Position Statements

Service Animals

June 7, 2021

Background

1. Service animals assist persons with a disability in many ways including: guiding and alerting the visually impaired and hearing impaired; assisting with activities of daily living; alerting and protecting those suffering from seizure disorders; reminding patients to take prescribed medications; calming individuals experiencing an anxiety attack, and performing critical tasks that provide support (1-3).
2. Under federal law in Canada “service animal” is defined as “an animal that is required by a person with a disability for assistance and is certified, in writing, as having been trained by a professional service animal institution to assist a person with a disability” (4). Service animals are most frequently dogs trained for one or more functions (5); however, in some jurisdictions other species of animals may be considered as service animals (6).
3. “Service dog” is defined under the federal Accessible Transportation for Persons with Disabilities Regulations (7) as “a dog that has been individually trained by an organization or person specializing in service dog training to perform a task to assist a person with a disability with a need related to their disability.”
4. The CVMA recognizes that although service animals provide great value to society by assisting individuals with disabilities (1,8), a national standard currently does not exist covering elements such as animal health and welfare, training and suitability for intended purpose.
5. In Canada, transportation service providers must accommodate persons who travel with service dogs under the Accessible Transportation for Persons with Disabilities Regulations (ATPDR) (9).
6. Provincial laws in Canada pertaining to rights of persons with disabilities vary between and within jurisdictions resulting in fragmented and inconsistent definitions, policies, and regulations across the country (10,11).
7. Internationally there are a variety of requirements, regulatory and otherwise, pertaining to service animals (12-14) which leads to global inconsistencies across policies and regulations.
8. Depending on the jurisdiction, an animal identified as a “therapy animal”, “emotional support animal” or “working animal” (e.g. military, police or search and rescue) may not be considered as a service animal and therefore may not have the same rights to access facilities or services such as workplaces, stores, restaurants and airlines (15).
9. Due in part to variation and fragmentation across jurisdictions in the definition and certification requirements of a service animal, many challenges have arisen (16) including:
   • industries such as travel, and hospitality may be unable to distinguish between true service animals and those not meeting the required definition in the relevant jurisdiction;
   • accommodating various species of animals that are presented as service animals such as miniature horses, birds and other species;
   • animals presented as service animals that are untrained, or unsuitable by nature for their intended purpose due to their physical attributes or behaviour(s);
   • animal health concerns (uncertain vaccination history, zoonotic disease potential);
   • animal welfare concerns (stress and anxiety for unconditioned animals presented as service animals in busy settings such as airports, aggressive behaviour presenting risks to other animals);
   • public health and safety concerns (people with allergies, immunocompromised individuals, potential bite incidents, people suffering from fear of animals);
   • fraud (organizations issuing improper or meaningless accreditation or certification documents);
   • owners claiming untrained household pets to be service animals;
   • improper training or absence of training of animals presented as service animals.
10. In the USA, the Department of Transportation established a final rule on service dogs in late 2020 that adds clarity to the definition of service animal with respect to air travel. Among other points it defines a service animal as a dog that is individually trained to do work or perform tasks for the benefit of a person with a disability and stipulates that  an emotional support animal is not considered to be to be a service animal (17).
11. Given the above challenges, the CVMA holds that a national standard for service animals should be developed that includes, but is not limited to the service animal being:
    • examined on a regular basis by a veterinarian in order to assess its health and welfare status as part of an ongoing health management program;
    • formally trained along with the handler to address specific disabilities and/or perform certain functions in accordance with recognized standards overseen by a recognized institution;
    • formally trained using only humane training methods;
    • certified by a recognized institution that the animal has reached a specified standard of competence (suitability for intended purpose);
    • re-certified on a regular basis a recognized institution;
    • a participant in a life plan designed to ensure humane treatment, for example from puppy to senior and end of life.
12. There are notable examples of organizations that have established standards for service animals in Canada and internationally such as the International Guide Dog Federation (18) and Assistance Dogs International (19).  Several Canadian organizations are accredited by these international bodies (20, 21).
13. The CVMA supports the exclusive use of humane training methods for service animals (22) and the incorporation of animal health and welfare requirements into organizational standards.
14. Veterinarians including those with specific training and expertise in animal behaviour, animal welfare, preventive medicine, animal disease and zoonotic disease are well-placed to contribute to the development of national standards for service animals, particularly with respect to animal health and welfare, and behaviour.

15. Veterinarians and the public should apply due diligence in their assessment of organizations that offer certification of service animals and should consider whether or not the organization is accredited to the standards that comply with international bodies such as those mentioned in #12 above (18,19).  The CVMA strongly encourages organizations involved with the training of service animals to join with those that adhere to recognized standards and accreditation processes.

16. The CVMA recommends that governments in Canada work to harmonize federal and provincial legislation across Canada with respect to service animals and to encourage the development of a national standard including animal health and welfare, training and suitability for intended purpose.

17. Veterinarians should limit their advice to clients on service animals to matters of animal health and welfare, and behaviour. Advice to clients on the need for a service animal in their particular circumstances should be left to human health professionals. Certification of the suitability of an animal as a service animal should fall to a professional service animal institution.  Wherever possible veterinarians should work in close collaboration with the above professions and institutions to support the health and welfare of service animals (23).

References

1. Hall et al. .  A survey of the impact of owning a service dog on quality of life for individuals with physical and hearing disability: a pilot study. Health and Quality of Life Outcomes. 2017;15:59. Available from : https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5372266/pdf/12955_2017_Article_640.pdf. Last accessed September 9th, 2020.
2. Accessibility for Ontarians with Disabilities Act (AODA). Understanding Service Animals (2019).  Available from:  https://aoda.ca/understanding-service-animals/. Last accessed September 9th, 2020.
3. Accessibility for Ontarians with Disabilities Act (AODA). Service Animal Laws for Ontario Workplaces. (2019). Available from :  https://aoda.ca/service-animal-laws-for-ontario-workplaces/. Last accessed September 9th, 2020.
4. Justice for Animals in Service Act (Quanto’s Law) (2015). Available from : https://laws-lois.justice.gc.ca/eng/annualstatutes/2015_34/page-1.html. Last accessed September 9th, 2020.
5. Lions Foundation of Canada. Dog Guides.  Available from : https://www.dogguides.com/programs.html. Last accessed September 9th, 2020.
6. American Veterinary Medical Association (AVMA).  Service Animals. Available from : https://www.avma.org/resources-tools/avma-policies/service-animals. Last accessed September 9th, 2020.
7. Government of Canada. Accessible Transportation for Persons with Disabilities Regulations (2019). Available from: https://laws-lois.justice.gc.ca/eng/regulations/SOR-2019-244/page-1.html. Last accessed September 9th, 2020.
8. American Veterinary Medical Association (AVMA). Service, emotional support and therapy animals. Available from:   https://www.avma.org/resources-tools/animal-health-welfare/service-emotional-support-and-therapy-animals. Last accessed September 9th, 2020.
9. Canadian Transportation Agency. Accessible Transportation. Service Dogs: A Guide (2020).Available from:  https://otc-cta.gc.ca/eng/publication/service-dogs-a-guide. Last accessed September 9th, 2020.
10. Assistance Dogs International. Available from : https://assistancedogsinternational.org/resources/public-access-laws-canada/. Last accessed Septmeber 9th, 2020
11. The Canadian Foundation for Animal Assisted Support Services. Available from:   https://www.cf4aass.org/the-abcs-of-service-dogs.html. Last accessed September 9th, 2020.
12. Government of New South Wales (Australia). Assistance Animals. Available from:   https://www.olg.nsw.gov.au/public/dogs-cats/responsible-pet-ownership/assistance-animals/. Last accessed September 9th, 2020.  
13. Government of New Zealand. Guidelines for authorization to certify disability assist dogs. Available from: https://www.dia.govt.nz/diawebsite.nsf/wpg_URL/Resource-material-Dog-Control-Guidelines-for-authorisation-to-certify-disability-assist-dogs. Last accessed September 9th, 2020.
14. Equality and Human Rights Commission (UK). Assistance Dogs. A Guide for All Businesses. Available from :https://www.equalityhumanrights.com/sites/default/files/assistance-dogs-a-guide-for-all-businesses.pdf  . Last accessed September 9th, 2020.
15. Province of Ontario. Integrated Accessibility Standards. under Accessibility for Ontarians with Disabilities Act (2005). Available from: https://www.ontario.ca/laws/regulation/110191#BK149. Last accessed September 9th, 2020.
16. American Veterinary Medical Association. Assistance Animals: Rights of Access and the Problem of Fraud (2017). Available from : https://www.avma.org/sites/default/files/resources/Assistance-Animals-Rights-Access-Fraud-AVMA.pdf . Last accessed September 9th, 2020.
17. US Department of Transportation. Service Animal Final Rule (2020). Accessible from:   https://www.transportation.gov/briefing-room/service-animal-final-rule. Last accessed Jan 20th, 2021.
18. Assistance Dogs International. Summary of Standards. Available from:https://assistancedogsinternational.org/standards/summary-of-standards/. Last accessed September 9th, 2020.
19. International Guide Dogs Federation. Standards. Available from: https://www.igdf.org.uk/about-us/igdf-standards/. Last accessed September 9th, 2020.
20. Canadian Association of Guide & Assistance Dog Schools. Available from: http://www.cagads.com/index.html. Last accessed September 9th, 2020.
21. BC and Alberta Guide Dogs. Available from:  https://bcandalbertaguidedogs.com/ . Last accessed September 9th, 2020.
22. Canadian Veterinary Medical Association. Humane Training Methods for Dogs, Position Statement (2015). Available from:https://www.canadianveterinarians.net/documents/humane-training-methods-for-dogs. Last accessed September 9th, 2020.
23. American Veterinary Medical Association .  The veterinarian’s role in supporting appropriate selection and use of service, assistance and therapy animals. Available from: https://www.avma.org/resources-tools/avma-policies/veterinarians-role-supporting-appropriate-selection-and-use-service-assistance-and-therapy. Last accessed January 26th, 2021.