Updated to Include the DOT’s Latest Rules for 2021 and Beyond

In this post we will provide a comprehensive guide of everything you need to know in order to travel with your service dog or psychiatric service dog (PSD). You may have heard that the U.S. Department of Transportation (DOT) recently issued a major overhaul of the rules governing assistance animals on planes. We’ll go over those rules in depth and summarize what you need to know as a service dog or PSD handler, including the new paperwork requirements. 

Under the DOT’s new rules, airlines are no longer obligated to recognize emotional support animals (ESAs) as assistance animals. That means starting on January 11th, 2021, airlines are no longer obligated to accommodate ESAs. 

The good news for service dog and PSD owners is that their canine companions remain protected, with some caveats. Service dogs are still allowed to accompany their handlers in the airplane cabin free of charge. The DOT however has radically changed the procedures for how airlines process service dogs.

So even if you’re an experienced service dog owner who has flown for years with your dog, you’ll want to read this guide. This guide is also perfect for those new to flying with a service animal and need to know all the relevant information. We’ll answer common questions like who is eligible to fly with a service dog, what the new paperwork requirements are and where to order a certification, license or ID. We’ll also share some practical insights for dealing with flights and airports from experienced service dog owners. 

Table of Contents:

What does the DOT consider to be a service animal? What does it mean to have a “disability”? What kinds of tasks do service dogs and psychiatric service dogs perform?  Does a service dog or PSD need to be professionally trained or certified by an organization? How can an airline verify that I have a service animal? What forms do I have to submit in order to fly with my service dog? Does my service dog need to have a harness, vest or ID card? How big can my service dog be in order to fly with me? Can an airline deny my service dog because it is a certain breed?  Can I bring aboard more than one service dog? What rules apply to my service dog during the flight? When is an airline allowed to deny boarding to a service animal? What are some other practical tips for flying with a service dog?  Is there anything else I should keep in mind?  What does the DOT consider to be a service animal?

First, let’s cover the basics. What does the DOT now consider a service animal that is eligible for special accommodation on flights? The DOT has revised their definition of service animal so it aligns more closely with the definition under the Americans with Disabilities Act (ADA). 

A service animal for purposes of air travel is a dog, regardless of what breed it is, that is individually trained to do work or perform tasks for someone with a disability, including psychiatric and mental disabilities. 

“Service animal” does not cover emotional support animals, or animals other than dogs. That is unfortunate news for owners of service animals like capuchin monkeys or miniature horses, but the DOT felt that dogs were the most appropriate service animals for the interior of an airplane cabin. 

The key difference between a service dog and a normal pet or other type of assistance animal is that a service dog must be trained to perform tasks related to the handler’s disability. That means even a service dog in training is not considered a full-fledged service dog until it has completed its training.

If you are looking to register your service animal and are ready to order an identification card for your Service Dog, click on the button below.

What does it mean to have a “disability”?

A service dog brought on board a plane must be trained to assist with a “disability”. The term “disability” has a specific legal meaning under the DOT’s rules and the Air Carrier Access Act (ACAA). A disability means a physical or mental impairment that, on a temporary or permanent basis, substantially limits one or more major life activities. “Major life activities” are things like working, sleeping, learning and other essential life activities. 

The definition of disability covers both physical impairments (for example, someone that has limited mobility or has sight impairment) and mental impairments. “Mental impairments” include emotional or mental illnesses and specific learning disabilities. The DOT’s new rules also specifically mention “psychiatric, intellectual or other mental” disabilities. Psychiatric service dogs are commonly used by people with conditions like severe depression, anxiety, PTSD, phobias and autism. 

It’s important to note that even though emotional support animals are no longer recognized as assistance animals for flights, PSD owners are still protected. Remember however that there is a crucial distinction between ESAs and PSDs: a psychiatric service dog must be trained to perform tasks. ESAs on the other hand provide support just through their presence.

What kinds of tasks do service dogs and psychiatric service dogs perform? 

Service dogs perform a wide array of tasks and it would be impossible to present an exhaustive list here. There is no official list of eligible tasks. The key criteria is that the service dog must be specifically trained to perform the task to assist the owner with their disability. 

For individuals with physical disabilities, service dogs perform tasks such as:

Pulling a wheelchair.  Guiding the visually impaired.  Guiding the hearing impaired.  Alerting the owner of an oncoming seizure.  Alerting the owner of a rise or drop in blood sugar levels.  Providing stability while going up and down stairs or other hazardous areas.  Retrieving items.  Opening and closing doors and drawers.  Pressing buttons (such as in an elevator).  Carrying bags and other objects. 

For individuals with psychiatric disabilities, psychiatric service dogs are known to perform tasks such as:

Interrupting panic/anxiety attacks.  Using pressure and tactile stimulation to calm the handler.  Reminding the owner to take their medication.  Preventing behaviors like scratching.  Grounding and reorienting the handler during a panic or anxiety attack. Acting as a physical buffer in crowded areas.  Waking up the handler to prevent oversleeping.  Interrupting repetitive behaviors. 

A dog does not qualify as a service animal until it has fully completed its training. In addition, it’s important to keep in mind that a proper service animal should also be obedient and trained to be comfortable in public settings. Airplanes and airports are crowded, hectic areas with a lot of potential distractions. A service dog should be able to focus on the handler and their duties even in potentially stressful environments. As we’ll discuss in detail later, an airline can reject a service dog if it is misbehaving or engaging in certain disruptive actions. 

Does a service dog or PSD need to be professionally trained or certified by an organization?

A certified service dog does not need to be trained a third party trainer, school or organization. These services may be useful, especially for novice dog owners, but the DOT notes that “service animal users are free to train their own dogs to perform a task or function for them”. That is good news for people who have the ability to train their service dogs, but not the financial means to afford a professional trainer or help from an organization. A service dog does not need to be certified by an organization that it has completed its training. 

How can an airline verify that I have a service animal?

The DOT gives airlines three methods to use in determining whether someone is travelling with a true service animal. In addition, as we’ll discuss in the next section, airlines can request that service dog owners fill out a new form created by the DOT that has to be submitted in advance of the flight. 

These are the three ways the airline’s staff can verify your canine companion is a service dog:

1. Asking whether the animal is required to accompany the passenger because of a disability and what work or task the animal has been trained to perform.

It’s important to note here that service dog owners have a right to a certain degree of privacy. Airline staff cannot make specific inquiries about your disability, or ask that you have your service dog demonstrate the task it has been trained for.

2. Observing the behavior of the animal. 

Airline staff can observe the general behavior of the service dog to see whether it remains under the control of its handler. A service dog can be barred from a flight if it is out of control, barking or growling repeatedly at other passengers or animals, biting, jumping on or causing injury to others, or urinating or defecating in the cabin or gate area. 

According to the DOT, a dog that engages in these types of disruptive actions demonstrates that it has not been successfully trained to behave in public settings. In such cases, the airline can deny boarding even if the service dog can otherwise perform the tasks relating to the handler’s disability. 

3. Looking at physical indicators such as harnesses and vests.

Lastly, an airline can look at physical indicators such as harnesses, vests, ID cards and tags to weigh whether the dog is a service dog. Paraphernalia such as tags, vests, ID cards, certificates and harnesses are frequently used by service dog owners to signal to members of the public that their service dog is on duty.

These types of accessories are especially helpful for psychiatric service dog owners because their disabilities are invisible and not readily apparent. Having these accessories helps protect service dog owners from intrusive inquiries and unwanted interactions. 

It’s important to note however that service animal paraphernalia is not, solely by itself, enough to qualify a dog as a service dog. It’s just one factor the DOT says airlines can use to help determine whether they are dealing with an authentic service dog or not. 

If you are looking to register your Service Dog so you that you have a Service Dog ID card for your own personal convenience at the airport, you may order one below.

What forms do I have to submit in order to fly with my service dog?

Perhaps the biggest change in how service dogs will be accommodated on flights is the newly created DOT forms. Airlines starting on January 11th, 2021 can require that all service dog owners complete and submit the DOT’s “Service Animal Transportation Form” (the “Transport Form”). This form has to be submitted at least 48 hours before departure (or, if the reservation is made within 48 hours of the flight, be submitted before the flight or at the gate). 

In the Transport Form, the service dog or psychiatric service dog handler has to make the following certifications: 

The service dog or PSD has been individually trained to do work or perform tasks for the benefit of the passenger with a disability; The service dog has been trained to behave properly in public;  The handler is aware that the service dog must be under their control at all times; The handler is aware that if their service dog misbehaves in a way that indicates it has not been properly trained, then the airline can treat the service dog as a normal pet; and  The handler is aware that they may be liable for damage caused by their service dog’s actions.

The handler must also certify that their service dog has been vaccinated. The form asks for a veterinarian’s name and contact, but does not require the vet’s signature. The form is self-certifying, meaning that the handler is personally responsible for making all of the attestations and signing the form. 

The DOT’s form will be used for all airlines, which eliminates the confusion that occurred in the past when each airline utilized their own special form for assistance animal accommodations. A copy of the DOT Transport Form for reference can be found below. 

 

U.S. Department of Transportation Service Animal Air Transportation Form

In addition to the Transport Form, the DOT is also requiring a separate form for flights longer than 8 hours called the “Service Animal Relief Attestation Form” (“Relief Form”). In the Relief Form, the handler must certify that their service dog will either (i) not need to relieve itself while on the flight, (ii) can relieve itself during the flight without creating a health or sanitation issue or (iii) refrain from relieving itself, or relieve itself without posing a health or sanitation issue (for example, through the use of a dog diaper). Like the Transport Form, this form is also self-certifying, but only required for flights that are longer than 8 hours. A copy of the Relief Form for reference can be found below. 

U.S. Department of Transportation Service Animal Relief Attestation Form Does my service dog need to have a harness, vest or ID card?

The DOT allows airline staff to look at paraphernalia such as harnesses, vests and tags to determine whether an animal is a service dog. These items are popular with service dog owners because they distinguish their working animals from normal pets. They may help with managing uncomfortable interactions with the public and staff members, and also can prevent pesky inquiries about why the dog is present. These accessories can be especially helpful for PSD owners whose disabilities are unseen. 

As a reminder however, these items alone cannot qualify a service dog and are for fully trained service dogs. Airlines can weigh the presence of service dog paraphernalia along with other factors to determine whether a dog is indeed a service dog. 

As a practical matter, service dog owners find these accessories especially helpful in areas that are crowded with unfamiliar people, such as airports and plane cabins. 

How big can my service dog be in order to fly with me?

Many service dogs are larger breeds such as Golden Retrievers or German Shepherds. There is no categorical weight limit for service dogs, but airlines can require that a service animal fit within the handler’s foot space or on the passenger’s lap. The DOT’s new rules require airlines to accommodate larger animals by moving them to another seat location within the same service class where the animal can be accommodated, if possible (such as if there is a seat next to an empty seat). 

If there is nowhere to place a larger service dog comfortably however, the airline is required to offer the handler the opportunity to transport the service dog in the cargo hold free of charge or travel on a later flight if there is space available in the cabin for that flight. Many service dog owners would be vehemently opposed to letting their dog fly in cargo however. Fortunately, many larger service dogs can still be trained to fit into the passenger’s foot space on an airplane. 

Can an airline deny my service dog because it is a certain breed? 

Under the DOT’s new rules, an airline cannot prohibit a service dog solely because it is a certain breed. The DOT recognizes that all types of dogs can serve as effective service dogs and disallows airlines from stereotyping certain breeds, such as Pitbulls. As we’ll discuss in a later section however, the airline can still prohibit boarding if the service dog is acting aggressively or being disruptive. 

Can I bring aboard more than one service dog?

Some handlers have multiple service dogs, each of which fulfill a different but important job relating to their disability. Under the DOT’s new guidelines, airlines can limit the number of service dogs a handler can bring onboard to two. The handler will also need to be able to comfortably accommodate both of the service dogs in their foot space or lap. 

For handlers with two large service dogs, they may want to consider taking additional steps to ensure their service dogs can be accommodated. For example, on a flight likely to be full without an empty seat, the handler may want to consider purchasing an additional seat or taking a less popular flight. Otherwise, they risk the chance they may have to relegate their service dog to cargo which is a non-starter for many service dog owners. 

What rules apply to my service dog during the flight?

During the flight, the airline can require the service dog be harnessed, leashed or tethered at all times, even if such items would interfere with the service animal’s work or the passenger’s disability prevents the use of these items. This is a much more stringent approach than the ADA which allows for a disabled person to use voice commands or other signals where appropriate. 

Service dog owners should come prepared for flights with a harness, leash or tether and anticipate that their service dog will have to be restrained during the flight and at the airport gate. 

In addition, as previously noted, all service dogs must be well-behaved during the flight and not create any significant disruptions. That means no barking, jumping on others, acting aggressively or defecating/urinating in the open. 

If the service dog causes any damage to the airplane cabin, the owner is responsible for the damages (that is, if the airline typically would charge a non-disabled passenger for those same damages). 

When is an airline allowed to deny boarding to a service animal?

There are four primary situations where an airline can justifiably deny boarding for a service animal:

The service animal poses a direct threat to the health or safety of others. 

Airlines must make an “individualized assessment” of the service dog in question. They can’t rely for example on stereotypes regarding a service dog’s breed. The airline also has to consider whether any mitigating measures can be taken – for example, the use of a muzzle to silence a barking service dog. 

The service dog causes a significant disruption or its actions indicate it hasn’t been trained properly to be in public. 

An airline can view a service dog as not having been properly trained if the service dog is running freely, barking or growling repeatedly at others, biting or jumping on people or urinating or defecating in the open. 

The transportation of the service dog would violate safety or health requirements of a foreign government. 

For international flights, it’s important to make sure you understand what the foreign country’s rules are for the arrival of service dogs. For example, some countries may require information regarding the service dog’s health and vaccination status. 

The passenger has not completed the DOT’s Transport Form or Relief Form. 

As previously discussed, service dog owners will need to submit the DOT’s Transport Form and, for longer flights, the Relief Form, prior to boarding the flight. 

If an airline refuses to accommodate your service dog for any reason, they must provide a written statement to you describing those reasons within 10 days. 

What are some other practical tips for flying with a service dog? 

The first time flying with your service dog or PSD can be a harrowing and intimidating experience. But fear not, thousands of service dog owners travel every day without incident and federal rules protect your rights. 

These are some practical tips and precautions to keep in mind to help ensure you have a smooth trip:

Tip #1: If necessary, visit your vet before your travel date to make sure your dog is healthy and up-to-date on vaccinations. The DOT’s Transport Form will require you to certify your service dog is vaccinated and will also ask for your vet’s contact information.  

Tip #2: Vests, tags, ID cards, harnesses and other accessories can help you navigate a busy airport and crowded airplane cabin. Remember, service dog paraphernalia is just one way an airline can determine whether an animal is a service animal, but it’s not dispositive. 

Tip #3: Try to avoid overfeeding your service dog prior to a flight as they could suffer from air sickness which can lead to an unpleasant accident during the flight. 

Tip #4: Let your airline know about your service dog and submit the DOT’s Transport Form as soon as possible. 

Tip #5: For first timers, arriving at the airport a few hours early can ease some of the anxiety, especially if there are unexpected obstacles like a long security line or changed gates. Many airports also have stations where your service dog can have an opportunity to relieve itself one last time before boarding. 

Tip #6: Remember to bring a harness, leash or tether – the airline can insist that your service dog is properly restrained and under your control at all times. 

Tip #7: Remember to pack all your pet’s grooming products, necessary medication, food, treats, water and food dishes in appropriately accessible compartments. 

Is there anything else I should keep in mind? 

The DOT’s new rules go into effect on January 11th, 2021, and there will likely be an adjustment period as airlines revise their old policies. It’s important to know the rules we have discussed in this guide, but you should also contact the airline you’re flying with to ensure you’re clear on their policies and have submitted you paperwork to their satisfaction. When it comes to successfully flying with a service dog or PSD, preparedness is the key!

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