Government tries to clarify rules for emotional support animals on flights

September 4, 2019
Brendan Howard, Business Channel Director

Brendan Howard oversees veterinary business, practice management and life-balance content for, dvm360 magazine, Firstline and Vetted, and plans the Practice Management track at all three Fetch dvm360 conferences.Brendan has proudly served under the Veterinary Economics and dvm360 banners for more than 10 years. Before that, he worked as a journalist, writer and editor at Entrepreneur magazine and a top filmed entertainment magazine in Southern California. Brendan received a Masters in English Literature from University of California, Riverside, in 1999.

dvm360, dvm360 October 2019, Volume 50, Issue 10

Department of Transportation offers guidance on what it will and wont enforce when it comes to dogs (or cats, or horses, or snakes) traveling with emotionally fragile airline passengers.

When it comes to emotional support animals on airplanes, there has been confusion, strong emotion and much suspicion that passengers are taking advantage of government policies in the last few years. In response, the U.S. Department of Transportation (DOT) has provided guidance on how it will enforce existing regulations concerning air travel, disabilities and animals in airplane cabins.

Patients flying?

Whether they're service animals or pets, your patients deserve some attention before a flight on an airplane. Educate clients with this handout.


Here are some basic takeaways from the DOT's document, “Guidance on Nondiscrimination on the Basis of Disability in Air Travel,” which reflects the agency's thinking after reading roughly 4,500 public comments and considering current policies. This information could be helpful for your veterinary clients as they contemplate flying with emotional support animals. This is what the DOT has told airlines it will and will not enforce:

  • Exotic species can be acceptable emotional support animals. Airlines can deny transport only to “certain unusual species” of service animals-snakes, other reptiles, ferrets, rodents and spiders. The DOT may take “enforcement action” on a case-by-case basis against airlines that fail to transport other species as service animals but will primarily focus on ensuring that dogs, cats and miniature horses-the most common ones-are accepted for transport.

  • Passengers can be required to take extra steps. The DOT says airlines can require passengers with psychiatric service animals (PSAs) or emotional support animals (ESAs)-but not traditional service animals-to do the following: 1) provide the airline advance notice of intention to travel with the animal, 2) appear in person in the airport lobby to verify that an animal can be transported safely, and 3) check in one hour earlier than the general public. Airlines cannot force passengers to use airline-specific medical forms and letters or require medical professionals to fill them out; any valid form or letter will do.

  • Health and safety must be documented-within reason. To verify that an animal is safe to fly, the DOT says airlines can require passengers with ESAs and PSAs to present documentation 48 hours before a flight showing proof of vaccinations, training or behavior. A number of forms created by airlines, however, are unacceptable-for example, one requiring a veterinarian to guarantee that an animal will behave. The DOT says certain airlines' bans of “pit bull type dogs” are also prohibited, but “airlines are permitted to find that any specific animal, regardless of breed, poses a direct threat based on behavior.”

  • Containment of an animal must be reasonable. The DOT says it will consider appropriate ways to leash, restrain, tether and carry service animals on a case-by-case basis, with a focus on “reasonableness.” Factors include size and species of animal, other passengers' foot space and the continuing ability of an animal to provide emotional support to the passenger.

  • Three's the magic number. The DOT says it will focus on ensuring that airlines allow passengers to travel with one emotional support animal (ESA) and as many as three service animals total. Airlines have complained about the number of allowed animals, but the DOT counters that “if 10 qualified individuals with a disability each need to bring an ESA, then … the airline must accept all 10 ESAs, so long as the ESAs are sufficiently trained to behave in a public setting.”

The DOT also considered other, newer policies by airlines, and found these to be enforceable:

  • Animals must be older than 4 months (younger animals are unlikely to be properly trained).

  • Animals may not be uniformly restricted by weight (animals should be judged on a case-by-case basis).

  • Animals may be allowed on flights longer than eight hours (as long as they won't need to relieve themselves or can do so a sanitary way).

These guidelines, the DOT says, explain how the agency will or will not enforce current laws, rules and policies and does not constitute a guarantee that its guidance won't change in the future.

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