Prioritizing The Welfare Of Service & Support Animals

It’s no secret that we humans love our companion animals. In the U.S. alone, nearly 70% of households across the country have at least one companion animal — the majority of whom are dogs and cats. Our lives are intimately intertwined with those of our companion animals, and the data shows that many of us will do just about anything to make them happy.

Of course, humans don’t just pamper companion animals — we also lean on them as our unofficial therapists, our friends and allies, our confidants, and our workout buddies. In some cases, we even employ them as working service animals and emotional support animals. Service and support animals play crucial roles in the lives of many people with disabilities and emotional support needs, but the rules and regulations governing those roles are often confusing and hard to understand.

In the blog that follows, we’ll look at the lives of both service and emotional support animals, exploring their welfare from their births, through to training, placement, and throughout their working lives. We write this with the hopes of encouraging more clarity on regulations, rules, and policies for both categories of animal, as well as encouraging more research to determine welfare risk factors, both for the animals’ sake and for the sake of the people they assist.

Defining Service & Support Animals

It’s important not to conflate service and support animals — for the sake of people with disabilities, people with emotional support needs, and the animals themselves. Each category of animal plays a different and specific role in different contexts.  

According to the Americans with Disabilities Act (ADA), a service animal must be a dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Those tasks can be wide-ranging, encompassing everything from pulling a wheelchair, retrieving dropped items, alerting a person to a sound, reminding a person to take medication, pressing an elevator button, and beyond. The crucial points are that they must be dogs and they must be specially trained in one or more disability-related tasks.

Meanwhile, emotional support animals, comfort animals, and therapy dogs are not service animals under Title II and Title III of the ADA. They can include dogs, as well as a range of other species, and do not need to perform any specific tasks — they can simply provide emotional support through their presence. They are designated as emotional support animals by a doctor’s note; for their part, the ADA attempts to make this distinction clear:  “the work or tasks performed by a service animal must be directly related to the individual’s disability. … A doctor’s letter does not turn an animal into a service animal.”

Why does this distinction matter? In short, the two different categories are treated differently under the law, though this may be in flux depending on where you live. In the United States for example, there has been a years-long trending increase in the number of emotional support animals and this has led to shifting regulations on various airlines, among other milieus. Perhaps the worst unintended side effect of the rise of emotional support animals has been the confusion it’s wrought around the issue of assistance animals more broadly. While people with service dogs already face discrimination, the distinctions between the service dogs and support animals is quite muddy in the eyes of the media, and often the public — which could lead to further discrimination.

Origins & Breeding

Considering the welfare of service and support animals needs to begin with their origins — and this is the first place where animal advocates may find a stumbling block. Many service dogs are purpose-bred for the job they are meant to do, and animal advocates don’t generally support purpose-breeding because it can produce welfare-reducing inbred traits and brings more dogs into the world when there are already many that need homes. The American Kennel Club (AKC) argues that “the predictability of dogs in a breeding program yields improved results,” and breeders claim that they stick to rigorous standards relating to “temperament, trainability, health, physical attributes, … only the ‘best of the best’ are chosen.” Just like other companion dogs, service dog welfare likely depends greatly on the care and training they receive from their handlers.

Accreditation and oversight for breeders and handlers is a positive thing. However, a recent study shows the increasingly uncertain origin of service dogs, and notes that, while there are organizations and international bodies that help to accredit breeders and trainers, the proportion of animals coming from accredited agencies is in flux. Among a range of findings, they found that non-accredited facilities were much newer than accredited ones, on average, with most being founded in the 2000s or 2010s. 

Interestingly, the AKC says that, “regardless of breed or mix, the best service dogs are handler-focused, desensitized to distractions, and highly trained to reliably perform specific tasks. They are not easily diverted from their tasks at home or in public and remain attentive and responsive [to] their owners while working.” These traits do not necessarily have to belong to purpose-bred dogs, and reputable service dog organizations are emphatic that rescue dogs can also become service dogs, given the right circumstances. This presents an interesting opportunity for companion animal advocates and disability advocates to work together to both rescue animals and provide disabled people with companions who can help them.

It’s worth noting here that we’re mostly talking about dogs, using the ADA’s definition above. However, with the explosion in popularity of emotional support animals, we’ve seen the range of species considered to be emotional support animals grow in tandem, sometimes including cats, ferrets, pot-bellied pigs, and even peacocks. The provenance of these animals is as varied as they are, and since special training for them is not required, there are no regulations around it. This could be an area where clearer policies and definitions could be beneficial, for both the emotional support animals, and the people who rely on them.

Training & Teaching

The training process for service dogs can be intense and rigorous, and that comes at a price: purchasing a trained service dog can range from $15,000 USD on the low end to as much as $50,000 USD on the high end. As noted above, such dogs are generally purpose-bred and trained from puppies to perform specific tasks related to certain disabilities. Not surprisingly, this means that some people with disabilities who might benefit from a service dog cannot actually afford one — there are grants and programs that exist to help defray or cover costs for those in need, but they do not provide for everyone. 

You may be surprised, however, to learn that not all certified service dogs undergo intensive training before adoption or purchase, and many people who can’t afford to buy a trained service dog do their own training — in fact, there are numerous online guides to help them in doing so. This is a positive thing for people with disabilities who cannot afford tens of thousands of dollars for a service dog, but it does mean that there is no oversight for training. Relatedly, the ADA does not require that service dogs be registered in any way — and businesses cannot require people with disabilities to produce a training certificate, registration, or ask anything specific about a person’s disability. That said, the ADA does outline various points that define a service dog, whether trained by a specialized breeder or not, that help to clarify the matter.

As mentioned previously, there is no special training or teaching required of emotional support animals, and the only thing needed to legally classify them as such is a doctor’s note. While some emotional support animals may receive training, the vast majority likely do not, and that seems to be a key way that they are differentiated from service animals. In this sense, we cannot talk about the training of emotional support animals in a scientifically meaningful way. This lack of training underscores that emotional support animals are governed by a patchwork of policies that are generally unclear.

Living & Working

Finally, the place where service and support animals spend the majority of their lives is in contexts where they’ll be working — that is, in the homes and daily living contexts of the people they are helping.

Considering the importance of service animals to people with disabilities, it should follow that there would be considerable body of research on their welfare on the job. Strangely, this does not seem to be the case. A 2018 review found only a handful of peer-reviewed studies and one book chapter looking at the topic. It seems especially counterintuitive, considering just how much research exists on the welfare of companion animals more broadly — but, as the review bluntly notes: “assistance dogs are not pets.” The review notes that many service dog organizations do seem to take their welfare seriously, and there’s no doubt that human guardians don’t want their service dogs to be in distress. Still, the review covers studies that reveal that there are clear negative welfare outcomes for at least some service dogs. “Very little research has been undertaken to understand the specific challenges faced by assistance dogs which could negatively impact their welfare,” they state, “and this needs to change.”

Emotional support animals have made news in recent years for their growing ubiquity on flights, and for the confusion over just where they are and are not allowed, especially the public’s generally weak understanding of the legal distinctions between emotional support animals and support animals. The range of species designated as emotional support animals and their broad allowance in public places reached an absurd apex in the case of an emotional support kangaroo brought to a McDonald’s in Wisconsin. These cases make for good media fodder, but something that is rarely discussed is the kind of distress that these non-domesticated animals might experience in public places. When we consider that even dogs can experience stress in busy urban environments, it’s not hard to imagine that a peacock or kangaroo would have an even harder time. In the meantime, the relatively no-holds-barred presence of support animals on flights seems to have come to an end. 

One area where support animal welfare has been studied fairly extensively is their use in Animal Assisted Therapy (AAT). These interventions are usually time-limited (no more than a couple of hours at a time in a clinical or controlled setting), and generally involve bringing an animal into the presence of the person needing therapeutic assistance. The Faunalytics Research Library contains information about guinea pig welfare during AAT sessions, articles outlining welfare concerns for dogs used in AATs, and multiple calls for clearer regulations.

In all of these contexts, the main throughline is that these animals should not be seen merely as tools to help achieve certain human health outcomes. As with companion animals — and, animal advocates would note, all animals — assistance animals have their own interests, and a right to be free from harm. In the quest to improve human lives, pain and distress in other species may be overlooked. As mentioned above, it’s a topic that could benefit from more research. In the meantime, pushing for clearer and more specific regulations for service and support animals in all contexts is a good place for animal advocates to start, and it’s a place where we can do so through coalitional work with the disability advocacy community.

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It’s important to recognize that service and support animals can have wonderful lives of close connection to their people, and can form bonds that are deep and mutually beneficial. It’s a great example of a topic that defies easy categorization or ethical positioning, and is one that animal advocates must approach carefully — these issues reveal distinct overlaps between animal advocacy and disability advocacy that should be treated with care and compassion from all angles.

Could it be possible to sidestep some of the ethical and welfare concerns with service animals by creating interventions where animals are not used at all? In addition to more traditional alternatives such as canes for the visually impaired, some researchers have tested the effectiveness of using “pet robots” as a proxy for real companion animals, and the results show some potential promise. While robotic animals may be a part of our more distant future, for now, service and support animals are here to stay. It behooves us to consider them as not just companions, but also workers who need their interests protected. Animal advocates have the capacity, the potential, and (some of) the data to help make meaningful interventions to help improve the lives of service and support animals, and to form coalitions with disability advocates as we do so.