provision which need not be discussed here, miniature horses — can be officially designated as service animals, emotional support animals can also be cats and other animals as prescribed by a physician or other medical professional if the owner of the animal has a verifiable disability in accordance with federal law of the United States.

In order to prevent discrimination by commercial airlines — based both within and outside of the United States — against passengers on the basis of physical or mental disability, the Air Carrier Access Act was passed by the Congress of the United States in 1986; and here are where complaints may be registered against an airline via the official Internet web site of the Aviation Consumer Protection and Enforcement division of the Department of Transportation of the United States.

Employees of airlines are limited by law to the questions they are permitted to ask owners of animals brought aboard airplanes. Only two questions may be asked by employees of an airline — or of any other company, for that matter pertaining to service animals…

1. Is the dog a service animal required because of a disability?
2. What work or task has the dog been trained to perform?

…and when the service an animal provides is not obvious, an employee of an airline or other company cannot do the following actions without violating federal law:

• Ask about the nature of the disability of the person
• Require medical documentation
• Require a special identification card or training documentation for the dog; or
• Ask that the dog demonstrate its ability to perform the work or task

Official Policies of Airlines in the United States

A commercial airline is permitted to require a passenger traveling with an emotional support animal provide written documentation that the animal is an emotional support animal — unlike for a service animal. A fee does not apply to service animals of passengers with disabilities — not even on airlines such as Spirit Airlines and Allegiant Air, which are known for their proliferation of ancillary fees.

Here is a list of airlines with links to their official policies pertaining to animals:

• Air Canada
• Alaska Airlines
• Allegiant Air
• American Airlines
• Delta Air Lines
• Frontier Airlines
• Hawaiian Airlines
• JetBlue Airways
• Southwest Airlines
• Spirit Airlines
• Sun Country Airlines
• United Airlines

Inside Take

What American Airlines, Alaska Airlines, United Airlines and Delta Air Lines are implementing can be considered a step in the right direction; but although the new requirements may mitigate the number of passengers who attempt to cheat the system — which is not fair to passengers who have legitimate service dogs or emotional support animals — the effort will not be enough to eliminate them, as those passengers who are determined to fraudulently pass their pets as legitimate service dogs or emotional support animals will continue to do so to save money.

Photograph ©2006 by B. Cohen.