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Assisting passengers traveling with service animals

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Title:
Assisting passengers traveling with service animals final report
Physical Description:
1 v. (various pagings) : ; 28 cm.
Language:
English
Creator:
Mathias, Rosemary G
Project ACTION (U.S.)
University of South Florida -- Center for Urban Transportation Research
Publisher:
Project ACTION
Place of Publication:
Washington, DC
Publication Date:

Subjects

Subjects / Keywords:
People with disabilities -- Transportation -- United States   ( lcsh )
Guide dogs -- United States   ( lcsh )
Bus drivers -- In-service training -- United States   ( lcsh )
Genre:
bibliography   ( marcgt )
non-fiction   ( marcgt )

Notes

Bibliography:
Includes bibliographical references (p. H-1-H-4).
Additional Physical Form:
Also available online.
Statement of Responsibility:
prepared by Rosemary G. Mathias.
General Note:
"January 1997."
General Note:
"Produced with assistance derived from the Federal Transit Act, through a cooperative agreement with the U.S. Department of Transportation, Federal Transit Administration and Project ACTION of the National Easter Seal Society."
General Note:
Prepared for Project ACTION, Washington D.C.

Record Information

Source Institution:
University of South Florida Library
Holding Location:
University of South Florida
Rights Management:
All applicable rights reserved by the source institution and holding location.
Resource Identifier:
aleph - 001929163
oclc - 36647159
usfldc doi - C01-00082
usfldc handle - c1.82
System ID:
SFS0032200:00001


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Assisting Passengers Traveling with Service Animals Final Report January 1997 Prepared by: Ro semary G. Mathias Center for Urban Transportation Research College of Engineering University of South Florida 4202 E Fowler Ave., ENB 118 Tampa Flo rida 33620 Tel: 813-974-3120 Prepared for: Project ACTION 700 13th Street NW, Suite 200 Washington, DC 20005 Tel: 202-347-3066

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Ac knowled g ments The author thanks the followin g individuals from the Center for Urb an Trans porta tion Research (CUTR), who participated in the preparat ion of this rep o rt: Lisa Argiry, Julee Green Sheryl Stire and Vicki Zambito. Thanks a l so to R. Benjamin Gribbon, for proposing the project, and to Robert Carlson of Project ACTION, who provi ded assistan ce through out the project. Special th anks to Alison S c hul tz of Can ine Companions for Independ ence (CC I ) South east Regional Trai ning Offi ce, and Susan Dun can of th e Delta Society National Service Dog Center, for their insig ht and advice re lating to tra ining servi ce anim a l teams. Finally thanks to the many transit agencies and service animal training schools that p ro vi d ed materials fo r this study. Thi s do cument is disseminated under s p o nsorshi p of Projec t ACTION ofthe Natio nal Easter Seal Society in the inte rest o f information exchan ge Ne ither Project A CTION, the Na tional Easter Seal Society nor the Federal Transi t Ad mini stra ti on assume s l iability for its contents or use thereof. The content s of this report refle c t the opinion of the author . I

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Service Animal Project Steering Committee Margaret Ager Canine Companions for Independence Southeast Regional Office Orlando, F lorida Marilyn Baldwin, Commissioner Flo r ida Commission for the Transportation Disadvantaged Tallahassee, Florida Valerie Barber-Simpson Casse lb erry, F lorida Marion Gwizdala National Federation of t he Blind of F lorida Brandon, Florida Carala Jewell Tampa, Florida Cathe rine Kelly Florida DO T Tallahassee, Flo rida James P. Liensenfelt Space Coast Area Tran si t Cocoa, Florida AnneN. Schwarz KETRON Division of The Bionetics Corp. Malvern, Pennsylvania II Kelly Shawn Community T ransportation Association of America Washington, DC Project Manager Robert Carlson P roject ACTION Washington, DC REVIEWERS: Federal Transit Administration Arthur Lopez FTA Office of Civil Rights Washington, DC Service Animal Organizations Alison Schultz Canine Companions for Independence Southeastern Regional Office Orlando, Florida Susan Duncan RN Delta Society National Service Dog Center Renton, Washington

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Exec uti v e S ummar y A wide variety of animals are now being train ed to assist individuals with disabilities. In addition to guide dogs, which assist perso ns who have vision impairm ents, dog s and other animal s are being trained to assist persons who have hearing impairments, mobility lim itations, seizure disorde rs menta l impairments, and other disabilitie s. Recognizing the important role that service animals pla y in helping persons with disabilities to b e more independent the Americans with Disabilities Act of I 990 (ADA) and its implementing regula tions include provisio ns specifi c to their accommo da t ion. Inc luded in t h e ADA regu lations is the right of a person traveling with a service anima l to enjoy equal access to publ ic and private transpo rtation programs. This project r ep r esents nearly two years of research into service animal training policies and practices, public transportation policies and practices, and a review of pertinent laws, regulation s, and literature. The Center for Urban Transportation Research contacted a variety of service animal training cen ters for information. Can ine Companions for Indepe ndence, Inc (CCI) and the D elta Society National Service Dog Cent er provided inval uable advi ce throu g hout the proje ct. Southeastern Guide Dogs provide d additional assistance. Two documents were produced: Assisting PO$sengers Traveling with Service Animals: Final Report and Assisting PO$sengers Traveling with Service Animals: Training Module. The Final Report documen ts the project and describes the issues relating to service animals and the ADA. The Training Module is a self contai ned guide for public transportation personnel to use to train their employees on how to assist pa ssengers trave ling with service anima ls Every effort was made to describe clearly what is required by the ADA and what is not. Nonetheless, because this is an evolving topic, not every issue is completely clear, nor do the "experts" agree in every case on how to handle passengers traveling with service animals. One thing is clear, however; "If it looks like a serv ice animal, and the handler says it is a serv ice animal then welcome the serv ice team aboard." 111

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IV

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T able of C ont e n ts Introduction ... ..... ........ ........ ....................... . ......................... .... . ...... ...... . ....... ...... l Applic able Laws & Regulations ..... ... . ...... .............. .......... ...... .. ............. ..... ... ......... 5 Service Animal Capabilities ................................................................................... I I Transit Policies & Procedures ... .... .... ............................ .................... ......... .... ... ... 25 Co nclusions ....... ................ ........ ....... .... ....... . ...... ....................... .............. ............... 3 5 Reference s Cited .......................... ............ ................ ..... ....... ....... .... ....... ............... 37 A P PEN DI CES Appendix A Append i x B Appendi x C AppendixD Appendix E AppendixF AppendixG AppendixH Commonly Asked Question s About Servi ce Animals in Places of Business Glossary of Terms Service Animal Organ izations & Training Schools Assistance Dog s International (AD I) M ember Programs M inimum Training Standard s A ssistan ce Dogs Int ernat i onal (ADI) Memb er Program s Standard s and Ethics Sample Servic e Animal Policies Sample Driver & Client Directions R esources v

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vi

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Introduction With passage of the Americans w i t h Disabiliti es Act of 1990 (ADA) persons who use ser vice animal s gained new access right s to public and private accommodations, among them the right to use public transportation provided by public and private entities (49 CFR 37.167 ). The purpose of this report, and its companion Training Module, is to clarify the issues related to public transporta tion acces s rights for persons traveling with service animal s including dogs, cats, pigs, monk eys, and other animal s. Service animals are llllt pets. They are individuall y trained to perform specific tasks for their human partners such as guiding someone w i th a visu al impairmen t fetching dropped items pulling a wheelchair, providing signals for person s with hearing impairments or alerting their partner s of an oncoming seizure. For conve nience (and as a function of their jobs) many service animal s wear a harness, cape, or backpack, often with some form of identification. Nonetheless, service animals are not required to be certified or registered, which can make it difficult for drivers to distinguish between a pet and a service animal. The impetus for thi s study came from anecdot es abo ut trans i t and paratr ansit drivers who were afraid of transporting serv i ce dog s or simply did not want to tran sport passengers traveling with service animals. After reviewing trainin g materials provided through several public tran sit training programs, it became I

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clear that there were virtually no training materials available on this topic. The materials in these documents will help to fill that gap This project was conducted by the Center for Urban Transportation Research (CUTR) at the University of South Florida in Tampa. The study was sponsored by Project ACTION, part of the National Easter Seal Society, and funded through a grant from the Federal Transit Administration (FTA). The Final Report includes a descript i on of relevant legislation and regulations at the federal and state levels with respect to access rights for persons with service anima l s. It also includes a description of various types of service animals and information about the scope of training they receive. Further, the Final Report includes examples of service animal po l icies gathered from transit agencies around the country, some of which are "good" and some of which are "bad." The Appendices include a Departmen t of Justice memo responding to frequently asked questions a glossary of terms, a list of service animal training schools, a sample standards and ethics statement, sample recommended minimum training standards, sample service anim a l policies from transit systems, sample driver directions, and a list of related resource materials. 2

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At a minimum the Final Rep o r t shoul d be read by managers, supervi so rs, and tra ine r s who are responsible for ensuri ng that thei r transit and paratransit pers onnel understand and comply with tbe requirement s of the ADA with respect to transporting passengers tra veling w ith s e rvice animals. T he App endices will provide resourc e documents to s upport public tran sporta tion agenci es i n developing better servic e animal policies and procedures. The Trainin g M o dule (a separat e documen t ) include s mate ria ls that may be used by public transportation prov ider s to teach th e ir per so nnel how to assi s t pass eng ers tra vel ing with servi ce animals It include s a train ers' script an d 20 sli des. The Training Module may be taught alon e o r in conjunction with other passenger sensitivi ty or assistan ce techniques training cou rses and may be used toward satisfyi ng the training r equ i reme nts of the ADA (49 CFR 37.17 3). T r ai ners should rea d and be familiar with the Final R eport prior to tea ching the cours e. 3

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4

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Applicable Laws & Regulations Americans with Disabilitie s Act of 1990 The ADA is civil rights legislation. Among other things, the ADA mandate s that: No entity shall disc r imin ate against an individual with a disability in connect ion with th e provision of transp ortati o n service . . an en t ity s hall not. o n the basis of disa bility deny to any individual with a disability the opportunity to us e the e ntity's tran sportation service for the gen e ral public, if the individual is capab le of using that service -49 CF R 37.5(a)(b) Included i n the ADA regulations i s the right of a person traveling with a serv ice a nimal to have equal access to public tran sportation accomm odati ons: 1 (Pu blic and private e ntities providing public t ransp ortat io n ) s hall permit service animals to accompa n y individuals with disabilities in vehicles and facilities. 49 CFR 37. 167 (d) The ADA defines se rvi ce a nimals i n the followin g way: 1The ADA does nol include regulations penaining to air travel. The Ai r Carrier Act of 1986 with final regulations issued in 1990 and updated in 1996 confers similar access rig)lts allowing se<";ce animals to tra vel in the cabin with their human partn ers (see CFR Vol. 61. No. 213, pp. 56420 56422. issued Novembe r I I, 1 996). 5

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Service animal means any guide dog, signal dog, or other animal individually trained to work or perform tasks for 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, pulling a wheelchair, or fetching dropped items. 49 CFR 37.3 Although references to services animals comprise a rel atively small part of the ADA overall, in practice the regulations pose some significant operational issues for public transportation providers. For example, the definition of a service animal is somewhat vague; there are no adopted certification standards by which to know whether an animal truly is a service animal or simply a pet. Further, the ADA does not specifically mention requirements for service animal identification training, animals in training, or penalties for interference with a service animal t eam The identification issue is compounded when a person has a hidden disability (e.g., epilepsy) and travels with a service animal (such as a seizure-response/alert dog or cat). In such cases it could be very hard for a driver to believe the service animal is not a pet. Likewise service animal trainers are not "certified" and may be independent or affiliated with a service animal train ing school. In addition, individuals with disabilities sometimes train their own service animals. These issues and others will be discussed more fully in the section on Service Animal Capabilities and in the Training Module. 6

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Because the ADA is c ivil rights legislation, suits may be filed directly in federal c ourt should an individual believe he or she has been discriminated against under the provisions of the ADA. An individual also may file a complaint directly with the U .S. Department of Justice (DOJ), which handles comp la ints regarding claims of discrimination under Titles II and Ill of the ADA. State Statutes & Regulations Although many access rights are covered by the ADA, state statutes may grant additional rights to persons with disabilities. A booklet published by Assistance Dogs International, Inc. (ADI), includes a lis t of federal and state statutes pertaining to service animals (Roche 1994 f For example, some state statutes further define issues such as what constitutes interference wit h a service animal team and what the associated penalties will be if someone interferes with the access rights of a person with a service animal. In 1996, the U.S. Attorney General's office prepared a statement responding to frequently asked questions about access rights for service animals. The statement was localized and reissued through state level attorneys general. A copy of that document, "Commonly Asked Questions Abou t Service Animals in Places of 'Because the material in the booklet i s several years old, current statu tes and rules should be checked to determine whether there have been changes since its publication. 7

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Business," d istributed in Flor id a in July 1996, i s inc l uded in Appendix A. Similar docu m ents s hould be available from the attorney general's office in each state. The Florida version includes answers to the following quest i ons (see Appendix A for complete text): 1. What are the laws that apply to my business? The answer li s t s applicable federal (ADA) and sta t e statutes and regu l ations In F lo rida, for ex am ple, a vio lat ions o f access laws incurs a second-degree misdemeanor, which may lead to incarceration and/or a criminal fine. Civil penalties for mental anguish, loss of dignity, and other tangib l e injuries are cover e d. Florida law provides for punitive damages of up to $100,000. 2. What is a service animal ? The memo d escribes a service animal, as defined by th e ADA, and clarifies that they do not have to be "certifi e d" s e rv i ce animals. 3. How can I tell if an animal is reall y a service animal and not just a pet? This section points out that some, but not all, service anima l s have certification or identification pape r s It a l so states that you ma y JlQl insist on proof of certification, even if some s t ates have certification programs. 4. What must I do wh e n an individual with a service animal comes to my business? Service animals must be permitted in all areas where customers may go. 5. I have always had a clearly posted "no pet s policy at my establishment. Do I still have to allow service animals in ? 8

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Yes. Service animals are not pets. 6 My county health d e p a rtmen t has told me t h a t o nly a seeing eye or gui d e dog has to be admitted. [f I f o ll ow those regulations, am I violat in g the ADA? Y es. Any type of service animal must be allowe d The ADA takes priority ove r local or state laws or regul ations. 7. Can 1 charge a maintenance o r c l eaning fee for custo me rs who brin g se rvice anim als into m y business? No. However, a public accommodation may charge a customer with a disability if his or her service animal causes damage, as long as it is the regular practice of the entity to charge non-disabl ed customers for the same type of damage. 8. I operat e a private taxicab and I don't want a nimals in my taxi; they s mell, shed hair and so metime s hav e "accidents." Am I violating t h e ADA if I refu se t o pick up som eone wit h a service anim al? Y es. 9. Am I r es p o n sib l e for the animal w hil e the person with a disa b ility i s in my bus in ess? No. 10. W hat if a serv ic e a nimal barks o r g r o wl s at other people, or othenovise acts out of control? Any anima l including a service anima l may be excluded when the anima l 's behavior pose s a direct threat to the health or sa fety of others. However, 9

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you may not assume t hat a particular animal is likely to be h ave b adly, based on expe ri e n ce with othe r animals 11. Can I excl ude an anim a l th a t d oes n't really see m dan gerous but i s disrup ti ve t o my business? There may be a few circumstances when a public accommodation is not required to accommodate a service animal if it would fundamentally a l ter the nature of the business. An exa mple would be a dog that barks during a movie. (See Question No. 10.) Summary This sec t i on provided a br ief overview of applicable laws and regulations pertaining to access rights of persons with disabilities and their service animals. Although service animals are defined in the ADA, there are no criteria requir i ng identificat i on or certification of a service a n imal. F urther, public enti ties are proh i bi t ed from requiring certification of a service ani mal for the purp ose of access This l ack of universally re c ognized standards has made it difficult to distinguish between service animals and pets in some cases. The next section de s cribes service ani ma l s a n d thei r capabilities, which may help to make it eas ie r to dist i nguish between a pet and service animal. 10

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Service Animal Capabilities Background Service an imals are used to assist persons with disabilities including those with visual impairments, hearing impairm ents, mobility impai rments epilep sy, rheumatoid arthr itis, and other physical disabilities. Service anima ls also may be trained to assist persons with mental disabilities. This section presents an overview of service animals (sometimes called assistance animals) and their capab i lities. It includes a description of types of service animals and the training h 3 t ey recetve. Types of Service Animals There are many typ es of service animals inc l uding: Guide dogs ( or dog guides) for persons who have visual impa i rments. Service animals (e.g., dogs, cats, monkeys, pigs) for persons who have physical disabilities. The term service animal ("assistance animal" or "assist ive animal ) is somewhat generic and someti mes is used to describ e all type s of anima l s individually trained to provide assistance to persons with disabilit ies The t erm "service a nim al also is used more specifically to describe animals that assist per sons with mobility limitations, e specially persons using wheelchairs. I 1

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Hearing and signal animals (e.g., dogs and cats) for persons who are deaf or have hearing impairments Seizure-response/alert animals (e.g., dogs, cats, birds) that alert individuals with seizure disorders to oncoming seizures and/or help the individual during and following the seizure. Emotional support animals (e.g., dogs and cats) that provide assistance for persons with severe emotional impairments or mental disabilities. Dogs are by far the most common type of service animal. However, cats pot bellied pigs, monkeys, and birds also are trained as service animals Some dogs also are cross-trained to provide a combination of assistance, such as guiding a visually impaired person while pulling his or her wheelchair. Guide Dogs Most people are familiar with dogs that have been trained to guide persons who are visually impaired The first guide dog in the United States was trained in the 1920s at The Seeing Eye, Inc in Morristown, New Jersey. For many years T he Seeing Eye was the only training school for guide dogs in this country, which is why is it common (although incorrect) to hear guide dogs called "seeing eye dogs." T h e correct term is "guide dog" (or "dog guide") (see Appendix B for a glossary of term s) In fact, now there are many schools that train guide dogs for 12

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TO: :--IATIONAL RESEARCH COUNCIL TRANSPORTATION RESEARCH BOARD January 8. 1998 \hUAoU '""' \\1, ()(Ike f...oution. ... "' o .c. TotltJf!eftt 1M2) ru fl 1"''m" FROM : Chairman and Member s ofl>roject Panel H-10 Transit Cooperative Research Program Dianne S. Schwager Senior Program Officer. TCRP D v---e.> SUBJECT : Review of the I nter i m Repor t for TCRP Project H -10. FY '95 Funding Srraiegies for Publi c Transpona rion In l ate December. yo u should have received a rev i sed int erim repon Costs of ;t:: \ Revisited : The Ev i dence of Sprawl's Negative and Positive Impacrs" directly from th e ( '3 j researcher. Or. Burcheile. (If you have not r eceived this report, please call me.} I am now asking for you to review the report complete the enc losed ballot and prepare any written comments. as necessary. We will assemble the panel's comme nts and inform you of the publication decision. Your review of the report is very much appreciated. Should you have any questions or need additiona l informa tion. please do not hes itate t o call me at 202/334-2969 Please return your ballot and comments to me by FAX on or before .January 30, 1998. My FAX number is 202-334-2006. Enclosures : Ballot/Comment F orm .., .. ,..D I -. # : rr.-&.MJ T{(BJ ""tiiiiM' .. ,"l..tMfllll Kntwt,_ Gll."'-.1. 01ii1Cb tS w .,.. ., tW twpOflNr ltUttl.,ti!IN t11111 tllrl.uda ,V..tJ(>fflll '" S.oiww. N.ttM.VI A.'akllf!' (""f;lfltWIIII ,'(. .-.1 tht IMlmu of MditJ-.

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people who have visual impairments (see Appendix C for a list of service animal training schools). Guide dogs are trained to lead their handlers around obstacles and to protect them from dangero u s situations. Guide dogs are taught what is sometimes called, "inte lli gence disobedience"; that is, a guide dog will refuse to carry out a command that puts its handler in danger (e.g., crossing in front of a car). Many breeds are used as guide dogs including Labrador Retrievers, Golden Retrievers, German Shepherds, Australian Shepherds, Collies, mixed breeds, and others. Most guide dogs are outfitted with a collar leash, leather harness, and sti ff h andle. Verbal commands (e.g., "forward" and "find the door" ) are given to instruct the dog. Handlers us e both a leash and harness to maintain control of the dog No one other than the dog's handler should instruct the dog, unless asked to do so by the handler B e cause the public is fairly fami liar with guide dogs, they are generally easily recognized and r eadily admitted to pub li c facilities, including public transportation vehicles and facili t ies. Service Animals In this context, s er vice animals refer to dogs, monkeys, pigs, and other animals that are trained to assist persons with mobi lit y limi t ations in c l uding persons who 13

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use wheelchairs. Many different types of dogs, including mixed breeds, are used as service dogs, depending on the functions they w ill perform. Service animals provide assistance in a number of ways. They may be taught to retrieve dropped items, pick up papers, pull their partner's wheelchair, and carry items. For example a service dog may carry a worker's briefcase in its mouth, placing it within reach upon arriving at the destination. Service animals also are trained to push elevator buttons, turn light switches off and on, open doors, and to retrieve groceries from a store shelf. Service animals may provide several types of assistance, particularly if the human partner has multiple disabilities such as a visual impairment and a mobility impairment. Although there are no legal requirements for service dog certification or identification, Assistance Dogs International (ADI) has developed minimum training standards for its member organizations to follow (see Appendix D). Assistance Dogs International requires that a service dog trained by its member organizations carry a laminated ID card with its pic t ure and the names of the dog and its handler. ADI also requires that a service dog trained by its member organizations wear a collar, leash, and cape or backpack, which must bear the logo of t he training center and clearly state the animal is a service animal. 14

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When questioned about whether public transit prov i ders can require service an i mals to carry identification and wear capes, harnesses backpacks, or other identification, the Federal Transit Administration responded that such a requirement may be i n conflict with the ADA, citing 49 CFR 37.5(d) of the regulation, which states: "an entity shall not impose special charges ... on individuals with disabilities." Thus, although many service animals will bear this type of identification, not all will. Given that identification is nQt required it is illegal to require a person with a service animal to provide proof that the animal is a service animal; however, you may ask "Is this a service animal?" Monkeys also are sometimes used as service animals. They are taught to perform many of the same functions as service dogs, such as retrieving dropped items, and can also be taught to open packages and jars, and to provide assistance with eating and other tacks of daily living. Monkeys are seldom seen on transit vehicles, although a bus system in Florida reports that it has a passenger who travels with a monkey, who deposits the fare into the fare box. As with service dogs, a monkey should have a harness or leash (or be kept in a carrier) so that it is under the control of its handler at all times. Pigs are very smart and are sometimes used as service animals. Pot bellied pigs are small and favored as service animals by persons who are allergic to dogs. The 15

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New York City Transit Authority has a passenger who travels with a service pig (TD Safety & Access Report 1995) Hearing or Signal Animals Hearing animals are usually dogs; however, cats also have been trained as hearing animals. Hearing animals are trained to respond to sounds their human partners cannot hear. For example, a hearing dog can be trained to respond to telephones, doorbells, alarm clocks, crying babies fire alarms, car horns, sirens, and other sounds. Heating animals alert their partners by physically contacting them and/or leading them to the source of the sound. As is the case w it h other service animals, a variety of breeds are used as hearing dogs, often not fitting the stereotype Labrador Retriever or Golden Retriever some people may expect to be used as a service animal. For example, Canine Companions for Independence (CCI) sometimes uses Pembroke Welsh Corgis and, in the past, has trained Border Collies and Shelties. Other schools use Poodles or Terriers. The San Francisco SPCA (Society for the Prevention of Cruelty to Animals) Hearing Dog Program rescues dogs from the animal shelter to train as hearing dogs. In the past 15 years, that program has trained more than 450 hearing dogs (Eames and Eames 1995). 16

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Although there are no legal requirements for hearing dog certification or identificat ion, Assistance Dogs International, Inc., has developed minimum training standards for its member organizations to follow (see Appendix D). Assistance Dogs In ternational requires that a hearing dog trained by its member organizations carry a laminated ID card with its picture and the names of the dog and its handler. Assistance Dogs International also requires that a hearing dog trained by its member organizations wear an orange collar, leash, and cape with the words "hearing dog" stitched or printed on them. Although many hearing dogs will have this type of identification, not all will. Given that iden t ifica tion is !lQt required, it is unlawful to require a person with a hearing dog (or cat) to provide proof that the animal is a service animal. With respect to cats, their use as hearing animals is a more recent innovation. Public transit drivers should expect to see h ea ring cats on their vehicles. Cats ei ther are carried in a carrier or harnessed on a leash. Because persons with hearing impairments may not be readily recognized, people with hearing dogs and cats have faced tremendous obstacles concerning access, which is compounded by communication problems associated with their hearing impairments. You may ask, "Is this a service animal?" 17

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Seizure-response/alert Animals A seizure-response/alert animal senses when its human partner is about to have a seizure. No one is exactly sure how some animals know that a seizure is imminent. It may be a change in scent, behavior or something else. In addition to alerting its owner abou t an oncoming episode, se i zu re -response/alert dogs may be trained to stay with the person during a seizure, seek help, help the person become reoriented following the sei z ure or provide mobility assistance. Seizure response/alert dogs also may be trained to fetch medication or press a medical alert button i f the person is unable to do so him or herself. Sometimes other animals are used as seizure -response/a lert animals including cats and birds There also is evidence that some snakes or iguanas may be capable of detecting som eone about to have a seizure; however, it is not clear whether these animals would really qualify as a service animal. Seizure-response/alert animals are among the most difficult for a transit driver to identify, particularly because their handlers often have hidden disab i lities (e.g., epilepsy). 18

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Emotional Support Animals Probably the bigger discussion point concerning service animals has to do with whether emotional support animals are service animals or social animals/pets. This is an important distinction because service animals have access rights under the ADA, but social animals and pets do not. Emotional support animals are used to assist persons with mental disabilities (e.g., autism or severe psychological problems), who use the assistance of a trained service anima l to function independently. In contrast, therapy animals, facility animals, and other social animals typically receive obedience training ; however, they are not specifically trained to perform a function for a particular person with a disability and, therefore, are not considered to be s ervice animals. These types of animal s would not be afforded access rights under the ADA.4 Some transit systems (e.g., Chicago Transit Authority) have elected to allow therapy animals onboard buses and trains, if they have proper identification from local training facilities. (Although service animals may not be required to have an 4 Acce-% rights dep end on whether the person has a disabili ty and is prot ected by the Americans with Disa b ilities Act AND whether the animal meets the definition of a service animal. 19

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ID or certification document, therapy and facility animals not covered by the ADA can be required to have this type of proof, if desired.) The question to ask is whether the animal is a service animal. If the answer is yes then the service anima l team must be transported. For now, until further guidance is offered by law or regulation, it is better to err on the side of the ADA and allow access Typical Assistance Dog Training There are no universally accepted methods for training or certifying assistance dogs. However, Assistance Dogs International has developed minimum training standards for its member organizations to follow (see Appendix D). In addition to the training requirements, ADI has developed a Code of Standards and Ethics for its members and is creating minimum requirements for assistance dog partners and assistance dog trainers (see Appendix E). Although there are no set training criteria, servi ce dogs, guide dogs, and hearing dogs trained by assistance animal schoo ls do go through a similar pattern of training, as described below. 20

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Puppy Raisers Puppies are given to volunteer puppy raisers, who w ill care for them until they are old enough to begin advanced training. During this phase, the puppies might be taken to obedience training to learn basic obedience commands such as sit, stay, heel down, and come here. At the same time, they are socialized with other dogs and people. Some puppy raisers take their puppi e s with them to school or work T hroughout this phase the intent is to expose the dog to as many different experiences as possible so that i t will be well-mannered and not easily distracted by new sights, sounds, and smells. Play t ime and quiet time also is included in puppy training. The puppies sleep in the puppy raiser's bedroom. When in public, these puppies often wear capes identifying them as puppies in training. Some state laws allow puppies in training to have access to public accommodations including public transportation, but this v aries by state (Roche 1994 ). Sam Trans specifically notes tha t 4-H club members serve as puppy raisers and should be allowed access onto Sam Trans' vehicle s (see Sam Trans' Draft Service Animal Policy included in Appendix F). 21

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Training Puppies are returned to t he training school to receive their assistance dog training. They are carefully evaluated to test their temperament and natural abilities. Dogs intended for service animal training are spayed or neutered. Dogs selected to continue in the t rain ing program spend additional time learning to perform specific tasks (e.g., guiding a person who is blind r esponding to doorb ell s and tel e phones, fetching dropped items, pulling a wheelchair). Not eve r y dog makes it through the training p r ogram, either because of temperament, health or physical problems. Placement After a serv ice dog completes it s training program, it is matched with a human partner. Trainers attempt to match skills, physica l size, and personality types of both the dog and human. Teams are t hen trained together for up to several weeks (or longer if needed) so t hat they can bond and learn how to work with each other and develop proper public etiquette. During th is phase th e person also learns about carin g for his or her dog, including veterinary care requirements, flea and tick control, grooming, and good n utrit i on Once t he trai ner is satisfied the pai r has suffic iently bonded and learned to work together, the team graduates. Some training organizations provide annual follow-up e valuations to ensure that no bad 22

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habits have developed and to correc t any training deficiencies. At that time they also ca n retrain the dog or perso n if a person's functio n a l abilities hav e c h anged. Certificatio n I ssues a n d t h e Prob lem of"Fake s" For the past several years Assistance Do gs International and its member organizat ions have been working to develop a standa r dize d public acce ss test for assistance dog s Canine Comp anions for Ind ependence an d other ADl-member training schools have been volun tarily using the test as part of the graduation requirement and follow-up for their programs. Participating programs report the pass/fail rates and test results to ADI as a mean s of validating the test. A cons iderable amount of discussion and debate takes place on the I nternet concernin g assistance dogs and requirements for training (see Internet and E-ma i I references in Appendix H). There is a sense of concern among assistance dog users that "fakes" as they call them, will ruin it for "legitim ate assistanc e animal users by bringing poorly trained pets or therapy animals into public facilities. Summary The purpose of this section was to describe service animals and the tasks they can perform. Keep in mind that not all persons with disabilities will be easily 23

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identified because of hidden disabilities (e g., epilepsy or hearing impairments). Also some service animals may provide assistance to persons who have multiple disabi l ities. In that case, the service animal may be trained to provide a combination of functions. For example, a person who is visually impaired and uses a wheelchair may depend on a service dog both for guidance and to pull the wheelchair. Likewise, someone who has a hearing impairment and a mobility limitation may have a hearing dog that does not provide functional assistance for his or her mobility limitation The discussion in this section has centered on dogs because they are the most common service animals. As stated above, cats, monkeys, pigs, birds, and other animals also are trained as service anima l s. T heir training is somewhat different. Service animals may be trained by training schools, independent trainers, or self trained by persons who have disabilities. The bottom line is if an animal is trained to perform tasks associated w i th assisting a person with a disability, i t is a service animal and is afforded access rights under the ADA. Animals that are present simply to provide companionship are considered to be therapy or social animals, and do not appear to have access rights under the ADA. The next section addresses issues of implementing the ADA requirements. 24

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Transit Policies & Procedures The previous section provided information about service animals, t heir training, and what can be expected from a trained service animal team. This section describes what public transportation providers can do to implement the ADA requirements for transporting persons with disabilities who travel with s e rvice animals. It also suggests ways to addre ss service animals through appropriate agency policies and procedures. Implementation Issues and Answers Implementing public policy directives, including the service animal provisions of the ADA, is not always easy. For public transportation providers, a whole host of issues arises: How do I know if it's a service animal? What am I supposed to do when a service animal team boards the train, bus or van? What if a driver is allergic to dogs (or cats)? What if the animal has an accident onboard the vehicle? What if the dog leaves dog hair or fleas behind? What if the animal bites someone? What if ... ? These issues fall into four basic categories: ( 1) identification of service animals, (2) health concerns, (3) safety issues, and ( 4) passenger assistance. Each will be discussed below. 25

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Identification As stated earlier, the ADA defines generally what a service animal is and does, but fails to address how to identify service animals. As a resu lt, public transportation providers and other public entities have been left on their own to figure out how to iden ti fy a service animal. The public advisory issued by DOJ, reprin ted in Appendix A, provides some guidance on this topic: The ADA defines a service animal as dog, signal dog, or othe r animal individually trained to provide assistance to an individual with a disability If they meet this definition, animals are considered service animals un der the ADA regardless of whether they have been licensed or certified by a state or local government .... A service animal is l1Ql a pet .... Some but not all, service animals wear special collars and harnesses. Some, but not all are licensed or certified and have identification papers. If you are not certain that an animal is a service animal, you may ask the person who has the animal if it is a service animal required because of a disability ... Although a number of states have programs to certify service animals, you may not insist on proof of state certification before permitting the service animal to accompany the person with a disability. Thus, some service animals will have ide ntificat ion and/or cert ificatio n papers issued by a train ing program. Although having an 10 card may make it easier for 26

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drivers to identify a service animal, the lack of an ID card in no way implies the animal is not a service animal. If in doubt, ask: "Is this a service animal?" Some transit agencies have requested that the service animal appear with its handler in the discount or paratransit identification card photograph. Although this approach would certainly help to verify for the driver that the animal in the photograph is a service animal, it is not clear that public transportation systems can legally require the animal to be photographed with the passenger. This is one of the issues yet to be fully resolved. As in any unregulated industry, there is a potential for abuse by those who represent themselves as traveling with a service animal when, in fact, the animal is not a service animal In some respects, this is one of the most talked about issues, not only for public entities, but also for persons with service animals who are concerned that "fakes," as they call them, will ruin it for "legitimate" service animal users. Even if there were regulations in place to certify service animals, abusers would find a way to beat the system. I fin doubt, ask: I s this a service animal?" If the pe r son says it's a service animal and the animal is under the control of the handler, then treat them as a service animal team and welcome them aboard. 27

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Health Concern s During the research for this project, transit personnel expressed a great deal of concern over health an d safety issues related to service animals. One set of concerns centers on issues related to "accidents" or damag e onboard vehicles; hair an d dander; fleas ticks or other pests; and what to do if drivers (or ot her passe ngers) are aller gic to animal s. During the i r training, service animals are soc i alized and taught not to r elieve themselves in public facilities. Occas i onally a will occu r and it is the responsi b ili t y of the passenger to clean up any mess associated wit h a service a nimal that has had a n "acci dent'' on board a vehicle or in a faci lity. According to the D OJ P olicy Advi sory, included in App endix A: . a public accommodation may charge its customers with disabilities if a service animal causes damage as long as it is the regular practice of the entity to charge non-disabled customers for the same type of damages. So me training progr a m s teach their stud ents how to ca r e for their service a nimals with respect to ve t e rin ary needs, feeding, and g r oomin g. F le a and tick prevention is taught and with new product s a vai lable to reduce or eliminate ticks and fleas, service animals should be virtually pest free. Some paratransit operators have servic e animals sit or lie on a shee t or towel so that hair and dirt can be easily 28

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removed after the animal leaves the vehicle (remember, servic e animals should ride on the floor of the vehicle or be in a secure carrier). In an extreme case, if the driver notices an anima l appears to be poorly cared for and poses a health concern, con t act the local animal control board or the school where the animal was trained and report the incident. Allergies generally should not be problematic for fixed route drivers who have liule direct contact with service animals. The issue may be more critical fo r paratransit drivers who come into closer contact with service animals and passengers onboard their vehicles. Paratransit drivers who are allergic to animals should not be assigned to transport passengers traveling with service animals. Similarly, it appears to be reasonable that when making a r e se rvation a paratran s it passenger sho uld be required to notify the sys tem that he or she will be traveling with a service animal. This practice will avoid problems with drivers who are allergic to animals. It also will allow schedulers to consider space req uirements and load factors for vehicles transporting service animals (remember the animal i s to sit or lie on the floor of the vehicle or be in a carrier). Finally, it will help the driver to know that a service animal will be transported if i t is noted on the manifest (in the same way a person requiring use of a wheelchair lift is indicated on a manifest). 29

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The bottom line is that the ADA requires public transportation entities to provide access to persons with disabiliti es who a r e traveling with service anim als. Minimi zing poten tial problem s by training and de v elo ping proactive writte n policies and procedu res will he lp transit personnel (especially drivers) to bette r assist passengers traveling with service animals and will avoid cost l y legal fees that might be incurred as a result of wrongfully den ying service to someone traveling with a service animal. S afety Issues Another set of concerns focused on safety issues relati ng to liability if a service animal caused injury to another animal or person Remember: service animals are sociali zed and traine d to i nteract appropria t ely with other animals and people. Nonet hele ss, it is possible that a service anima l cou ld be provoked and become agg ressive. Accordin g to the DOJ P olicy Advisory, included in App endix A: You may exclude any animal, including a service animal from your facility when the animal's behavior poses a direct threat to the heclth or safety of others. For example any service animal that displays vicious behavior towards other guests or customers may be excluded. You may not make ass ump tions, however, about how a particular animal is likely to behave based on your past exper iences with other ani mals Each situation must be considered individually. The best practice is to develop a written policy regarding service animals that includes directions for drivers on how to cope with service animals if the animal becomes aggressive. Some transit agencies have included this t ype of information 30

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in their operators' procedures (see Sam Trans Draft Service Animal Po licy included in Appendix F ). Again developing proactive policies and applying them fairly and consistently will aid the driver and the system. Being reactionary in response to a situation without benefit of written guidelines could create serious problems for a transit agency and end up in court. Keep in mind, too, that control of the service animal is the responsibility of the animal's handler. The DOJ Policy Advisory found in Appendix A states: The care and supervision of a service animal is solely the responsibility of his or her owner. You are not required to provide care or food or special location for the animal. I f an incident occurs and the public transportation entity has followed proper standard policies and procedures for transporting service animals, then accountability for damages or injuries should remain with the person responsible fo r the dog. A transit agency may wish to seek its own lega l counsel on this point and develop written practices that address this type of occurrence. This is a good example of an i tem that could be included in a pamphlet on rider rights and responsibilities. Remember the o ld adage, "an ounce of prevention is worth a pound of cure." Proper written policies and procedures, and ongoing training of transit personnel will help to avert problems before they occur. Remember: the goal 31

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is to transport all passengers safely to their destinations--including those traveling with service animals. Passenger Assistance One of the goals ofthis projec t was to develop a set of instructions drivers could use to assist passengers with disabilities who were traveling with service animals. Not surprisingly, there appears to be no one "best" way to assist passengers who have disabilities and travel with service animals. Persons who have disabilities have varying degrees of capabilities. The same is true for service animal users. Some will be very independent and require little or no driver assistance. Others will be more in need of assistance. Different service animal trainers also teach different methods for boarding and alighting from transit vehicles, often tailored to meet the needs of the individual and his or her service animal. There are a few general rules that should be followed: Do not stereotype passengers based on their disabilities. F or example, do not assume that all persons with visual impairments require the same level of assistance. Ask the passenger what you can do to assist. 32

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Do not touch or give the service animal any commands unless asked to do so by its handler. If necessary, remind passengers that the service anima l i s working and not to distract it. A service anima l might board and a li ght with the passenger if the passenger is ambulatory. A service animal might board firs t and alight after the passenger if the p ass enger is using a wheelchair. In most cases, because of safety concerns, service animals should not be allowed to ride on wheelchair lifts. Their tails, paws, heads or equipment may catch in the lift mechanism, causing severe injury to the animal. An e x ception migh t be a standee traveling with a service animal who boards using a lift. Service animals shou l d sit or lie on the floor. Anima ls should not occupy a passenger seat. Service animals should not block the passenger aisle. Remember some people have hidden disabilities, making it hard to know the person has a disability and even harder to identify a service animal. Ask if the animal is a service animal. You may not require identification or proof that an an i mal is a service animal. You may ask, "Is this a service animal?" The best advice is c ommon sense and courtesy. Avoid confrontations and call dispatch if there is a problem or question. 33

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Additional information on assisting passengers is included in the Training Module. 34

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Conclusions This document and its companion Training Module were written to present information on how public transportation entities can better identify and assist passengers with disabilit i es who t ravel with service animals. This project was written in response to concerns voiced by transit agencies reacting to the service animal provisions included in the Americans with Di sabi.lities Act. The ADA represents civil rights law, which takes precedence over other state and local laws, regulations or ordinances. Seven years after passage of the ADA, much remains to be done to make public transportation systems more user-friendly and accessible for all passengers, including persons traveling with service animals. Transit policies still exist that only cite access rights for guide dogs (often incorrectly termed "seeing -eye dogs ). Many transit policies do not acknowledge the v ariety of animals now used as service animal s and the multitude of tasks they can be tmined to perform There is very little information provided in pas senger assi stance or sensitivity courses dealing specifically with service animals. The approach taken here is meant to be positive and supportive of providing the best possible public transportation service for persons with disabilities who trave l with service animals. The information presented here is intended to serve as a bridge between ADA policy and im plementation--not always an easy task! 35

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Rather than being reactive, the purpose of this doc umen t is to be proactive The aim is to educate public transportation personnel about service animals and the persons with disabilities who depend on t hem for greater independence and an improved quality of life. By understanding how service animals are trained and used, transit personnel will be able to develop a better understanding of how to assist passengers who travel with service animals. By using these materials and reviewing their own policies and procedures, public transportation entities should possess enough information to develop appropriate policies and procedures that will aid their employees in knowing how to assist passengers traveling with service animals. Remember: Access for persons with disabilities who are traveling with service animals is not only a civil r ight, but it's the right thing to do. If it looks like a service animal, And the passenger says it's a service animal, Then welcome aboard the service animal team! 36

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References Cited5 Eames, Ed and Toni Eames 1995 Partners in Independence Dog World 80(5):50-52. Roche, Michael P. 199 4 Legal Rights of Guide Dogs, Hearing Dogs and Service Dogs. Lakewood CO: Assistance Dogs International. TD Safety & Access Report 199 5 Pig Travels as Service An i mal on NYCTA Bus. TD Safety & Access Report 3(7) : 4 -5. 'A complete l is t of resources is inc luded in Appendix H. 37

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38

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Appendix A Appendix B AppendixC Appendix D Appendix E Appendix F Appendix G Appendix H Appendices Commonly Asked Questions About Service Animals in Places of Business Glossary of T erms Service Animal Organizations & Training Schools Assistance Dogs International (AD!): All Member Programs Minimum Training Standards Assistance Dogs International (AD!): All Member Programs Standards and Ethics Sample Service Anima l Pol icies Sample Driver & Client Directions Resources

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Appendix A Commonly Asked Questions In July 1996, the Florida Office of the Attorney General issued the attached public advisory regarding Service Animals in Places of Business. Similar statements were issued in other states A-I

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A -2

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State of Florida Office of the Attorney Generol SUBJECT: Commonly Asked Questions About Service Animals in Places of Business 6 Public Advisories CATEGORY: DATE ENTERED: 07125/96 l. Q: What are the law s that apply to m y bu s iness? A: Under the Americans with Disabilit ies Act (ADA), privately owned businesses that serve the public such as restaurants, hot e ls, retail stores taxicabs, theat ers, concert halls, and sports facilities, are prohibit ed from discriminatin g against individuals with disabilities. The ADA requires these businesses to allow people with disabilities to bring their service animals onto business premises in whatever a r eas customers are generally allowed. Under Florida Jaw, the blind and all other physically disabled persons who use guide dog s or service animals are entitled to equal acc ess, without extra charge, to all common carriers, airplan es, motor vehicles, railroad trains, motor buse s, streetcars, boats, and other public conveyances or modes of transportation, and at hotels, lodging places, restaurants, places of public accommodation, amusement or resort and other places to which the general public is invited Violation of this law is a second degree misdemeanor which may result in incarceration and/or a criminal fine. Additionally violation of this law may result in civil penalties for mental anguish, loss of dignity and any other tangible injuries. Florida law also provid es for punitive damag es not to exceed $100 000 See Sect ion 413.08 Florida Statutes 2. Q: What i s a service animal? A: The ADA defines a service animal guide dog, signal dog, or othe r animal individually trained to provide assistance to an individual with a disability. If they meet this definition animals are considered service A-3

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animals under the ADA regard le ss of whether they have been licensed or certified by a state or local government. Service animals perform some of the functions and tasks that the individual with a disability cannot perform for him or herself. "Seeing eye dogs" are one t ype of service animal, used by some individuals who are blind. This is the type of service animal with which most people are familiar. But there are service animals that assist persons with other kinds of disabilities in their day-to-day activities. Some examples inc lude: Alerting persons with hearing impairments to sounds. Pulling wheelchairs or carrying and picking up things for persons with mobility impairments. Assisting persons with mobility impairments with balance. A service animal is llil1 a pet. 3. Q: How can I tell if an animal is really a service animal and not just a pet? A: Some, but not all, service animals wear special collars and harnesses. Some, but not all, are licensed or certified and have identification papers. I f you are not certain that an animal is a service animal, you may ask the person who has the animal if it is a service animal required because of a disabil i ty. However, an individual who is going to a restaurant or theater is not likely to be carrying documentation to his or her medical condition or disability. Therefore, such documentation generally may not be required as a condition for providing service to an i ndividual accompanied by a service animal. Although a number of states have programs to certify service animals, you may not insist on proof of state certification before permitting the service animal to accompany the person with a disability. 4 Q: What must I do when an individual with a service animal comes to my business? A-4

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A: The service animal must be permitted to accompany the individual with a disability to all areas of the facility where customers are normally allowed to go. An individual with a service animal may not be segregated from other cu stomers 5. Q: I have always had a clearly posted "no pets" policy at my establishment. Do I still have to allow service animals in? A: Yes. A service animal is llQ1 a pet. The ADA requires you to modify your "no pets" policy to allow the use of a service animal by a person with a disability. This does not mean you must abandon your "no pets" policy altogether but simply that you must make an exception to your general rul e for service animals. 6. Q: My county health department has told me that only a seeing eye or guide dog has to be admitted. If I follow those regulations, am I violating the ADA? A: Yes, if you refuse to admit any other type of service animal on the basis oflocal health department regulations or other state or local laws The ADA providers greater protection for individuals with disabilities and so it takes priority over the local or state laws or regulations. 7. Q: Can I charge a maintenance or cleaning fee for customers who bring service animals into my business? A: No. N e i ther a depos it no r a s u r charge may be imposed on an individual with a d i sability as a condition of allowing a service anim al to accompany the individual with a disabili ty, even if deposits are routinely required for pets. However, a public accommodation may charge its customers with disabilities if a service animal causes damage as long as it is the regular practice of the en tity to charge non-disabled customers for the same types of damages. Fo r example, a hotel can charge a guest with a disability for the A-5

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costs of repairing or cleaning furniture damaged by a service animal if it is the hotel's policy to charge when non-disabled guests cause such damage. 8. Q: I operate a private taxicab and I don t want animals in my taxi; they smell, shed hair and sometimes have "accidents." Am I violating the ADA if I refuse to pick up someone with a service animal? A: Yes. Taxicab companies may not refuse to provide services to individuals with disabilities. Private taxicab companies are also prohibited from charging higher fares or fees for transporting individuals with disabilities and their service animals that they charge to other persons for the same or equivalent service. 9. Q: Am I responsible for the animal while the person with a disability is in my business? A: No The care or supervision of a service animal is solely the responsibility of his or her owner. You are not required to provide care or food or a special location for the animal. 10. Q: What if a service animal barks or growls at other people, or otherwise acts out of control? A: You may exclude any animal, including a service animal, from your facility when the animal's behavior poses a direct threat to the hea lt h or safety of others. For example, any service animal that displays vicious behavior towards other guests or customers may be excluded. You may not make assumptions, howeve r about how a particular animal is likely to behave based on your past experiences with other animals. Each situation must be considered individually. 11. Q: Can I exclude an animal that doesn't really seem dangerous but i s disruptive to my business? A-6

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A: There may be a few circumstances when a public accommodation is not required to accommodate a service animal--that is, when doing so would result in a fundamental alteration to the nature of the business. Generally, this is not lik ely to occur in restaurants, hotels, retail stores, theaters, concert halls, and sports facilities But when it does, for example, when a dog barks during a movie, the animal can be excluded. If you have further questions about service animals or other requirements of the ADA you may call the U.S. Departme nt of Just ice toll-free ADA Information Line at 800-0301 (vo i ce) or 800 14-0383 (TDD). You may also con t ac t Gregory Durden Director of Civil Righ ts Office of the Attorney Genera l State of Florida at (954) 712-4800. DUPLICATION OF TIDS DOCUMENT IS ENCOURAGED A-7

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A 8

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Appendix B Glossary of Terms Glossary of Terms1 ADA-Americans with Disabilities Act of 1990 is civil rights law tha t provides protection a gainst discr imination to persons with disabilities. ADA regu la tions permit service animals to accompany individuals with disabilities in vehicles and facilities ADI-Assistance Dogs International is an organization of assistance dog providers committed to developing standa rd s of training and ethics for the ind ustry. ADI is working to dev elop a certification test to protect individuals from scam artists who provide poo rl y t rai ned animals. Assistance Animals-the appropriate term for all animals providing as s istance to individuals who have disabilities (see also service animals). Facility Dog s -like social animals, facility dogs are used in nu rsin g homes or at other facilities to pro v ide compan i onship to seniors children, or persons with disabi l ities. These dogs do not have access r i g h ts und er t h e p r ovisions of the ADA. Guide Dog s (or Dog Guides)-assist persons who are b lind or visually impaired by guiding them safe l y around obstac les. Note: "Seeing Ey e Dog" is a generic term for guide dogs. "Seeing E ye Dog" should only be used i n reference to dogs that were trained at The Seeing Eye, I nc., training center in Morristown, New Jersey. 'There are many terms used t o describe assist ance/service animals; however, there is no universally adopted glossary ofteml s The -se are some common ones. B-1

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Hearing & Signal Dogs (or Hearing Ear Dogs)-alert persons who are deaf or hearing-impaired to many everyday sounds such as alarms, timers, doorbells, the person's name, crying babies, etc. Some cats also are trained to perform these tasks. These animals have access rights under the provisions of the ADA. IAADP-International Association of Assistance Dog Partners is a national consumer advocacy group composed of people who are blind or visually impaired partnered with guide dogs, people who are deaf/hearing impaired partnered with h earing dogs, and people with physical disabilities partnered with service dog s IAADP is the first cross-d i sability coalition based upon partnership with assistance dogs. Its goals are education legislation, advocacy and mutual support. Intelligent Disobedience-a guide dog will not obey a command that will put its human partner in danger. For example, a guide dog will not cross the street when a car is coming and the dog will block its partner f rom crossing Seizure-response/alert Animals alert their human partners that they are going to have a seizure before it happens A sei z ure dog is trained to take its partner to a "sa fe" p l ace before a seizure, get help, and protect the human partner during a sei z ure. These animals have access rights under the provisions of the ADA. Service Animal .s-usually dogs, these animals are individually trained to perform specific tasks to assist persons wit h disabilities. There is no requirement for formal "certification'' or "registration" of a service animal, although many t raining programs provide identification tags and/or certificates. Most service animals are dogs; however, other animals also may be used (e.g potbellied pigs, monkeys cats, and birds). T hese animals have access rights under the provisions of the ADA. Social Dogs-see therapy animals. Specialty or Combination Dogs are trained to assist people with multiple disabilities (e.g., a person who is visually impaired and uses a wheelchair) These dogs have access rights under the provisions of the ADA. B-2

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Team, Partner or Unit -is the handler and the service dog together. Therapy Animals-often dogs, these animals visit hospitals, care facilities, nursing homes, or provide companionship for individuals. These animals are emo tionally therapeutic and have received some obedience training. These animals do not have access rights under the provisions of the ADA. Work or Working -The team is at work or working when the an imal is in harn ess, vest or backpack, etc. B-3

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B-4

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Appendix C Service Animal Organizations & Training Schools U pdated January 24 199 7 This is a rapidly chan ging industry; new programs enter and leave the market often. Most service animal training schools and organizatio n s are very willing to work with l oca l t ransit age n cies. ASSISTA NCE DOGS: NATIONAL CONTA C TS Assis t a nce Dog s Internat i o n a l c/o Freedom Service Dogs, Inc PO Box 1 50217 Lakewoo d, CO 802 1 5-0217 (303) 23 4 -95 1 2 The Assis tan ce Dog In st it u t e PO Box 2334 R o hnert Park, CA 94927 (707) 585 0300 C anine Compani o n s for Indep e ndence (C C I ) N a t i onal Headquarte r s POBox466 Santa Rosa, CA 95402 0446 ( 800) 572-2275 V/TDD I (707) 528 0830 C-1

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D elta So ciety National Se rvice D og Cente r 289 P erimeter Road East Renton, WA 98055 ( 800) 869-6898 / (20 6 ) 235-1076 / ( 800) 809-2714 TDD Interna ti o nal Association of Assi s ta nce D og Partner s (IAADP ) PO Box 1326 Sterling Heights MI 48311 (81 0) 826-3938 Nationa l Education for Assistance Dog Se rvic es ( NEADS) PO Box 2 1 3 We s t Boyls t on, MA 01583 (50 8 ) 422-9064 Na ti o nal H ea ri ng Dog Center, Inc. 1116 South Main Street Athol, MA 0133 1 (508) 249-92 64 Paw s with a Cause Corporate Offic e 123 5 I OOth Street SE Byron Center MI 49315 (800) 253-7297 (TDDN) I (616) 698 0688 (TDDN) CAPUCHIN MONKEYS H e l p in g Hands Boston Universi ty Schoo l of Medi cine 1505 C ommonwea lth Avenu e Boston, MA 02135 (617) 7874419 C-2

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GUIDE DOGS ARIZONA Eye Dog Foundation of Arizona 8252 South 15th Avenue Phoenix, AZ 85041 (602) 276-0051 CALIFORNIA Guide Dogs for the Blind, Inc. PO Box 151200 San Rafael, CA 94915 (415) 499-4000 Guide Dogs of America 13445 Glenoaks Boulevard Sylmar, CA 91342 (818) 362-5834 Guide Dogs of the Desert PO Box 1692 Palm Springs, CA 92262 (619) 329-6257 CONNECTICUT Fidelco Guide Dog Foundation PO Box 142 Bloomfield, CT 06002 (203) 243-5200 C-3

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FLORIDA S ou thea stern Gui de D o g s Inc. 421 0 77 t h Street E Pal m e tto, F L 3422 1 (8 1 3) 72 9-566 5 KANSAS Kans a s Spec i a l ty D og S ervice, Inc. PO Box 216 W as hington, KS 66968 (9 1 3 ) 325-2256 M I CHIGAN Leader Dogs for th e Blind 1039 S Roches ter Road Rochest e r, MI 48307 (81 0) 65 1 -90 1 1 NEW JERSEY The Seein g E y e In c PO Box375 Morristown, NJ 07963-0375 (20 I) 539 -4 425 NEW YORK Freedom Guide Dogs 1210 Har d scrabble Road Cassvi lle NY 13318 (315) 822 5132 C-4

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Guide Dog Foundation for the Blind, Inc. 371 E Jericho Turnpike Smithtown, NY 11787 (800) 548-4337 I (516) 265-2121 Guiding Eyes for the Blind, Inc. 611 Granite Springs Road Yorktown Heights, NY 10598 (80 0) 942-0149/ (914) 245-4024 Upstate Guide Dog Association, Inc. PO Box 165 Hamlin, NY 14464 (7 I 6) 964-8815 OHIO Pilot Dogs, Inc. 625 W Town Street Columbus, OH 43215 (614) 221-6367 HEARING & SIGNAL DOGS ARIZONA Handi-Dogs, lnc.2 PO Box 12563 Tucson, AZ 85732 (602) 325-6466 'Handi-Dogs t e ac hes peo p l e who are deaf to train their own dogs C-5

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CALIFORNIA Canine Companion s for I ndependence NW Regional Training Center PO Box 446 Santa R osa, CA 95402 (707) 577 -1700 Canine Support Teams P O Box 1329 Perri s, CA 925 721329 (909) 943-3 972 San Francisco SPCA Hearing Dog Prog r a m 2500 16th Street San Francisco, CA 94 10 3 ( 4 15) 55 4 -3020 I ( 415) 554-3022 TDD COLORADO American Humane Association 63 Inv e rness Drive E Englewood, CO 80112 (3 1 3) 792-9 900 International Hearing Dog, Inc. 590 I E 89th A venue H enderson, CO 80640 (303) 287-3277 Mile Hi g h Hearing and Handi D og, In c. POBox Park er, CO 80134 (303) 288-7297 C-6

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T op D og Ro c ky M o untain R egion 1614 W 6th Street Alamosa, CO 81101-2929 (719) 589-0652 CONNECTICUT Connecti cut K-9 Hear ing D og Training 239 Maple Hill Avenue Newington, CT 06111 (203) 666-4646 / (203) 666-4648 TOO Hearing Ear D ogs o f New E n gland Ltd. 420 Groton Long Point Road Groton, CT 06340 (2 03) 446-1576 FLORIDA Florida Dog Guides for the D eaf, Inc. PO Box20662 Bradenton, FL 34203 0662 (800) 520-4589/ (941) 748-8245 I NDIANA Access K -9 Co -Workers PO Box 30142 Indianapolis, IN 46230 (317) 257-3727 Midwe s t Ass i stance Do gs, In c. 3702 W Sample Street South Bend IN 46619 (219) 287-7677 C-7

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MARYLAND Canine Companions PO Bo x 12142 Silver Spring, MD 20908 (301) 460-3040 Fid os for Freedo m Inc. PO Box 5508 Laurel, MD 20726 (410) 880-4178 MASSACHUSETTS Na tion a l Educatio n for Ass istance Dog Services PO Box 213 West Boylston, MA 01583 (508) 422-9064 National Hearing Dog Center, Inc. 1116 S Main Street Athol, MA 01331 (508) 249 -92 64 MICffiGAN Paws with a Cause Corporate Office 1235 I OOth S treet SE Byro n Center, MI 49315 (800) 2 53-729 7 I (6 1 6) 698-0688 C-8

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MINNESOTA Hearing and Service Dogs of Minnesota 2223 E. 35th Street M innea po lis, MN 55407 (617) 729-5986 I (617) 729-5914 TDD NEW YORK Canine Companions for Independence NE Regional Center P0Box205 Fa rmingdale NY 11735-0205 (5 16) 694-6938 Canine Helpers for the Handicapped Inc. 5705 Ridge Road Lockport,NY 14094 (716) 433-4035 Canine Working Companions, Inc. 7558 Gro ton Lake Road Waterville, NY 13480 (315) 861-7770 NORTH CAROLINA Carolina Canine Companions 1609 Pembrook Road Conc ord N C 28025 (704) 455-3776 C-9

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OHIO A ss i s tance Do gs of America In c. 29687 Camoustie Court Perrysburg, OH 43551 ( 419) 666-8799 Lion s Hearin g D ogs, In c 290 North H amilton R oad Gahanna, OH 43230 (617) 471-7397 Lions Hearin g D ogs, Inc. 4623 Pleasant Chapel Newark, OH 4 3055 (614) 5 48 -4447 OKLAHOMA Dogs Ears, Inc. 4200 E. Britt on Ro ad Oklahoma City, OK 73 1 32 ( 405 ) 4 78 -2303 OREGON D ogs for the D ea f 10175 Wheeler Road Cent r al Point, OR 97502 (503) 826-9220 C-10

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SOUTH CAROLINA Carolina Canine Companions 1961 White Oak Road Camden, SC 29020 (803) 432-0004 TEXAS Texas Hearing & Service Dogs, Inc. 13422 Katy Knoll Court Houston, TX 77082 (714) 497-2502 WISCONSIN Okada W 5634 Stearns Road Fontana, WI 53 I 25 (4 1 4) 275-5226 SERVICE (ASSISTANCE) DOGS ARIZONA Companion Animal Association of Arizona PO Box 5006 Scottsdale AZ 85261-5006 (602) 258-3306 Top Dog, Inc. 5315 Eas t Broadway# I 06 Tucson, AZ 85711 (602) 747-4945 C-11

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CALI FORN I A Cani ne C ompanion s for In depe n dence NW R egiona l Training Center POBox446 Santa Rosa, CA 95402 (707) 577-1700 Canine Co mpanion s for Indepe nd e n ce Sac ramento Satellite Offi ce 7610 Auburn Boulevar d Suite 3 Citrus Heights, CA 95610 (9 1 6) 722-4243 Can ine Companions for Independenc e SW R eg i o n a l Traini n g Cen ter P O Box4558 Oceanside, CA 92052 (619) 754-3300 COLORADO Canine C ompanions for Indepe nd ence Co lorado Satellite Offic e I 045-F Ga rden of the Gods Road Co l orado Springs, CO 80907 (719) 260-6151 Freedo m Service D o gs Inc. PO Box 150217 Lakewood, CO 80215-0217 (303) 234-9512 ILLINOI S Canin e Companions for In dependence C h icago Sate llit e Offi ce PO Box 847 G l env i ew, IL 60025 (84 7) 5 59-9346 C-12

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MIN NES OTA Canine Companions for Independence Minnesota Satellite Office Minnesota Satellite 938 Prairie Center Drive #187 E den Prairie, MN 55344 (612) 949-3756 Helping Paws of Minnesota, Inc. 263 86 I 12th Street Aimmerman, MN 55398 (612) 924-2404 MISSOURI Support Dogs, Inc. 3958 Union Road St. Louis, MO 63125 (314) 892-2554 NEW YORK Canine Companions for Independence NE Regional Training Center PO Box 205 Farmingdale NY 11735 (516) 694-6938 VffDD Canine Helpers for the Handicapped Inc. 5705 R idge Road Lockport,NY 14094 (716) 433 4035 Canine Working Companions, Inc. 7558 Groton Lake Road Waterville, NY 13480 (315) 861-7770 C-13

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NORTH CAROLINA Nan hall Training Center 2206 Martin Luther King Drive Greensboro, NC 27406 (91 0) 272-5684 People Animal Linking System (PALS) 716 Charnel Lane Cl ima x, NC 27406 (910) 674-9220 NORTH DAKOTA Great Plains Assistance Dogs Foundation, Inc. POBox 513 Jud,ND 58454 (70 I) 685-2242 OHIO Canine Companions for Independence N C Regional Training Center 4989 State Road 37 E Delaware, OH 43015 (614) 548-4447 V/TDD Happy Canine Helpers, Inc. 16277 Montgomery Road Johnstown, OH 43031 (614) 965-2204 Support Dogs for the Handicapped Inc. PO Box 28457 Columbus OH 43228-0457 (614) 878-2427 C-14

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OKLAHOMA TheraPetics Service Dogs of Oklahoma, Inc. PO Box 701707 Tulsa, OK 74170-1707 (918) 827-6051 OREGON Kings Valley Collies 39968 Ward Road Kings Valley, OR 97361 (503) 929-2100 PENNSYLVANIA Canine Partners for Life #1300 RD2 Cochranville, PA 19330 (610) 869-4902 Independence Dogs, Inc. 146 State Line Road Chaddsford, P A 1931 7 (61 0) 358-2723 Ne w Life Assistance Dogs PO Box 564 Lancaster, PA 17602 (717) 872-2771 Susquehanna Service Dogs 555 Le Sentier Harrisburg, P A 17112 (717) 599-5920 VIRGINIA C-15

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Caring Canine Companions Inc PO Bo x 353 Verona, VA 24482 (540) 248-6655 Virg ini a Canines f o r Independen ce, In c. PO Box 11441 R ic hmond, VA 23230 (804) 288DOGS WASHINGTON Pris on Pet Partnership Prog r a m Washington Correction Center for Women PO B ox 17 Gig Harbor WA 9833 50017 (206) 8584 240 WISCONSIN Wi sco n s in Academy for Graduate Serv i ce Dog s 205 North Main, Suite I 03 J anesville, WI 83545 3062 (608) 757-1171 CANADIAN C ONTACTS B C. Interact #250167 W 2nd Avenue Vancouver, BC V5Y IB8 (604) 8 7 9-5991 C-16

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Canadian Guide Dogs for the Blind POBox280 Manotick, Ontario K4M IA3 (613) 692-7777 Canadian Guide Dogs for the Blind (B.C. Branch) PO Box 26074 4440 Colcherster Drive Richmond, BC V7C 4R4 (604) 241 Key Companions 2148 Mango Street Oakville, Ontario L6H 3M I (905) 845-3593 Hearing Ear Dogs of Canada POBox 907 Oakville, Ontario L6J 5E8 (416) 842-7344 Lions Foundation PO Box 907 Oakville, Ontario L6J 5E8 (095) 842-2891 Mira Foundation 1820 Rang Nord-Ouest. Ste-Madelaine, Quebec JOH I SO (514) 467-7524 Pacific Assistance Dogs Society 9048 Stormont A venue Bemaby, BC V3N 3G6 (604) 527-0556 C-17

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Powell River Therapy Dog Club Dogwood T raining Center 7372 Nootka Powell River, BC V8A IK6 C-18

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Appendix D Assistance Dogs International, Inc. (ADI) All Member Programs Minimum Standards for Training Please note: The following information is offered as a n example of training criteria; however, no there are no universally accepted minimum standardY for service animal training. Hearing Dogs These are i n tended to be minimum standards fo r all Hear i ng Dog centers that want t o be affiliated with AD!. All cen t ers are enc<>uraged to strive to work at levels above these minimums 1. A minimum of three (3) months/sixty (60) hours of training mus t take place at t he facility with the facility's trainer. During this time, at l east twenty (20) hours of r egularly scheduled training mus t be d e voted to city work ob e dience, and socialization training during the dogs entire tr aining time. 2. Basic obedience skills the dogs must master with both voice and h and sign a ls are sit stay, come, down heel, and off leash recall. 3. Social behavior skills the dogs must mas ter are no aggression no nuisance barking, no biting no snapping, or growling; no jumping on s t rangers, no begging, and the dog must keep his nose to himself. 4 Sound awareness skillsUpon hearing a sound, the dog must make physical contact with the rec i pient and specifically indicate or lead the person to the source of the sound. A ll dogs must be trained to at least three (3) sounds. D-1

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5. The placement of the Hearing Dog must last at least four (4) days/32 hours. By the end of the placement the recipient will be able to correctly praise and discipline the dog, care for t he dog, practice sound work with the dog, control the dog, and enforce obedience skills. During the placement, the trainer will go with the recipient and the dog to do city training and go to stores and a restaurant. Also, during the placement, the t rainer, recipient, and dog will practice sound work and obedience every day 6. The training facility must require the recipient to complete a follow-up progress report once a month for the first six (6) months following the placement. A personal contact will be done by a staff member or qualified volunteer within twelve to eighteen ( 1 2 -18 ) months after the placement and annually thereafter. 7. Identification of the Hearing Dog and recipient will be accomplished by a laminated ID card with a picture of the dog and names of both the recipient and dog. The dog must wear its blaze orange collar and leash, approved by ADI, with Hearing Dog printed/stitched on it and a cape with the program's logo whenever in public. 8. The training center must demonstrate knowledge of deafness and hearing impairment. Staff members must know basic sign language and must read at least two o f the following books : DEAF LIKE ME-Thomas and James Spadley, OUTSIDERS IN A HEARING WORLD Paul I Iiggins, A DEAF ADULT SPEAKS OUTLeo M. Jacobs, A LOSS FOR WORDS -The Story of Deafness in a family SILENT VICTORYand NEVER THE TWAIN SHALL MEET. 9 The recipient must agree to abide by the following responsibilities: Practice sound training regularly, practice obedience training regularly, maintain the dog's pcoper behavior in public and at home, carry proper identification, keep the dog groomed and well cared for, practice preventative hea lth care for the dog, including annual health checks and vaccinations, keep the dog at its proper weight, abide by all leash and license laws, establish proper toileting habits for the dog and clean up after the dog, and follow the training facilities requirements for progress reports and medical reports. D-2

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I 0. At the onset of training, every dog will be spayed or neutered and will have a thorough medical evaluation to determine tha t the dog does not have any physical problems that would cause difficulty for a working dog. Service Dogs These are intended to be minimum standards for all Service Dog centers that want to be affiliated with AD I. All centers are encouraged to strive to work at levels above the minimum. I. A minimum of six (6) months/one hundred twenty (120) hours of training must take place at the fa cility with the facility's trainer. During this time at least thirty (30) hours of regularly schedule d training must be devoted to field tr ip s and public exposure 2. Basic obedience skills the dog must master with voice and/or hand signals are sit stay, come, down, heel, and offleash recall. 3. Social behavior skills the dog must master are no aggression, no nuisance barking, no biting, no snapping, or growling; no jumping on strang ers, no begging, and the dog must keep his nose t o himself. 4. The Service Dog must be trained to perform at least physical tasks. 5 The recipient and Service Dog must be worked with by the facility's trainer for at least thirteen (13) days. This is both public and private instruction. All graduate s must be given a solid education in appropriate behavior of the t eam. The dog should stay as invisible as possible and not interfere with people. Proper toileting habits for the dog and cleaning up after it are a must. 6. The training facility must req uire the recipient to comple te a follow-up progress report once a month for the firs t six (6) months following the placement. A personal contact will be done by a staff member or qualified D-3

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volunteer within twelve to eighteen (12-18) months after the placement and annually thereafter. 7. Identification of the Service Dog and recipient will be accomplished by a laminated ID card with a picture of the dog and names of both the recipient and dog. In public the Service Dog must wear a harness or backpack with a logo that is clear and easy to read and identifies it as a Service Dog. 8. The training center must demonstrate knowledge of the handicaps in the clients it works with. Staff members must read at least two of the following books: to be added later. 9. The recipient must agree to abide by the following responsibi lities : Practice the dog's training regularly, practice obedience r egularly, maintain the dog's proper behavior in public and at home, carry proper id ent ification, keep the dog groomed and well cared for, practice preventative health care for th e dog, including annual health checks and vaccinations, abide by all leash and license laws and follow the training facilities requirements for progress reports and m ed ical reports. 10. At the onset of training, every dog will be spayed or neutered and will have a thorough medical evaluation to determine that the dog does not have nay physical problems that would cause difficulty for a working dog. D-4

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Appendix E Assistance Dogs International, Inc. (ADI) All Member Programs Standards and Ethics Please note : The following information is offered as an example of standa rds and ethics; howeve r no there are no univers a lly accepted standards and ethics for serv ic e animal training In keeping w i th our purpose of helping people with disabilities ach ieve greater indepen dence and/or improve the qua lit y of their lives, the mem be r organizations of ADI believe the following ethical criteria are essen tial to ensure that t his mandate is reasonably and r esponsibly met. I. Appli c ants have a right to be consid e r ed to receive an Assistance Dog regardless of race sex, religion o r cr ee d 2. App l icants students and graduates hav e th e righ t to b e treated with respect and d ignity at all times in their dealings with the mem ber organization's personnel and representatives. 3 The s t udent has a right to receive a sound educational program to learn how to use his or her Assistance Dog effectively at home or in public 4 The stu dent ha s a right to rec e iv e a p propr i ate e ducation on his or h er ro l e as a user of an Ass istance dog in the community. 5 The graduate has the right to receive regularly scheduled team evaluation and follow up support programs 6. The guardian has a right to rece ive information on or ask for assistance in the following manner: E1

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A. Additional training for the dog that is needed due to a change in the graduate's functional level B. A behavioral management problem with the dog C. A major veterinary problem D. L ega l p roblems pertaining to the use and access of the Assistance Dog as allowed by law 7. Applicants, students and graduates have a right to expect that personal files will r emain confidential and will not be disclosed unless they have given express prior permission. 8. The community has a right to expect an Assistance Dog to be under control at all times and to exhibit no intrusive behavior in public. 9. The community has a right to receive information concerning AD! Program Standards and Eth i cs. 10. The community has a right to receiv e education on the benefits r ece ived by a person w ith a disability through the use of an Assistance Dog. AD! also believes that any dog the member organizations train to become an Assistance Dog has a right to a quality life. Therefore, the only ethical use of an Assistance Dog must incorp orate the following criteria. I. An Assistance Dog must be temperamentally screened for emotional soundness and working ability 2. An Assistance Dog must be physically screened for the highest degree of good health and physical soundness. 3 An Assistance Dog must be technically and analytically trained for maximum control and for the specialized tasks he /s he is asked to perform. 4. An Assistance Dog must be permitted to learn at his/her own individual pace and not be placed in service before reaching adequate physical and emotional maturity. E-2

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5. An Assistance Dog must be matched to best suit the client's needs, abilities and lifestyle. 6. An Assistance dog must be placed with a student able to interact with him/her. 7. An assistance dog must be placed with a student able to provide for the dog s emotional, physical and financial needs. 8. An Assistance Dog mus t be placed with a student able to provide a stable and secure living environment. 9. An Assistance Dog must be placed with a student who expresses a desire for independent living and/or an improvement in the quality of his/her life through the use of an Assistance Dog I 0. An ADI member organization will accept responsibility for its dogs in the event of a graduate's death or incapacity to provide proper care Member organizations of ADI also believe that the following tenets are necessary to ensure that the member organization will continue to produce a quality product and to protect applicants, students and graduate from feeling exploited or demeaned. 1. Any individual holding a major staff position, that requires specialized people/canine skills must have not onl y the affinity for people and excellent communications skills but also canine knowledge and experience to en s ure that the member organizations will be able to maintain established standards of service to people with disabilities through their applicant/student/graduate selection, training and follow-up protocols and their canine production, selection, training and team matching methods. 2. All Board members of ADI member organizations must rece ive orientation and be provided with appropriate educational materials about their respective programs. The materials should include but not be limited to the following: E-3

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History of Assistance Dogs and the h istory of their respective programs ADI's established Standards and Ethics Board of Director functions such as funding, resource identification, solicitation and raising of funds Ongoing and planned Programs and Services E-4

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Appendix F Sample Service Animal Policies In 1996, CUTR requested copies of service animal policies from about I 00 transit agencies. Some real examples are included here tor discussion purposes A critique follows each statement in italics. Also included at the end of this section are several longer transit policies that are good examples of transit agency service animal policies. Pets & Service Animals Animals on Board ... Do not allow passengers accompanied by animals to board your bus. Only small caged animals are allowed aboard, accompanied by their owner. Seeing-eye and Hearing-ear dogs will be allowed to accompany their owners aboard the coach. This statement is incorrect All service animals must be allowed to accompany their handlers not just guide dogs or hearing dogs. Pets ... Small pets are permitted if enclosed in a proper carrying cage no larger than 21" x 13" x 9". Large animals are prohibited on trains with the exception of service animals, which are animals trained to assist individuals with a disability as defined in the Americans with Disabilities Act of 1990. Howeve r animals which may be unsafe to other customers may be denied passage aboard the train. Technically correct; could be improved by stating what is a/lowed first {i.e., service animals must be transported) before stating what cannot occur. No Animals on Board Buses ... Operators shall not allow animals aboard any bus operated by the Transi t Authority except for Seeing Eye Dogs for the blind, or small animals confined to portable cages. Any pet owner who insists F-1

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on bringing his/her uncaged pet aboard the bus should be informed to remove himself/herself and the pet from the bus immediately. If a problem results, contact a Supervisor at once and do no t enter into any further discussion with the passenger. Do not forcefully remove either the passenger or the pet from the bus. This could result in your arrest, so it is best to let the police officer do this if this measure is required. This is a badly worded policy. First, it only addresses "seeing eye dogs" and ignores other types of service animals. It puts pets in the same category as guide dogs. Most of the policy is aimed at what to do if there is a problem, resulting in extreme action (i.e., calling the police). Terminology & Wording Problems Passengers Are Permitted to Travel with Assistance Animals Trained to Assist Them .. Coach operators shall penn it assistance animals to accompany passengers with disabilities. Although technically correct, this statement does not really say anything and does not help the driver to know what an assistance animal is Guide Dogs ... The visually impaired passenger may travel with a guide dog. T he only assistance this passenger may require will be an indic ation as to where to sit. Seating should provide ample space for the dog in which to lie down where he will be out of passenger traftic. Only addresses guide dogs. Further, some persons with visual impairments may need to know more than just where to sit (e.g. where to get ojj'the bus). Animals ... Seeing eye dogs, hearing-aid dogs, and other special-assistance dogs are allowed aboard buses. Once aboard, dogs must remain on a leash, under the complete control of the owner and remain in the "down" or "sit" position for the remainder ofthe ride. The dog may ride on the passenger lift F-2

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with the passenger. For your safety, (the transit agency) recommends that the dog not occupy the bus aisle or bus seats. Intent is correct but terminology is not correct ("seeing-eye" and hearing aid" are incorrect terms). It is not safe for service animals to rid e on lifts unless absolutely necessary. Also dogs should not block aisles nor should they be allowed to occupy a seat. Certification/Identification Assist Animals Are Permitted on Our Buses .. Assist animals include but may not be limited to seeing eye dogs, hearing dogs and monkeys. All assist animals require some official authorization. You may reques t to see this authorization if is not apparent that the animal is an officia l assist animal. This statement is incorrect. The system cannot require ''official authorization" and the driver may not request to see any. Carriage of Small Animals ... Small animals may be carried free o f charge, provided they are securely enclosed in a box or basket sufficiently small enough to be carried without danger or offense to other passengers. Also permitted are trained service animals used by disabled individuals. In those circumstances where it may not be obvious that a particular animal is a trained service animal, individuals shall provide written assurances, in response to a request by an employee and as a condition of admission to the transit system, that the animal is, in fact, a trained service animal. Examples of written assurances inc lude a letter from a doctor, a letter from the service animal's trainer, or a certification of training. Combines pets and service animals in one policy. Also says there must be written assurances that animal is a service animal, which is illegal. F3

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D i scount Cards ... Qualified individuals who travel with a certified signa l service, o r guide dog shoul d i n clude the dog in the photograph for the card. Thi s will assist yo u in boarding wit h your dog. Generally all right; howev er, could imply discount cards require photo Also, dogs are not the only kind of service animal Other PCA ... Individua ls accompan ying a n ADA paratransit individual as a Personal Care Attendant (PCA) mus t be designa t e d at the time of certification ( thi s includes service animals ) On paratransit trips the PC A must have th e same origin and destination as the eligible p assenger W hen sche duling trips .. .Inform t h e scheduler if y ou are in a wheelchair, use a wal k er, etc., and of any persons (including PCA or a service an i ma l) traveling with you. This is an interesting approac h of co mbining personal care att e ndant s (PCAs) in the same category as service animals Goo d State ments Service An imal s ... Serv ice animals shall always be permi tted to ac company their users in any .. public transportation vehicle ... One o f the most common misunderstanding about service animals is that they are limited to being guide dogs for persons with visual impairment. Dogs are trained to assist people with a wide variety of disabilities, including individuals wit h hearing and mobility impairments. Other a nimal s (e.g., monke ys) ar e someti me s used as service animal s as well. In a ny of these situations, the entity mu s t permit the service animal to acco mpany its' user. F 4

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Assistive Animals--July 7, 1994 Operator's Bulletin ... Operators are reminded that assistive animals, accompanying customers with visual, hearing, or mobi lity disabilities, ride free. Also, if a customer states that he/she uses the animal to assist with a disability, treat the animal as an assistive animal. Customers with assistive animals usually prefer to sit in the securement area so the dog can rest out of the aisle. Please accommodate this request unless a wheelchair user needs this area. Two additional examples of good service animal policies begin on the next page (Sam Trans and Tri-Met). F-5

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DRAFT October 16, 1996 SERVICE ANIMAL POLICY-SAMTRANS Service animals, such as guide dogs, may accompany persons with disabilities in the facilities of and in the vehicles operated by or for the San Mateo County Transit District, if the animal is on a l ead that does not interfere with the other passengers on the bus and the animal is under the constant supervision and the control o f the person with disabilities. A service animal is any guide dog, signal dog, or other animal individually trained to work or perform tasks for an individual with a disability including but not limited to, guiding individuals with impaired vision alerting individuals with impaired hearing to sounds, providing minimal protection or rescue work, pulling a wheelchair, or fetching dropped items. If the operator has a doubt that the animal is a service animal, the operator may ask the customer if the animal is a service animal. If the customer says it is the operator must allow the animal to board the bus. If the customer says it is not a service anima l the operator should tell the customer that the animal is not allowed on the bus. While riding in a vehicle, the animal will be required to sit or stand on the floor of the bus, and may not block the aisle If ao animal misbehaves, then the passenger will be asked to remove his or her animal from the vehicle. If there are multiple occurrences of misbehavior the animal's riding or entry privileges may be revoked. Examples of misbehavior include unprovoked growl ing or attacking passengers the bus driver, other Sam Trans' employees or other service animals. Young people from the 4-H Club raise puppies in training for Guide Dogs for the Blind. These puppies may board Sam Trans buses when in their green coats and with their trainer. Customers of RediWheels are required to notify the reservationist that the animal will be accompanying them when they book their ride. F-6

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December 9, 1995 NOTICE TO OPERATORS ASSISTANCE ANIMALS EFFECTIVE IMMEDIATELY All assistance animals are to be allowed on our system. We cannot require permits or other forms of proof of their being an assistance animal. Refer to Patty Nielsen's Accessible l:lot Flash dated December 9, 1993, and Transportation Department's Procedures Manual, sec tion 203.17 Assistance Animals. cc: Road Operations Dispatch F-7 Clyde A. Earl, Director of Transportation

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ERICANS WIT ABJ.LITIES ACT Paii1Cia NielSen ADA compliance 238 49J4 ACCESSIBLE HOT FLAS H by Patty Nielsen ASS ISTANCE ANIMALS December 8, 1993 This "HO T FLASH" is an attempt to clarify a rule concerning Assjstao,e Animals on board Tri -Met vehicles. The Operators' Rule Book (Rule 268) states, "Bring ing aboard animals, except for hearing ear dogs for the deaf; seeing eye dogs for the blind; 'Canine Companions' for the disabled (appropriate identification); and small animals fully enclosed in carrying conta iners;" The Americans with Disabilities Act (ADA) (effective October 7 1991) states "The entity shall permit service animals to accompany individuals with disabilities in vehicles and facilities." The following serves as clarification regarding this ADA rule: Service animals shall always be permitted to accompany their users in any private or public transportation vehicles or facility One of the most common misunderstandings about service animals is that they are limited to being guide dogs for p e r sons with visual impairments Dogs are trained to assist people with a wide variety of disabilities, including individuals with hearing and mobil ity impairme nt s. Other animals (e.g., monkeys) are sometimes used as serv ice animal s as well. In any of these situations, the entity must permit the service animal to accompany its user. F-8

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Accessible Hot Flash December 8, 1993 Page2 Oregon State Law "Prohibits discrimination against physically disabled person who owns or i s accompanied by assistance animal in access to public accommodations. Section 1. As used in this Act: (I) "Assistance animal" means any animal trained to assist a phy sically impaired person in one or more daily life activities, including but not limited to (a) dog guides; (b) hearing ear dogs; (c) pulling a wheelchair; (d) fetching dropped it ems; (e) balance work. (2) Assistance animal trainee" means any animal undergoing training to assist a physically impai red person. (3) "Daily life activity" i ncludes but is not limited to (a) self care; (b) ambulation; (c) communication; or (d) transportation. (4) "Mode of transportation'' means any mode of transportation operating within this state. Section 2. {I) A physically impaired person has the right to have an assistance animal with the physically impaired person and a trainer has the right to have an assistance animal or assistance animal trainee with the trainer, in any place of public accommodation or on any mode of transportation so long as the physically impaired person or trainer controls the behavior of the animal. (4) A physically impaired person or trainer is liable for any damages done to a place of public accommodation or to any mode of transportation by the assistance animal." On January 27, 1993 Tri-Met's Board adopted an ordinance which amended Tri-Met Code Section 28 .10 and 28.15: The following definition is added to Tri-Met Code Section 28.10: '"Assistance animal' means a dog guide hearing car dog, and any service animal trained to assist a disabled person in one or more daily life activities including, but not limited to, pulling a wheelchair, fetching, and balance work. Section 28.15 .E of the Tri-Met Code is amended as follows: "Anima ls: No person shall bring or carry aboard a District Vehicle any animal not housed in an enclosed carrying container, except that a disabled person, or a person training an assistance animal, may bring or carry aboard an assistance animal, so long as the disabled person or trainer controls the behavior of the animal. F-9

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Accessible Hot Flash December 8, 1993 Page3 When the Operators' Rule Book is reprinted, Rule 268 will reflect the above Tri-Met Code language. To provide you with further assistance in understanding this ordinance, Tri-Met's l egal counsel offers the following: Assistance animal identification will not always be available. The ADA or Oregon State Law fails to provide guidance on how to identify an assistance animal. Tri-Met has determined that it is appropriate for personnel to specifically inquire with the disabled individual whether the animal is an "assistance animal". Animals accompanied for personal security do not qualify as assistance animals. Consequently, such guard animals must be in an enclosed container. Finally, whether the animal's behavior is under control by the disabled individual or trainer shall be determined on a case by case basis. If the animal's behavior is obviously out of control, the operator may in his/her judgment based upon passenger safety refuse to allow the animal to board the bus. Keep in mind, the disabled individual or trainer is liable for any damages done by the assistance animal. Bottom line, if the customer is a person with a disability and says their animals is an assistance animal, and they have the animal under control, there should be no further debate -the customer and their assistance animal should be welcomed aboard your vehicle. I hope this lengthy explanation alleviates any further misunderstandings between you and your customers regarding assistance animals. F-10

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Appendix G Sample Driver & Client Directions SAMPLE#l Driver Instructions for Loading and Unloading a Client and Assistance Dog (Canine Companions for Independence, Inc. (CCI)) Please note: these are driver instruct ions prepared by Canine Companions for Independence (CCI). Other organizations may provide different instructions to their clients. The best advice is to ask whether the person needs assistance and how he or she would like to board and alight from the transit vehi cle. Loading When y ou arrive to pick up the client, open the door and lo we r the lift The client will then let go of the dog's leash and in struct the dog to jump into the vehicle. The dog will wait inside the vehicle The client will get on the lift and be loaded as normal. Once the client i s loaded, he o r she will pick up an d hold the dog's leash Unloading The clien t will drop the lea sh and tell the dog to wait in the vehicle. The client will be unloaded as norma l. When the clien t is off of the l ift he or sh e will call the dog, and instruct the dog to jump out of the vehicle and come directly to him or her. The client will then pick up and hold the leash. Drivers Please do not pet or talk to the dog ; this distracts the dog from its work. Do not give the dog any commands unless the client specifically asks you to. G-1

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Do no t take the dog's leash unless the client specifically asks you to. So m e clients may ask yo u to pick up the end of the dog's leash and hand it to them if they are having d ifficu lty pic king up the leash. What you should do when you meet an assistance dog team in public. Make eye contact and greet the person first It is very tempting for dog l overs to greet the dog first. Always ask if you can pet the do g. Do not be off en d e d if the person requests that you do not pet the dog. If you are speaking to so meone who uses a wheelchair for more than a b rief conversation sit or kneel down and face him or her. What you should expect when you see an assistance dog team in public. The dog will be well groomed and odor f r ee. The dog will not shake, scratch or groom itself excess iv ely in public. The dog will be quie t and not whine bark or growl. The dog will always be with in 12 inc h es of the owner's leg or chair. The dog will be parallel with the p e rson and not block walkways with body, tai l or feet. The dog will not initiate contact with someone without the owner's direct permission. The dog will not sniff people, store shelves, restaurant tables or the belongings of others. T he dog will on l y toilet on command in appropriate areas outdoors. G-2

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SAMPLE#2 Transit Pro cedures (T h e Assistance Do g Institute) Please note : these are sample transit procedures for persons trav eling with service animals, prepared by The Assistance Dog Institute. Other o r ganizations may provide different instructions to their clients The best advice is to ask whether the person ne e ds assistance and how he or she would like to board and alight from the tran sit vehicle Loa ding: With the bus stopped at the loa ding site, the bus operato r is to ad v i se p asse n ge r s on the bus that a wheelchair passenge r accompanied by a servi c e dog i s about to board. The operator should reques t that passengers seate d on the two front inward facing seats relocate temporarily to the rear of the bus. Passeng ers using wheelc h a irs shoul d board the bus a head of other pas se nger s waiting at t he bus stop. T he operator is to ext e nd the wheelchai r lift to stree t level. The serv i ce dog at the command of its owner the n jumps aboard the bu s and s t ays at the top of the s tairs for it s master. Driver s and passe ngers alike are to be discouraged from ta lk ing to o r petting the dog unl ess assistance is requ es ted fro m the dog' s master. The wheelchair passenger is to back his/her chair onto the lift at street level. Prior to raising the lift the operator sho uld verball y check to insur e that the wheelchair brakes have been set and the person is ready As the lift begins to rise, it is advis able for the oper a tor to inform the wheel c h a ir passenge r i f his dog moves fro m its assigned spo t s ince the passenger m ay not be ab l e to see his/her dog. The lift is raised t o bus level. At this time, the opera t or is to ask if be may assist in maneuvering the wheelchai r down the aisle to the stowage position. The owne r is to take hold of the s erv ic e do g and the dog is to back up behind the wheelchai r to t he stowage positi on. OR if there is room on the bu s the owne r can G-3

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reposition the dog in front of the wheelchair and the dog will follow the owner to the stowage position. Once this maneuver is completed, the wheelchair may be guided down the aisle of the bust to the stowage position. T he wheelchair is to be lo cked in the securing clamps. Regardless of whether the operator's help is accepted while maneuvering the wheelchair to the stowage position, the operator is to check that the security clamps are engaged. At this time the operator is also to request that the wheelcha i r passenger utilize the seat belt provided, and if necessary assist in fastening the seat belt. The passenger should be encouraged b y the operator to instruct hi/her dog to lie or sit as far out of the aisle of the bus as possible. Discharging: The passenger who use s the wheelchair should notifY the operator that his/her stop is ahead. While extending the wheelchair lift to bus level, the operator should request that passengers seated on the two front inward facing seats relocate temporarily to the rear of the bus. While releasing the wheelchair from the security clamps, the operator i s to ask if he/she may assist in maneuvering the wheelchair down the aisle and onto the lift. The service dog should, on its owne r's orders, accompany the wheelchair to the top of the stairs, and stay there until the wheelchair is unloaded. The lift is lowered to st r eet level, whereupon the wheelchair passenger will maneuver off the lift. The service dog is to r emain at the top of the stairs until called. The wheelchair passenger should immediately clear the lift and tum to face the dog and call the dog. Once the passenger and/or dog are clear of the lift, the operator is to return the lift to the "steps" position. Always thank the operator! G-4

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Appendix H Re s ources Related Book s & A rticl e s o f Int e rest Donahue, Connie 1996 Training Drivers to Work with Service Animals. K ansas TransReporter O ctober 1996:8-9. Drastura, Jenny 1994 Delta Society Bonds People, Animals, Nature Dog World (November 1994):46-48. Eames Ed 1994 From Academic to Advocate. Anthropology of Work N ewsletter 15(2&3):30 31. Eames, Ed and Toni Eames 1994 Partners in In dependence. Dog World 79(4):29 30. 1995a Partners in Independence. Dog World 80(2):74-78. 1995 b Pa rt ne r s in Independence. D og World 80(5):50-52 Flemming, Jim 1996 Transit Personnel Trained in Role of Se r vice Animals. Passenger T r ansport 54(12):9. Go ld, Gerald 1994 Ca r etakers in a Miniaturized World: Encounters Between Para transit Drivers and a Disabled Anthropologist. Ant hropology of Work Newsletter 15(2&3):19-21. Harrington, Paula 1990 Looking Ahead: Guide Dogs for th e Blind. San Rafael CA: Guide Dogs for the Blind H-1

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Medford, Eleanor M. 1992 Bringing Up Baby. Dog World 77(2):36-39. Pfaffenberger, Clarence J. 1963 The N ew Knowledge of Dog Behavior. New York : Howell Book House Pfaffenberger, Claren ce J. et al. 1976 Guide Dogs for the Blind: Their Selection, Development, and Training. Amsterdam, NY: Elsevier Scientific Publishing Company P flaumer Sharon 1992 Seizure-alert Dogs. Dog World 77(1 ):42-43. Roche, Michael P. 199 4 Legal Rights of Guide Dogs, Hearing Dogs and Service Dogs. Lakewood, CO: Assistance Dogs International. Rutenberg, Uwe and Tom Geehan 1994 Provisions for Service Animals on Regulated Carriers. Montreal, Quebec : Transportation Development Cen tre. Shaw, Fran Pennock 1994 Guid e Dogs Open Road to Independence. Dog World (November 1992) :40-44. Stiverson Carla and Norm Pritchett I 996 Assistance Dog Providers in the United States. Fairview, NC: N. C. Service Dogs. TD Safety & Acce ss Report 1995 Pig T rav el s as Service Animal on N YCTA Bus. TD Safety & Access Report 3(7):4-5. H-2

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Uslan, Mark M., Alec F. Peck, William R. Wiener, and Arlene Stem, eds. 1990 Access to Mass Transit for Blind and Visually Impaired Travelers. New York : American Foundation for the Blind. E-mail/Internet Resources Internet/E-mail Addresses: Here are a few of the many E-mail and Internet addres ses that may be of interest. New ones are continually being added. Canine Companions for Independence http://www.caninecompanions.org/ info@caninecompanions.org Delta Society National Service Dog Center http://www.petsforum.com/deltasociety/ deltasociety@cis.compuserve.com Guide Dog F oundation for the Blind htt p:/ /www.g uidedog.org/gdfb.htm IAADP IAADP @aol.com Leader Dogs http://www.leaderdog.org The Seeing Eye, Inc. http://www.seeingeye.org semaster@seeingeye.org Southeastern Guide Dogs, Inc. http://www.guidedogs.org/ H-3

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Othe r E -mail R e sour ces: The quickest way to find information on the World Wide Web is by asking your browser to search for "service dog," "dog guide," or "guide dog." You will find updated l i sts of assistance animal training schools, frequently asked questions, etc. Service dog discussion group. This discussion group is primarily made up of persons who have or train service dogs. Among the topics of discussion is the issue of certification for service dogs To subscribe to this discussion group send an E -mail to: majordomo@acpub.duke.edu With no subject line make your first text line read : subscribe service-dogs Vid e os Several videos have been produced by service an i mal training centers. Most focus on how service dogs are raised and trained, and include promotional information about the sponsoring program. No videos were found that dealt primarily with the issue of t r ansporting service anima l s; however Tri Met in Portland, Oregon, includes a brief spot on passengers traveling with service animals in its driver training video "ADA Ope r ator Video" (10 : 23 minutes) produced by Tri-Met, 4012 SE 17th Portland, OR 97202 "Courage" (10 : 30 minutes) produced by Southeast ern Guide Dogs, Inc., 4210 77th Street East, Palmetto, FL 34221 (Tel. 813-729-5665) H -4

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"Harnessing Freedom" (22:00 minutes) produced by The See ing Eye, PO Box 375, Morristown N J 07063 ( Tel. 20 1 -539-44 25). "Heart of a He ro (12:00 minutes) produc ed by Canine Companion s for Independence PO Box 446, Santa Rosa, CA 95422 (Tel. 707-528-08 30). Partners" (20:39 minutes) produced by The Seeing Eye PO Box 375, Morristown, NJ 07063 ( Tel. 20 1 -539-44 25). "Service Dog s Welcome!" (15:00 minute s) produced by Delta So ciety Service Dog Center 289 P erimete r Road East, Renton, WA 98055 (Tel 800 -869-68 98 I 800-809-2714 (TDD)). Yaz: The Beginnin g of Independence (10:40 minutes) produced by Southeastern Guide Dogs, Inc., 4210 77th Street Eas t Palmetto F L 34221 (Tel. 813 729 5665) O t h e r Resources The National Inform atio n Center on Deafn ess at Gallaude t Univer s ity publishes a fa c t sheet on hearing ear dog s. The cost i s $1.00. NICD Gallau det Universi ty 800 Florida Avenue NE, W ashington, DC 20002. U.S. Department of Ju stice ADA Information Line may be reached by calling 800-514 0301 (voice) or 800-514-0383 (TDD). H-5