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Photograph ©2013 by Brian Cohen.
Brian Cohen·
Health and Environment
··2 Comments·8 min read

Stricter Requirements for Emotional Support Animals By United Airlines

United Airlines will require all passengers traveling with 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.

Stricter Requirements for Emotional Support Animals By United Airlines

In developing the updated requirements, United Airlines solicited the feedback and input of members of its Accessible Travel Advisory Board, customers; flight attendants; pilots; employees with disabilities; and organizations representing passengers with disabilities to ensure that its revised policy continues to provide safe, reliable and accessible transportation for all passengers — particularly those with disabilities — while remaining in compliance with the Air Carrier Access Act.

Customers traveling with service animals and emotional support animals must contact the Accessibility Desk of United Airlines 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.

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.

Passengers who are traveling with 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 Accessibility Desk of United Airlines via United.com at least 48 hours in advance of travel.

The policy pertaining to passengers traveling with service animals remains unchanged, as no documentation is required — other than for foreign travel if required by national law.

“Year-over-year, we have seen a 75 percent increase in customers bringing emotional support animals onboard and as a result have experienced a significant increase in onboard incidents involving these animals”, according to this article posted at United Hub. “We understand that other carriers are seeing similar trends. The Department of Transportation’s rules regarding emotional support animals are not working as they were intended to, prompting us to change our approach in order to ensure a safe and pleasant travel experience for all of our customers.”

Animals Which are Not Permitted to Travel on United Airlines

United Airlines 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
  • Exotic animals
  • Non-household birds — such as farm poultry, waterfowl, game bird, and birds of prey
  • Animals not properly cleaned and/or with a foul odor

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.

See also

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

Summary

“Expect other airlines to eventually follow the lead of Delta Air Lines and implement similar policies” is what I wrote in this article pertaining to similarly stricter requirements for emotional support animals by Delta Air Lines on Friday, January 19, 2018 — but one difference is that service dogs are also included in the updated policy with Delta Air Lines; whereas the policy for service dogs remains unchanged with United Airlines. Look for American Airlines — and possibly other airlines — to release a similar updated policy in the coming weeks.

I believe that what United Airlines and Delta Air Lines are 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.

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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