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Photograph ©2013 by Brian Cohen.
Brian Cohen·
Health and Environment
··1 Comment·9 min read

Enhancements Added to Stricter Requirements for Emotional Support Animals and Service Dogs By Delta Air Lines

Since an announcement was released last month that Delta Air Lines will require all passengers traveling with service dogs, psychiatric service animals or emotional support animals to provide documentation of proof of health or vaccinations 48 hours in advance of the departure of a flight effective as of Tuesday, March 1, 2018, the airline has added enhancements to the stricter requirements.

Enhancements Added to Stricter Requirements for Emotional Support Animals and Service Dogs By Delta Air Lines

In developing the updated requirements — which must be in compliance with the Air Carrier Access Act — Delta Air Lines solicited the feedback and input of its Advisory Board on Disability, which is a group comprised of 15 disability advocates established greater than ten years ago and composed of diverse frequent fliers of Delta Air Lines with a range of disabilities.

As a measure to prevent untrained and sometimes aggressive household pets from traveling without a kennel in the cabin, passengers traveling with psychiatric service animals and emotional support animals will also need to provide a signed document confirming that their animals can behave during a flight. This is in addition to the current requirement of providing a letter which was prepared and signed by a doctor or licensed mental health professional.

Delta Air Lines will create a Service Animal Support Desk for customers traveling with service animals and emotional support animals to verify that the required documentation is received and confirm the reservation of the customer to travel with the animal prior to arrival at the airport. If the required form has not been completed, a representative will communicate with the customer via e-mail message to request the missing or incomplete items.

With the recent enhancements highlighted in dark red type, passengers who are traveling with:

  • A trained service animal will be required to submit a signed Veterinary Health Form and/or an immunization record — current within one year of the travel date — for their animal to the Service Animal Support Desk of Delta Air Lines via Delta.com at least 48 hours in advance of travel; and these customers can check-in via Delta.com, the Fly Delta mobile software application program, airport kiosks, or with an airport agent.
  • An emotional support animal or psychiatric service animal will be required to submit a signed Veterinary Health Form and/or an immunization record — current within one year of the travel date — an Emotional Support/Psychiatric Service Animal Request form which requires a letter prepared and signed by a doctor or licensed mental health professional, and a signed Confirmation of Animal Training form to Service Animal Support Desk of Delta Air Lines via Delta.com at least 48 hours in advance of travel; and these customers must use the full-service check-in process with an airport agent.

“Rise in Serious Incidents Involving Animals in Flight”

An emotional support dog — which was described as “possibly a lab mix weighing about 50 pounds” — was accused of biting a passenger and causing serious injury prior to departure aboard an airplane which operated as Delta Air Lines flight 1430 from Atlanta to San Diego back in June of 2017. The passenger was so seriously injured — blood covered his face, eyes, cheeks, nose, mouth and shirt — that he had to leave the airplane to receive medical attention in the form of 28 stitches; and will likely suffer permanent scarring as a result of the reportedly unprovoked attack.

“The rise in serious incidents involving animals in flight leads us to believe that the lack of regulation in both health and training screening for these animals is creating unsafe conditions across U.S. air travel,” John Laughter — who is the senior vice president of corporate safety, security and compliance for Delta Air Lines — said in this article from Delta News Hub. “We have received extensive customer feedback through calls, emails and social posts — many from among those within the disability community — urging Delta to take action. This new policy is our first step in better protecting those who fly with Delta with a more thoughtful screening process.”

According to the aforementioned article, with the greater than 180 million passengers Delta Air Lines carries annually, the airline also carries almost 250,000 service animals or support animals — which averages approximately 700 carried every day — and has also seen reported incidents involving animals increase by 84 percent since 2016, which includes urination and defecation by animals aboard airplanes. “Ignoring the true intent of existing rules governing the transport of service and support animals can be a disservice to customers who have real and documented needs.”

Additionally, employees of Delta Air Lines have reported increased acts of aggression — such as barking, growling, lunging and biting — from supposed service and support animals, which is a key indicator that they were more likely pets being transported free of charge by their owners and not properly trained and working as intended.

Animals Which are Not Permitted to Travel on Delta Air Lines

Delta Air Lines no longer accepts pets as checked baggage effective as of Tuesday, March 1, 2016 to protect animals from dangerous conditions from being in the cargo hold; but pets can still be shipped via Delta Cargo.

Delta Air Lines does not accept the following exotic or unusual animals to be misidentified as emotional support animals or psychiatric service animals:

  • Hedgehogs
  • Ferrets
  • Insects
  • Rodents
  • Snakes
  • Spiders
  • Sugar gliders
  • Reptiles
  • Amphibians
  • Goats
  • Non-household birds — such as farm poultry, waterfowl, game bird, and birds of prey
  • Animals improperly cleaned and/or with a foul odor
  • Animals with tusks, horns or hooves

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.

See also

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:

Summary

I believe that what Delta Air Lines is implementing is 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.

Expect other airlines to eventually follow the lead of Delta Air Lines and implement similar policies — if they have not already done so — as well as with similar enhancements.

I have written extensively over the years pertaining to service dogs and emotional support animals in the form of articles posted here at The Gate — including:

Photograph ©2013 by Brian Cohen.

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