CONGRATS TO TAYLOR AND “TUCKER”

CONGRATULATIONS TO CLIENT TAYLOR AND NOW SERVICE DOG, HEELER MIX “TUCKER”!!! THEY PASSED THE PUBLIC ACCESS TEST!!!

Taylor suffers from severe depression and agoraphobia.

Trainer Letty writes:

“I can’t stress how far this team has come! When we started, I looked at this team as a true challenge. Tucker was extremely hyperactive, and Taylor had almost no control of him. He ate through more than one leash and had a few accidents while training in public. Taylor really worked hard to turn things around with Tucker. She trained tirelessly on not only his basics but on all aspects of his Service Dog training. I am extremely proud of this amazing Service Dog team.”

SCORING OF THE PUBLIC ACCESS CERTIFICATION TEST Always=All the time
Mostly=Most of the time (more than half of time) Sometimes=Some of the time (half or less of the time) Never=Never demonstrated the skill
The team must score all ‘Always’ or’ Mostly’ ’ responses on the A-M-S-N parts of the test.
The team must score at least 80% “YES” answers on the “YES” “NO” portion of the test.
All questions marked by an asterisk (*) must be answered by a “YES” response.

CONTROLLED UNLOAD OUT OF VEHICLE:

Tucker did not try to leave vehicle until given release command.

Tucker waited in the vehicle until released.* Yes
Tucker waited outside the vehicle under control. Yes
Tucker remained under control while another dog was walked. Yes

APPROACHING THE BUILDING:

Relative heel position, not straining or forging.

Tucker stayed in relative heel position. Always
Tucker was calm around traffic.* Yes
Tucker stopped when Taylor came to a halt. Always

CONTROLLED ENTRY THROUGH A DOORWAY

Tucker waited quietly at the door until commanded to enter.* Yes Tucker waited on the inside until able to return to heel position.* Yes

HEELING THROUGH THE BUILDING

Tucker was within the prescribed distance of Taylor. Always Tucker ignored the public, remaining focused on Taylor. Always Tucker readily adjusted to speed changes. Always
Tucker readily turned corners–did not have to be tugged or jerked to change direction. Always
Tucker readily maneuvered through tight quarters. Always

SIX FOOT RECALL ON LEAD

Tucker responded readily to the recall command–did not stray away, seek attention from others, or trudge slowly.* Yes
Tucker remained under control and focused on Taylor.* Yes
Tucker came within the prescribed distance of Taylor.* Yes
Tucker came directly to Taylor.* Yes

SITS ON COMMAND

Tucker responded promptly to the command to sit. Always
Tucker remained under control around food–not trying to get food and not needing repeated corrections.* Yes
Tucker remained composed while the shopping cart passed–did not shy away, show signs of fear, etc.* Yes
Tucker maintained a sit-stay while being petted by a stranger.* Yes

DOWNS ON COMMAND

Tucker responded promptly to the command to down. Always
Tucker remained under control around the food–not trying to get food and not needing repeated corrections.* Yes
Tucker remained in control while the child approached – child should not taunt Tucker or be overly dramatic.* Yes

NOISE DISTRACTIONS

If Tucker jumps, turns, or shows a quick startle type reaction, that is fine. Tucker should not show fear, aggression, or continue to be affected by the noise.

Tucker remained composed during the noise distraction.* Yes

RESTAURANT

Tucker is unobtrusive and out of the way of patrons and employees as much as possible.* Yes
Tucker maintained proper behavior, ignoring food and being quiet.* Yes

OFF LEAD

When told to drop the leash, the team maintained control and Taylor got the leash back in position.* Yes

DOG TAKEN BY ANOTHER PERSON

Another person can take Tucker’s leash and Taylor can move away without aggression or undue stress on the part of Tucker.* Yes

CONTROLLED EXIT

Tucker stayed in relative heel position. Always
Tucker was calm around traffic.* Yes
Tucker stopped when Taylor came to a halt. Always

CONTROLLED LOAD INTO VEHICLE

Tucker waited until commanded to enter the vehicle. Yes
Tucker readily entered the vehicle upon command. Yes

TEAM RELATIONSHIP

When Tucker did well, Taylor praised Tucker. Always
Tucker is relaxed, confident, and friendly. Always
Taylor kept Tucker under control. Always
Taylor was prepared with proper working materials and equipment in case of an access confrontation (laws, etc.). Yes

PASS TEST: Yes

CONGRATS TO WOUNDED WARRIOR STEVE AND “ELLIE”

CONGRATULATIONS TO WOUNDED WARRIOR (NAVY) STEVE AND HIS NOW SERVICE DOG, GREAT DANE “ELLIE”!!!!!!!!!! THEY PASSED THEIR PUBLIC ACCESS TEST – AND ELLIE IS AN OFFICIAL RED CROSS THERAPY DOG, AS WELL!!!!!!!!!!!!!!!!

Steve suffers from PTSD, Bipolar Disorder, anxiety, panic attacks, depression, and night terrors – but not much anymore since he’s had ELLIE!!

Laurie writes:

“What can I say? Service Dog Ellie is an absolutely perfect, on-point, sharp as a tack, loving Great Dane. Her relationship with her handler, Steve, is unbelievable. There is nothing this team can’t do! Ellie is truly a model Service Dog, and she brings so much joy to Steve and his whole family! Ellie does many extra tasks like “covers”, “deep pressure therapy”, waking Steve up from night terrors, and she goes from room to room checking on each member of the house before she lies down! Ellie had also earned her Red Cross patch, and accompanies Steve to disaster relief areas, where she provides therapy for those in distress! She is on her way to her third trip for flood victims, where she is treated like a queen at the places they stay! Here are pictures of Ellie on her first Amtrak train ride!

SCORING OF THE PUBLIC ACCESS CERTIFICATION TEST
Always=All the time
Mostly=Most of the time (more than half of time)
Sometimes=Some of the time (half or less of the time)
Never=Never demonstrated the skill
The team must score all ‘Always’ or’ Mostly’ ’ responses on the A-M-S-N parts of the test.
The team must score at least 80% “YES” answers on the “YES” “NO” portion of the test.
All questions marked by an asterisk (*) must be answered by a “YES” response.

CONTROLLED UNLOAD OUT OF VEHICLE:

Ellie did not try to leave vehicle until given release command.

Ellie waited in the vehicle until released.* Yes
Ellie waited outside the vehicle under control. Yes
Ellie remained under control while another dog was walked. Yes

APPROACHING THE BUILDING:

Relative heel position, not straining or forging.

Ellie stayed in relative heel position. Always
Ellie was calm around traffic.* Yes
Ellie stopped when Steven came to a halt. Always

CONTROLLED ENTRY THROUGH A DOORWAY

Ellie waited quietly at the door until commanded to enter.* Yes
Ellie waited on the inside until able to return to heel position.* Yes

HEELING THROUGH THE BUILDING

Ellie was within the prescribed distance of Steven. Always
Ellie ignored the public, remaining focused on Steven. Always
Ellie readily adjusted to speed changes. Always
Ellie readily turned corners–did not have to be tugged or jerked to change direction. Always
Ellie readily maneuvered through tight quarters. Always

SIX FOOT RECALL ON LEAD

Ellie responded readily to the recall command–did not stray away, seek attention from others, or trudge slowly.* Yes
Ellie remained under control and focused on Steven.* Yes
Ellie came within the prescribed distance of Steven.* Yes
Ellie came directly to Steven.* Yes

SITS ON COMMAND

Ellie responded promptly to the command to sit. Always
Ellie remained under control around food–not trying to get food and not needing repeated corrections.* Yes
Ellie remained composed while the shopping cart passed–did not shy away, show signs of fear, etc.* Yes
Ellie maintained a sit-stay while being petted by a stranger.* Yes

DOWNS ON COMMAND

Ellie responded promptly to the command to down. Always
Ellie remained under control around the food–not trying to get food and not needing repeated corrections.* Yes
Ellie remained in control while the child approached – child should not taunt Ellie or be overly dramatic.* Yes

NOISE DISTRACTIONS

If Ellie jumps, turns, or shows a quick startle type reaction, that is fine. Ellie should not show fear, aggression, or continue to be affected by the noise.

Ellie remained composed during the noise distraction.* Yes

RESTAURANT

Ellie is unobtrusive and out of the way of patrons and employees as much as possible.* Yes
Ellie maintained proper behavior, ignoring food and being quiet.* Yes

OFF LEAD

When told to drop the leash, the team maintained control and Steven got the leash back in position.* Yes

DOG TAKEN BY ANOTHER PERSON

Another person can take Ellie’s leash and Steven can move away without aggression or undue stress on the part of Ellie.* Yes

CONTROLLED EXIT

Ellie stayed in relative heel position. Always
Ellie was calm around traffic.* Yes
Ellie stopped when Steven came to a halt. Always

CONTROLLED LOAD INTO VEHICLE

Ellie waited until commanded to enter the vehicle. Yes
Ellie readily entered the vehicle upon command. Yes

TEAM RELATIONSHIP

When Ellie did well, Steven praised Ellie. Always
Ellie is relaxed, confident, and friendly. Always
Steven kept Ellie under control. Always
Steven was prepared with proper working materials and equipment in case of an access confrontation (laws, etc.). Yes

PASS TEST: Yes – 110%

CONGRATS TO KALIE AND GRACIE

CONGRATULATIONS TO CLIENT KALIE AND HER NOW SERVICE DOG, LABRADOODLE, “GRACIE”! THEY PASSED THEIR PUBLIC ACCESS TEST!!!!

San Antonio Trainer Pat writes:

Gracie is about 14 months now, knows what the phrase “She’s SOOOO CUTE” means, and has calmed down nicely over the time I have been working with her and Kalie. While she is still an energetic adolescent, she knows that her job is to watch over Kalie. She alerts to Kalie before she has a seizure and responds with intense focus when it happens. Kalie has a reliable companion as she moves forward into her college years.

SCORING OF THE PUBLIC ACCESS CERTIFICATION TEST
Always=All the time
Mostly=Most of the time (more than half of time)
Sometimes=Some of the time (half or less of the time)
Never=Never demonstrated the skill
The team must score all ‘Always’ or’ Mostly’ ’ responses on the A-M-S-N parts of the test.
The team must score at least 80% “YES” answers on the “YES” “NO” portion of the test.
All questions marked by an asterisk (*) must be answered by a “YES” response.

CONTROLLED UNLOAD OUT OF VEHICLE:

Gracie did not try to leave vehicle until given release command.

Gracie waited in the vehicle until released.* Yes
Gracie waited outside the vehicle under control. Yes
Gracie remained under control while another dog was walked. Yes

APPROACHING THE BUILDING:

Relative heel position, not straining or forging.

Gracie stayed in relative heel position. Always
Gracie was calm around traffic.* Yes
Gracie stopped when Kalie came to a halt. Always

CONTROLLED ENTRY THROUGH A DOORWAY

Gracie waited quietly at the door until commanded to enter.* Yes
Gracie waited on the inside until able to return to heel position.* Yes

HEELING THROUGH THE BUILDING

Gracie was within the prescribed distance of Kalie. Always
Gracie ignored the public, remaining focused on Kalie. Mostly
Gracie readily adjusted to speed changes. Always
Gracie readily turned corners–did not have to be tugged or jerked to change direction. Always
Gracie readily maneuvered through tight quarters. Always

SIX FOOT RECALL ON LEAD

Gracie responded readily to the recall command–did not stray away, seek attention from others, or trudge slowly.* Yes
Gracie remained under control and focused on Kalie.* Yes
Gracie came within the prescribed distance of Kalie.* Yes
Gracie came directly to Kalie.* Yes

SITS ON COMMAND

Gracie responded promptly to the command to sit. Mostly
Gracie remained under control around food–not trying to get food and not needing repeated corrections.* Yes
Gracie remained composed while the shopping cart passed–did not shy away, show signs of fear, etc.* Yes
Gracie maintained a sit-stay while being petted by a stranger.* No

DOWNS ON COMMAND

Gracie responded promptly to the command to down. Mostly
Gracie remained under control around the food–not trying to get food and not needing repeated corrections.* Yes
Gracie remained in control while the child approached – child should not taunt Gracie or be overly dramatic.* No

NOISE DISTRACTIONS

If Gracie jumps, turns, or shows a quick startle type reaction, that is fine. Gracie should not show fear, aggression, or continue to be affected by the noise.

Gracie remained composed during the noise distraction.* Yes

RESTAURANT

Gracie is unobtrusive and out of the way of patrons and employees as much as possible.* Yes
Gracie maintained proper behavior, ignoring food and being quiet.* Yes

OFF LEAD

When told to drop the leash, the team maintained control and Kalie got the leash back in position.* Yes

DOG TAKEN BY ANOTHER PERSON

Another person can take Gracie’s leash and Kalie can move away without aggression or undue stress on the part of Gracie.* Yes

CONTROLLED EXIT

Gracie stayed in relative heel position. Always
Gracie was calm around traffic.* Yes
Gracie stopped when Kalie came to a halt. Always

CONTROLLED LOAD INTO VEHICLE

Gracie waited until commanded to enter the vehicle. Yes
Gracie readily entered the vehicle upon command. Yes

TEAM RELATIONSHIP

When Gracie did well, Kalie praised Gracie. Always
Gracie is relaxed, confident, and friendly. Mostly
Kalie kept Gracie under control. Always
Kalie was prepared with proper working materials and equipment in case of an access confrontation (laws, etc.). Yes

PASS TEST: YES

Trans Depart Gets Specific about Service Animal Relief Areas in Airports

Transportation Department Gets Specific about Service Animal Relief Areas in Airports

On August 5, 2015, the Department of Transportation published a final rule in the Federal Register regarding service animal relief areas (SARAs) in airports, requiring that most airports have one such area for each terminal and generally inside the sterile section of the terminal. The requirements of the final rules were described here in a prior blog.

The Department has now issued a draft of an Advisory Circular “designed to assist airports in complying with the laws and regulations regarding individuals with disabilities,” which includes a set of standards for SARAs. The draft Circular, AC 150/5360-14A, which will cancel and replace a prior Circular that was issued on June 30, 1999, adds significant granularity to the relief area requirements.

Before making the proposed draft final, the Department “invites interested persons, airport operators, guide dog trainers and handlers, consultants, industry representatives, and all other interested parties to review and comment on the draft.” Comments may be submitted until June 6 on the regulations.gov website. The specific reference to “guide dog trainers and handlers” may not be an atavistic throwback to the days when most service dogs were guide dogs, but may reflect the Department’s express interest in issues of particular importance to individuals who use guide dogs:

The FAA is also aware that it may be difficult for people with visual impairments to navigate within the SARA. To allow these people to familiarize themselves with the SARA’s layout before entering, the AC recommends placing special signs, maps, and other orienting cues at the entrance to the SARA. In addition, this AC defines the airport terminal for the purpose of helping airports decide on the number and locations of required SARA. To enhance SARAs, the FAA is seeking input on new concept cleaning technology; like nano technology as a potential for self-cleaning SARA.

The draft Circular deserves the attention of the service animal community, particularly when an airport wishes to place a SARA outside of the sterile area of a terminal. The draft states that when this is the case, the airport must obtain the agreement of a service animal training organization. Also, “the airport must … document and retain a record of this agreement, including when TSA prohibits location of the SARA in a sterile area.”

Proposed Standards for Service Animal Relief Areas

The draft SARA Standards in the Circular, printed in full in the Appendix at the end of this blog, provide that a relief area “must be located on an accessible route to each terminal.” Although 49 CFR 27.71(2) specifies that there must be “at least one relief area in each airport terminal,” the draft provides that “[o]ne relief area may serve two or more terminals if travel to and from it meets reasonable transit times…,” which means that the “transit time from any gate to a relief area is no more than 15 minutes, based on a walking pace of 200 ft/min,” with “expected time using transportation vehicles and waiting time for an escort, wheelchair, or elevators” being included in total transit time.

Relief areas “must be designed to accommodate a person using a wheelchair handling a service animal on a six-foot leash.” In 1991, the Department issued Accessibility Guidelines for Buildings and Facilities that included diagrams indicating such things as turning space needed for wheelchairs, from which the diagram shown here is taken.

The draft provides that in “busier locations, a relief area may be sized to accommodate more than one service animal at one time.” Presumably in smaller airports, therefore, relief areas may be so small as to only accommodate one animal at a time. Nevertheless that space would have to be large enough for a wheelchair user to enter and turn around.

Two Surfaces Required in Each Relief Area

A relief area is to have “at least two surfaces.” The draft elaborates:

One [surface] should be hard and located immediately inside the entrance to allow wheelchair access. This surface should be delineated in a manner to indicate the portion intended to be traversed by people, and the portion intended for animal relief. The other should be an appropriate softer surface, such as gravel or mulch for outdoor areas, and artificial turf specially designed as an animal relief surface, treated to inhibit the spread of disease, for indoor (and outdoor) areas. Other artificial turf is not recommended, as it harbors odors and bacteria. Consider that artificial turf is often perceived as carpet by service animals, making them reluctant to use it. Avoid surfaces such as sand that will stick to paws and be tracked outside the SARA. When using mulch, be sure it is not of a species that can be harmful to animals. Dark colored surfaces should not be used where exposed to the sun, as they can become unbearably hot.

Fencing may be necessary, particularly for SARAs outside of buildings, which will often mean outside of sterile areas. Nevertheless, the draft suggests that outdoor locations are preferred because “some animals are trained not to relieve indoors.” Also, strong chemicals are often used to clean indoor relief areas, and some dogs may consequently balk at entering them. (Veronica Morris makes the interesting observation that “before 9/11, it was common for individuals with service animals to be allowed to go onto the tarmac from the gate and potty their animals on the tarmac or on nearby patches of grass, which actually worked out pretty well.”)

SARAs cannot be co-located with a designated smoking area. Apparently the Department feared that some airports would try to combine troublesome smells by putting smoke and dog poop near each other.

Water Sources and Fake Fire Hydrants

A SARA “must include a sink and a faucet for hand washing,” with potable water as users can be expected to fill water bowls in the SARA. The SARA must have a separate water source for cleaning and must have adequate drainage so that water used in cleaning can run off.  A SARA must include something like a rock or fake fire hydrant “to encourage urination by male dogs.” There must also be poop bags and a receptacle for them, and these must be placed so that wheelchair users can get to them. A sign should indicate that users should clean up after their animals (though as already noted the request for comments raised the possibility of self-cleaning SARAs).

The airport must have signage and maps indicating where SARAs are located. “Braille signing must be installed adjacent to the side of doors and gates opposite the hinges.” Airports are encouraged “to adopt state-of-the-art technology (e.g., smart phone applications) as it becomes available.”

Tweaking the Definition of Service Animal

Throughout the Federal Register 2015 release on service animal relief areas no definition of service animals was provided, and I did not think at the time that any definition was particularly needed. It could be assumed that someone at an airport who would be using a SARA would have a service animal that was going to enter the cabin of an airliner (as an animal going into a pressurized and heated hold would have been checked before the passenger entered the sterile area). Also, the Department acknowledged that pets and TSA dogs would be using SARAs along with service dogs:

The final rule also offers the benefits of improved convenience to nondisabled persons accompanied by an animal or pet while at the airport. Although these benefits are not encompassed by the rule’s purpose, individuals traveling with pets or security dogs trained to detect security threats may also find it convenient to use service animal relief areas located in the secure area of the airport.

Nevertheless, the draft Circular now provides a definition of service animal:

Service Animal.

Any guide dog, signal dog, or other animal individually trained to do work or perform tasks for the benefit of an individual with a disability, including, but not limited to, guiding individuals with impaired vision, alerting individuals with impaired hearing to intruders or sounds, providing minimal protection or rescue work, providing emotional support, pulling a wheelchair, or fetching dropped items. (49 CFR § 37.3)

One would expect from the parenthetical at the end of the definition that it follows 49 CFR 37.3 word for word. It does not. The regulation does not contain the italicized phrase, “providing emotional support.” The 1999 Circular that is being replaced had used the exact definition from 49 CFR 37.3, i.e., without that phrase.

The reference to emotional support appears to have been inserted by the drafters of the proposed Circular not from 49 CFR at all but rather the Air Carrier Access Act releases of the Department. For instance, in policy guidance issued in 2003, a service animal was defined, for purposes of assisting airline employees in determining whether an animal qualifies, as “[a]ny animal that is individually trained or able to provide assistance to a qualified person with a disability; or any animal shown by documentation to be necessary for the emotional well being of a passenger.” (68 Fed. Reg. 24878, May 9, 2003) In that definition, however, and generally in the Department’s ACAA guidance, there is no presumption that emotional support requires training.

The phrase is, in any case, inconsistent with the approach of the Department of Justice, which provides in its basic definition in 28 CFR 36.104 that “the provision of emotional support [does] not constitute work or tasks for the purposes of this definition.” The definition in 49 CFR 37.3 was not original with the Department of Transportation, which adopted it in September 1991 (56 Fed. Reg. 45624, September 6, 1991), but rather was the definition of service animal in the first ADA regulations issued by the Department of Justice in July 1991 (56 Fed. Reg. 35544, July 26, 1991), a definition that for DOJ was superseded in 2010. Thus by adding the emotional support phrase to a now outdated DOJ definition, the draft Circular has created an illogical hybrid that requires training but allows providing emotional support as sufficient to qualify an animal as a service animal.

Miniature Horses

This effort by the drafters of the proposed Circular to modify the definition of service animal presents another problem, though this one may be temporary. The problem comes from a footnote to the tweaked definition, which states the following:

A public entity shall make reasonable modifications in policies, practices, or procedures to permit the use of a miniature horse by an individual with a disability if the miniature horse has been individually trained to do work or perform tasks for the benefit of the individual with a disability. (28 CFR § 35.136).

Thus, the Department would acknowledge, as did the Department of Justice in 2010, that a miniature horse may, much like a dog, fulfill service animal functions, particularly as a guide (28 CFR 36.302(c)(9), as finalized by DOJ in 75 Fed. Reg. 56236, September 15, 2010).

The Department of Transportation indicated as far back as 2011 that it might have to consider revising its definition of service animal in light of the revisions made by the Department of Justice in 2010, saying that the “Department will consider whether, in the future, to propose changes to part 37 to parallel the new DOJ definitions. Meanwhile, the existing DOT definitions continue in effect.” (76 Fed. Reg. 57924, September 19, 2011) That may be changing, however.

Neither of the Department of Transportation’s definitions of service animal has a species limitation—either the one in the 2003 ACAA guidance or the one in 49 CFR 37.3.  Referring to miniature horses as an exception only makes logical sense if the Department of Transportation has a species limitation on service animals, which it does not. In issuing its 1991 rule defining service animals, DOT specifically stated that “[o]ther animals (e.g. monkeys) are sometimes used as service animals as well…. the entity must permit the service animal to accompany its user.” The Department accepts that not all service animals need to be admitted to an airplane cabin, however, and stated the following in 2008:

[T]he Department has added language to the final rule specifying that carriers need never permit certain creatures (e.g., rodents or reptiles) to travel as service animals. For others (e.g., miniature horses, pot-bellied pigs, monkeys), a U.S. carrier could make a judgment call about whether any factors (e.g., size and weight of the animal, any direct threat to the health and safety of others, significant disruption of cabin service) would preclude carrying the animal. Absent such factors, the carrier would have to allow the animal to accompany its owner on the flight. (73 Fed. Reg. 27636, May 13, 2008)

The reason any confusion here may be temporary is that the Department of Transportation has begun a process of revising its service animal airplane access rules, and the possibility of conforming its rules to those of the Department of Justice is clearly on the table. The Department of Transportation’s initiative with regard to service animal access has been discussed extensively in several blogs on this site. Thus, as with the Department of Justice, the Department of Transportation may be moving towards recognizing only dogs, and perhaps miniature horses, as service animals and the footnote reference to miniature horses may be an indication of where the Department expects its revision process to go in this regard.

Meanwhile, however, the occasional monkey, pot-bellied pig, or miniature horse may, if trained to do so, make use of a SARA.

Conclusions

No specific mechanism is provided for service animal organizations to engage with airports on the design and implementation of service animal relief areas. The regulations may consider it the responsibility of an airport to find a guide or service dog organization that will be willing to give a perspective on or approve plans the airport is considering. Individuals with vision impairments and individuals who use wheelchairs will have somewhat different needs when it comes to design of relief areas, so it is to be hoped that a range of organizations will be able to participate in relief area designs.

Since the Department seeks input from interested parties on the Circular, though allowing only a month to submit comments on the regulations.gov website (by entering Docket No. FAA-2016-4716), a guide dog or service animal organization wishing to be involved in the design and creation of relief areas in an airport should consider submitting a comment expressing this interest and thereby put the airport (through the FAA) on notice of its availability. As previously noted, this must be done by June 6.

It appears the drafters of the Circular inside the Department of Transportation are hedging their bets by massaging the definition of service animal to take into account changes that may be coming to the Department’s longstanding acceptance of a broad range of species as service animals. At the moment, however, a service animal relief area cannot be presumed to be one that will only be used by dogs, or even just by dogs and miniature horses. (No miniature horse lobbying group put itself forward to participate in the Reg Neg process for revising the ACAA rules on service animals, though a capuchin monkey group did submit a comment. I am told by someone associated with this group that service monkeys generally wear diapers during flights and do not require a service area.)

Thanks to Brad Morris for careful review and correction of the legal issues.

APPENDIX: STANDARDS FOR SERVICE ANIMAL RELIEF AREAS

A.1 General.

The SARA standards below have been developed in collaboration with nationally recognized service animal training organizations and groups of users of service animals.

A.2 Number.

SARA must be located on an accessible route to each terminal. One relief area may serve two or more terminals if travel to and from it meets reasonable transit times as defined in paragraph A.3.

A.3 Transit time.

The design transit time from any gate to a relief area is no more than 15 minutes, based on a walking pace of 200 ft/min. Any expected time spent using transportation vehicles and waiting time for an escort, wheelchair, or elevators is included in this total transit time.

A.4 Size and shape.

The SARA may be of any shape, but must be designed to accommodate a person using a wheelchair handling a service animal on a six-foot leash. In busier locations, a relief area may be sized to accommodate more than one service animal at one time.

A.5 Surfaces.

A relief area should have at least two different surfaces. One should be hard and located immediately inside the entrance to allow wheelchair access. This surface should be delineated in a manner to indicate the portion intended to be traversed by people, and the portion intended for animal relief. The other should be an appropriate softer surface, such as gravel or mulch for outdoor areas, and artificial turf specially designed as an animal relief surface, treated to inhibit the spread of disease, for indoor (and outdoor) areas. Other artificial turf is not recommended, as it harbors odors and bacteria. Consider that artificial turf is often perceived as carpet by service animals, making them reluctant to use it. Avoid surfaces such as sand that will stick to paws and be tracked outside the SARA. When using mulch, be sure it is not of a species that can be harmful to animals. Dark colored surfaces should not be used where exposed to the sun, as they can become unbearably hot.

A.6 Fencing.

Fencing or another suitable barrier, with an accessible gate/entrance, adequate to contain service animals must be provided.

A.7 Plumbing.

The SARA must include a sink with a faucet for hand washing. Water must be potable, as it will often also serve as a drinking water supply to fill bowls supplied by service animal handlers. A separate water supply must be included for use in cleaning the surface. The surface must be constructed with adequate drainage to facilitate regular cleaning.

A.8 Location.

Outdoor locations are preferred, as all service animals are trained to use outdoor relief areas. While some service animals are trained not to relieve indoors, at some terminals it may not be feasible to establish an outdoor relief area within the sterile area. In such cases, the relief area will have to be constructed indoors. SARA must not be co-located with a designated smoking area.

A.9 Weather protection.

Outdoor SARA must include weather protection from sun and precipitation. If the SARA is close to operating aircraft, protection from jet blast and prop wash must be provided.

A.10 Scent.

The sense of smell is much more acute in animals than in humans. This can be a help or a hindrance in encouraging service animals to use a relief area. Pheromone-scented surfaces or devices can be beneficial, while disinfecting chemicals with strong odors can be detrimental.

A.11 Accessories.

The SARA, at a minimum, must include:

  1. A three-dimensional device (e.g. rock or fake fire hydrant) to encourage urination by male dogs.
  2. Animal waste bags.
  3. A waste receptacle.

Note: The disposal bags and receptacle must be located just inside the entrance to the SARA on an accessible route and at a height reachable by wheelchair users.

A.12 Wayfinding and Signage

A.12.1 Signage Standardization is desirable.

The sign shown in Figure A-1, with or without accompanying text, may be used with directional arrows to guide users to the SARA. The signage, when used, must be included in airport layout maps and in wayfinding instructions provided throughout the airport. In addition, signing at the SARA should indicate the following:

  1. The need for handlers to clean up after animals;
  2. The location of waste disposal bags, and waste receptacles, hand washing facilities, and any other facilities (e.g. automatic flushing controls);
  3. Instructions for the operation of any facilities; and
  4. Contact information for maintenance and assistance.

A.12.2 Other guidance.

Signage should be supplemented with means, including auditory announcements, to guide people with vision impairments. Braille signing must be installed adjacent to the side of doors and gates opposite the hinges. Airports are encouraged to adopt state-of-the art technology (e.g., smart phone applications) as it becomes available.

Posted by John Ensminger at 5:47 AM

Source: http://doglawreporter.blogspot.com/2016/05/transportation-department-gets-specific.html

CONGRATS TO CHRISTIAN AND ELLEN

CONGRATULATIONS TO CLIENT CHRISTIAN AND HIS NOW SERVICE DOG, “ELLEN”!!! THEY PASSED THE PUBLIC ACCESS TEST!!! Christian suffers from PTSD, anxiety, depression, panic attacks, and night terrors. Christian was a first responder at Ground Zero (in an unofficial capacity) and suffered from sexual abuse as a child.

Trainer Robin, in Philadelphia, writes:

“Service Dog “Ellen” was initially trained as a Seeing Eye dog through another organization. Therefore commands are different, and she was trained to walk further ahead (hip to leg) and to keep the leash taut. She is, however, extremely bonded, obedient, enthusiastic and responsive. Great dog!

Location of where PAT took place: Bridgewater Commons, NJ

SCORING OF THE PUBLIC ACCESS CERTIFICATION TEST Always=All the time Mostly=Most of the time (more than half of time) Sometimes=Some of the time (half or less of the time) Never=Never demonstrated the skill The team must score all ‘Always’ or’ Mostly’ ’ responses on the A-M-S-N parts of the test.
The team must score at least 80% “YES” answers on the “YES” “NO” portion of the test.
All questions marked by an asterisk (*) must be answered by a “YES” response.

CONTROLLED UNLOAD OUT OF VEHICLE:

Ellen did not try to leave vehicle until given release command.

Ellen waited in the vehicle until released.* Yes
Ellen waited outside the vehicle under control. Yes
Ellen remained under control while another dog was walked. Yes

APPROACHING THE BUILDING:

Relative heel position, not straining or forging.

Ellen stayed in relative heel position. Always
Ellen was calm around traffic.* Yes
Ellen stopped when Christian came to a halt. Always

CONTROLLED ENTRY THROUGH A DOORWAY

Ellen waited quietly at the door until commanded to enter.* Yes Ellen waited on the inside until able to return to heel position.* Yes

HEELING THROUGH THE BUILDING

Ellen was within the prescribed distance of Christian. Mostly
Ellen ignored the public, remaining focused on Christian. Always Ellen readily adjusted to speed changes. Always
Ellen readily turned corners–did not have to be tugged or jerked to change direction. Always
Ellen readily maneuvered through tight quarters. Always

SIX FOOT RECALL ON LEAD

Ellen responded readily to the recall command–did not stray away, seek attention from others, or trudge slowly.* Yes
Ellen remained under control and focused on Christian.* Yes Ellen came within the prescribed distance of Christian.* Yes
Ellen came directly to Christian.* Yes

SITS ON COMMAND

Ellen responded promptly to the command to sit. Mostly
Ellen remained under control around food–not trying to get food and not needing repeated corrections.* Yes
Ellen remained composed while the shopping cart passed–did not shy away, show signs of fear, etc.* Yes
Ellen maintained a sit-stay while being petted by a stranger.* Yes

DOWNS ON COMMAND

Ellen responded promptly to the command to down. Mostly
Ellen remained under control around the food–not trying to get food and not needing repeated corrections.* Yes
Ellen remained in control while the child approached – child should not taunt Ellen or be overly dramatic.* Yes

NOISE DISTRACTIONS

If Ellen jumps, turns, or shows a quick startle type reaction, that is fine. Ellen should not show fear, aggression, or continue to be affected by the noise.

Ellen remained composed during the noise distraction.* Yes

RESTAURANT

Ellen is unobtrusive and out of the way of patrons and employees as much as possible.* Yes
Ellen maintained proper behavior, ignoring food and being quiet.* Yes

OFF LEAD

When told to drop the leash, the team maintained control and Christian got the leash back in position.* Yes

DOG TAKEN BY ANOTHER PERSON

Another person can take Ellen’s leash and Christian can move away without aggression or undue stress on the part of Ellen.* Yes

CONTROLLED EXIT

Ellen stayed in relative heel position. Always
Ellen was calm around traffic.* Yes
Ellen stopped when Christian came to a halt. Always

CONTROLLED LOAD INTO VEHICLE

Ellen waited until commanded to enter the vehicle. Yes
Ellen readily entered the vehicle upon command. Yes

TEAM RELATIONSHIP

When Ellen did well, Christian praised Ellen. Always
Ellen is relaxed, confident, and friendly. Always
Christian kept Ellen under control. Always
Christian was prepared with proper working materials and equipment in case of an access confrontation (laws, etc.). No

PASS TEST: Yes

Physical Fitness and Safety with Mobility Service Dogs ~ The Dogsider

There is a lot of discussion about the size of a mobility dog necessary for clients who need them for certain tasks. I found this article to be very informative, and would welcome any other suggestions on good articles regarding this:

The job description of a mobility dog can include a myriad of things. Wheelchair pulling, button pushing, flipping light switches, counter balance, bracing, item retrieval, door opening and closing and momentum pulling, just to name a few. Whatever mobility tasks a service dog is trained to do are things they should be more than physically competent to perform.

For example: an 8 lb Papillon can do light item retrieval (keys, medicine) and may be able to operate a K9 phone, certain adapted light switches, open lower, lightweight doors, but they are in no way capable of pulling a wheelchair.

Another example: a 58 lb Chesapeake Bay Retriever (I’m using Saxon in this example!) can easily tug doors, turn on/off lights, press handicapped buttons, counterbalance, item retrieval and momentum pull, but is NOT capable of bracing. I will never ask her to learn to square up or stiffen her body for bracing. She will never be large enough to support the weight I carry.

Yet another example: a 90 lb Doberman can easily do most if not all mobility tasks that could be required, including bracing. A 90 lb dog will be large enough for most adults who are of average or overweight (NOT obese) size to do brace work with.

For this post I’m not mentioning program trained mobility dogs because they generally come with their own set of trained tasks, health check up, mobility harness/gear with usage instructions and have been chosen specifically for the client. The following questions are geared at those people who have mobility issues, either diagnosed or self assessed (symptoms can still impede your overall mobility) and decide to train a mobility dog for themselves.

What mobility tasks can you not live without?

First you need to have an honest discussion with yourself and anyone who knows you and your issues well (family member, friend, doctor) and can provide insight into tasks you may need. Come up with symptoms or scenarios that make a situation challenging or limit your mobility. Then assign tasks to those things you struggle with and rank them from most important to least. Make sure to distinguish between tasks you do not think you could function well or at all without, and those that would make your life easier. (get medication when you cannot get up to get it yourself vs. turn off your light at night when you’re capable, but comfy in bed).
Is the dog large enough to be able to perform all the tasks you need ESPECIALLY if you want them to bare weight?
If you have a specific breed of dog in mind you should be comparing the average height and weight of that breed to what you are hoping to have the dog someday perform as tasks. There are a lot of weight ratios thrown around. I’ve heard the dog is supposed to be 50% of your weight and 40% of your height (measured from their shoulder) to be deemed large enough for heavy mobility such as bracing. It’s 30% weight and 30% height for counterbalance and momentum pull I think. I’m not sure where these numbers came from or if they are just arbitrary percentages. I think for bracing 50/40% is accurate. Counterbalance and momentum pull I personally disagree with as I’ve seen videos of Chihuahuas pulling 500+ lbs in Weight Pull. In the right harness (not on a flat collar, prong collar, head collar or front clip harness) there should be absolutely no issues with straight momentum pull. But back to the bracing percentages. If you weigh 150 lbs and are 5’6, your dog needs to weigh 75 lbs minimum and be at least 26.5″ at the shoulder. If you weigh 100 lbs I still think dogs should be minimum 60 lbs, but that’s my personal feelings. Most dogs under 60 lbs don’t have the bone build to support significant excess weight, even if only momentarily.
And in every single case where the dog will have any weight applied it is essential to your dog’s health that you get the dog’s hips and elbows x-rayed and then looked at by an orthopedic vet to determine joint health. Failure to do so could cause unnecessary pain and additional issues in a dysplastic dog. Although it is possible to get with a dog with great hips, either all but guaranteed by hip scores in the dog’s lineage, or purely by luck. In any case though, a dog you are asking to physically support your weight for your health should not have their health left up to luck and chance. A dysplastic dog does not need to be supporting their handler’s weight if they are struggling or could at any point begin to struggle to support their own. The dog should be 2 years prior to final x-rays that will determine the mature hips and joint structures of the dog. 2 years is generally when the joint capsules have closed, though in some giant breed dogs it may take up to 3 years for all joints to close and bones to have fused. It can seriously harm a puppy or young dog, even a large or giant breed, to brace on their unfused joints.
In the 2 week old pup there are clear spaces in the joint capsule of nothing. You can see how far the bones have to grow to be able to touch each other and create strong joints. The 7 month old has most of the bone structure but the bones are still softer as they have not are not fully hardened to how they will be as adults. The last photo is an x-ray of a dog with a healthy set of adult hips with hardened bones and complete joint sockets where the bones fit well together.

There are many mobility harness makers, several of them making custom harnesses to the dog’s specifications. Unless you can go to the harness maker’s store front to have your dog measured personally, the handler is often left to get their dog’s own measurements. A proper rigid bracing harness consists of a a piece of metal that runs horizontally across the shoulders NOT vertically up the spine. The strongest point on dog to bare weight is right across the shoulders. When bracing on the shoulders it is imperative the dog be taught to square up and brace to minimize likelihood of injury for both dog and handler.

Prior to putting on any rigid handled harness, the dog must have already mastered squaring up and tensing up muscles prior. Training a mobility dog, contrary to some things I’ve seen floating around, is not as simple as throwing a harness over their head, buckling it up and just walking with it. The dog does not automatically know what to simply because they are now wearing a mobility harness. What I mean by this is the dog stands with both of their front feet together so the shoulders line up. The back feet are in line with the shoulders and are also square (not one significantly forward or backward). From this position the dog has the best ability to brace themselves effectively. I am using the word “Brace”, but whatever you call it (“Stiff” “Hold” “Steady”) the behavior is the same. The dog who has now mastered squaring their body will now need to learn how to stiffen their muscles in response to pressure being applied. This is NOT a behavior that can be introduced, learned and proofed in a single training session. This behavior also should NEVER be taught with a mobility harness. The harness should be added later once the brace behavior is solid.

Handle height is important. The proper way to measure for handle height is for you to up as straight as you can with your arms hanging loose at your side. Whichever side your dog heels on, make a loose fist with that hand. That is the height your mobility handle needs to be. Your shoulder should not raise to extend your arm nor should you be able to bend your elbow while holding the handle. When measuring for a handle you will stand as straight as you can, let your arm hang and hold it as if you are gripping a bar. It may actually help to hold a pen or marker while you are measuring from the distance from your hand to the floor. The other number needed to get a handle height is the dog’s height. My dog is 23″ at the shoulder. The height from my relaxed arm with a  closed fist to the floor is 30″. Therefore I would need a handle height of 7″.

It is not advised to do mobility with a dog for which you would require greater than a 6″ handle. Although there are harness makers that will add handles of heights as high as 14″, that is too high, and a dog can far more easily get harmed with the same action and force with a 10″ rigid handle vs a 4″ one. When a handle is too high too much pressure (such as a full force brace) or an incorrect brace (where the dog is not squared and the handler may not be completely next to or parallel to the dog and handle) it creates something called torque. Torque for those who aren’t mechanics or into physics, is defined as: a twisting force that tends to cause rotation.

Naturally any twisting force repeatedly applied to the spine and shoulders of a dog of any size is as dangerous as it sounds. Since to my knowledge none of the rigid handle harnesses on the market come with a detailed instruction manual including safe, proper usage, the handler/owner of their service dog’s new harness must now choose between trying to figure out what to do on their own or rely on the sometimes misguided advice of trainers or the internet. Bracing as carried out ideally will have the handler cue to the dog to stop or the dog auto stops. The handler asks the dog to square up if the dog has not already done so. The handler puts pressure on the handle to lever themselves up, usually from lower to higher ground (curb or stair) or from seated to rising such as standing from a chair. The dog remains still with muscles stiffened while the handler has hands on the handle. This is momentary pressure. The dog’s back is not meant to sustain the prolonged pressure of an adult’s body weight.

A dog should not be asked to brace while they are standing. The handle may be used for steadying purposes, such as reaching out to hold it or reorient in space, but at that point it is unsafe to apply any weight or downward force as the dog is not squared or prepared to brace. A rigid handle should not be used as a crutch or cane. Even a dog large enough to handle temporary bracing should not be subjected to step by step partial or full adult weight with downward force. If every step needs physical support above steadying simply by way of the handle simply being held, another mobility aid (cane, crutch, walker) may need to be added so the dog’s safety can be ensured.

On the note of discussing bracing in motion, a dog cannot square their body in motion, so bracing with a handle of any height cannot and should not be done in motion. The handle is NEVER meant to be pushed forward or backward. It is NOT a guide handle. There are a multitude of other harnesses that have guiding handles or pull straps if that is what is needed. There are also harness makers who combine a mobility harness with a rigid handle with a guide handle or pull strap attached so the harness can serve both functions.

One thing I see frequently in some of the service dog gear groups targeted toward mobility harnesses is that people will buy a rigid handle thinking they need it or that their disability manifests itself far more physically than it actually does. I see a lot of people trying desperately to downgrade their rigid handle for a soft handled balance harness. One of the only real differences between a rigid handle and a non rigid one is that a non rigid handle cannot be used for bracing at all. It can however be pulled up on to help yourself up or to hold the handle while the dog leans the opposite way, providing momentum to help you right yourself. A non rigid can double as a leading harness and can be used for momentum pulling and counter balance.

With one final comment, if you require an 85 lb dog, a dog who would at peak fitness be 70 lbs should not be used because it weighs at or in excess of the necessary 85 lbs. A dog who carries a good deal of excess weight should not be used as a mobility dog. There is simply no selfless way to ask a dog, even a trained dog, to support your weight and many multiple excess pounds of their own. I’m not talking a 3-5 lbs too many. There are so many dogs I’ve seen who weigh probably 20-30 lbs overweight, and I’ve seen some who may even be 40+ lbs overweight working as bracing mobility dogs. It’s just not fair. After a diet if they are healthy and fit (and evaluated by a vet to be cleared after a large weight loss) sure, but until then, the dog doesn’t need to carry more than his own share of weight and yours too.

Just for kicks, here is my little Mochi dog wearing a mobility harness. She is a retired service dog, but she never was a mobility dog.
“Hey Mochi! What are your thoughts on small dogs, unhealthy dogs, other unsuited dogs being used as bracing mobility dogs? I’ll make this tougher, contemplate this quandary! What if it’s not an issue with the dog, but how the handler uses the harness? Mochi, think about this, what if it’s both?”
That above is Mochi’s response. She says USE COMMON SENSE! I concur. Wisely spoken, Little One, wisely spoken.

 

 

Source: Physical Fitness and Safety with Mobility Service Dogs ~ The Dogsider

CONGRATS TO MISTY AND SERVICE DOG “AXLE”

CONGRATULATIONS TO CLIENT MISTY AND HER NOW SERVICE DOG, YELLOW LABRADOR RETRIEVER, “AXLE”! THEY PASSED THEIR PUBLIC ACCESS TEST!!!!
 
Misty suffers from PTSD. She was violently assaulted while working overseas in Kuwait in 2014. She was beaten until she was unconscious, and recently had her third surgery. When she first applied for Service Dog training, Misty had just begun learning what her “triggers” were, and she is on several medications right now to help her sleep through the night and try to function “normally”. She didn’t know what was wrong with her in the beginning, and didn’t start talking to a therapist until she returned to the US last October. LOOK how far she has come!!!! Training with a Service Dog – we are SO proud of you, dear Misty!!
 
Trainer Lori writes:
 
“Today, Misty and her now Service Dog “Axle” passed the Public Access Test at the Tractor Supply in Lampasas, TX! For the restaurant portion of the test, we went next door to the El Rodeo Mexican Restaurant. I am so proud of this team! They passed with a score of 100%!”
 
SCORING OF THE PUBLIC ACCESS CERTIFICATION TEST
Always=All the time
Mostly=Most of the time (more than half of time)
Sometimes=Some of the time (half or less of the time)
Never=Never demonstrated the skill
The team must score all ‘Always’ or’ Mostly’ ’ responses on the A-M-S-N parts of the test.
The team must score at least 80% “YES” answers on the “YES” “NO” portion of the test.
All questions marked by an asterisk (*) must be answered by a “YES” response.
 
CONTROLLED UNLOAD OUT OF VEHICLE:
 
Axle did not try to leave vehicle until given release command.
 
Axle waited in the vehicle until released.* Yes
Axle waited outside the vehicle under control. Yes
Axle remained under control while another dog was walked. Yes
 
APPROACHING THE BUILDING:
 
Relative heel position, not straining or forging.
 
Axle stayed in relative heel position. Always
Axle was calm around traffic.* Yes
Axle stopped when Misty came to a halt. Always
 
CONTROLLED ENTRY THROUGH A DOORWAY
 
Axle waited quietly at the door until commanded to enter.* Yes
Axle waited on the inside until able to return to heel position.* Yes
 
HEELING THROUGH THE BUILDING
 
Axle was within the prescribed distance of Misty. Always
Axle ignored the public, remaining focused on Misty. Always
Axle readily adjusted to speed changes. Always
Axle readily turned corners–did not have to be tugged or jerked to change direction. Always
Axle readily maneuvered through tight quarters. Always
 
SIX FOOT RECALL ON LEAD
 
Axle responded readily to the recall command–did not stray away, seek attention from others, or trudge slowly.* Yes
Axle remained under control and focused on Misty.* Yes
Axle came within the prescribed distance of Misty.* Yes
Axle came directly to Misty.* Yes
 
SITS ON COMMAND
 
Axle responded promptly to the command to sit. Always
Axle remained under control around food–not trying to get food and not needing repeated corrections.* Yes
Axle remained composed while the shopping cart passed–did not shy away, show signs of fear, etc.* Yes
Axle maintained a sit-stay while being petted by a stranger.* Yes
 
DOWNS ON COMMAND
 
Axle responded promptly to the command to down. Always
Axle remained under control around the food–not trying to get food and not needing repeated corrections.* Yes
Axle remained in control while the child approached – child should not taunt Axle or be overly dramatic.* Yes
 
NOISE DISTRACTIONS
 
If Axle jumps, turns, or shows a quick startle type reaction, that is fine. Axle should not show fear, aggression, or continue to be affected by the noise.
 
Axle remained composed during the noise distraction.* Yes
 
RESTAURANT
 
Axle is unobtrusive and out of the way of patrons and employees as much as possible.* Yes
Axle maintained proper behavior, ignoring food and being quiet.* Yes
 
OFF LEAD
 
When told to drop the leash, the team maintained control and Misty got the leash back in position.* Yes
 
DOG TAKEN BY ANOTHER PERSON
 
Another person can take Axle’s leash and Misty can move away without aggression or undue stress on the part of Axle.* Yes
 
CONTROLLED EXIT
 
Axle stayed in relative heel position. Always
Axle was calm around traffic.* Yes
Axle stopped when Misty came to a halt. Always
 
CONTROLLED LOAD INTO VEHICLE
 
Axle waited until commanded to enter the vehicle. Yes
Axle readily entered the vehicle upon command. Yes
 
TEAM RELATIONSHIP
 
When Axle did well, Misty praised Axle. Always
Axle is relaxed, confident, and friendly. Always
Misty kept Axle under control. Always
Misty was prepared with proper working materials and equipment in case of an access confrontation (laws, etc.). Yes
 
PASS TEST: Yes

10 Spring Plants That Are Dangerous for Pets

10 Spring Plants That Are Dangerous for Dogs and Cats

Spring has finally sprung — but some of the flowers and plants growing in your garden or blooming in your vases could cause serious harm to your pet.

As a veterinary toxicologist for the ASPCA Animal Poison Control Center and a gardening enthusiast, I often give advice on planting pet-safe gardens — and with the planting season in full force, it’s important for all dog and cat owners to be extra vigilant about keeping dangerous plants out of their homes and gardens. If you suspect your dog or cat has ingested a toxic plant, call the ASPCA Animal Poison Control Center hotline at 888-426-4435 and contact your veterinarian. It’s always better to be safe than sorry.

Read more atVetstreet.com – 10 Spring Plants That Are Dangerous for Dogs and Cats