...............and ensuring that, in situations concerning
emotional support animals, the authority of
airline personnel to require documentation of
the individual’s disability and the medical
necessity of the passenger traveling with the
animal is understood.
Today, both the general public and people
with disabilities use many different terms to
identify animals that can meet the legal
definition of ‘‘service animal.’’ These range
from umbrella terms such as ‘‘assistance
animal’’ to specific labels such as ‘‘hearing,’’
‘‘signal,’’ ‘‘seizure alert,’’ ‘‘psychiatric
service,’’ ‘‘emotional support’’ animal, etc.
that describe how the animal assists a person
with a disability.
When Part 382 was promulgated, most
service animals were guide or hearing dogs.
Since then, a wider variety of animals (e.g.,
cats, monkeys, etc.) have been individually
trained to assist people with disabilities.
Service animals also perform a much wider
variety of functions than ever before (e.g.,
alerting a person with epilepsy of imminent
seizure onset, pulling a wheelchair, assisting
persons with mobility impairments with
balance). These developments can make it
difficult for airline employees to distinguish
service animals from pets, especially when a
passenger does not appear to be disabled, or
the animal has no obvious indicators that it
is a service animal. Passengers may claim
that their animals are service animals at
times to get around airline policies that
restrict the carriage of pets. Clear guidelines
are needed to assist airline personnel and
people with disabilities in knowing what to
expect and what to do when these
assessments are made.
Since airlines also are obliged to provide
all accommodations in accordance with FAA
safety regulations (see section 382.3(d)),
educated consumers help assure that airlines
provide accommodations consistent with the
carriers’ safety duties and responsibilities.
Educated consumers also assist the airline in
providing them the services they want,
including accommodations, as quickly and
efficiently as possible.
General Requirements of Part 382
In a nutshell, the main requirements of Part
382 regarding service animals are:
• Carriers shall permit dogs and other
service animals used by persons with
disabilities to accompany the persons on a
flight. See section 382.55(a)(1–2).
—Carriers shall accept as evidence that an
animal is a service animal identifiers such as
identification cards, other written
documentation, presence of harnesses, tags or
the credible verbal assurances of a qualified
individual with a disability using the animal.
—Carriers shall permit a service animal to
accompany a qualified individual with a
disability in any seat in which the person
sits, unless the animal obstructs an aisle or
other area that must remain unobstructed in
order to facilitate an emergency evacuation or
to comply with FAA regulations.
• If a service animal cannot be
accommodated at the seat location of the
qualified individual with a disability whom
the animal is accompanying, the carrier shall
offer the passenger the opportunity to move
with the animal to a seat location in the same
class of service, if present on the aircraft,
where the animal can be accommodated, as
an alternative to requiring that the animal
travel in the cargo hold (see section
• Carriers shall not impose charges for
providing facilities, equipment, or services
that are required by this part to be provided
to qualified individuals with a disability (see
Two Steps for Airline Personnel
To determine whether an animal is a
service animal and should be allowed to
accompany its user in the cabin, airline
1. Establish whether the animal is a pet or
a service animal, and whether the passenger
is a qualified individual with a disability;
2. Determine if the service animal presents
• a ‘‘direct threat to the health or safety of
• a significant threat of disruption to the
airline service in the cabin (i.e. a
‘‘fundamental alteration’’ to passenger
service). See 382.7(c).
How Do I Know It’s a Service Animal and
Not a Pet?
Remember: In most situations the key is
TRAINING. Generally, a service animal is
individually trained to perform functions to
assist the passenger who is a qualified
individual with a disability. In a few
extremely limited situations, an animal such.....................
Somewhere, there's a retired airline employee hoping to rehabilitate her psyche with the help of the support python she is training.