What Will You Do With the Dog?
If you were presented with one of the following scenarios, do you know what the most appropriate action would be?
You arrive to find a pedestrian who has been struck by a car. The patient is injured but stable, so you prepare to transport him to the closest hospital. The patient is also blind, however, and says his guide dog must come with him. Your partner says that is a health code violation and against departmental policy. Who is correct?
You are led into a house by a neighbor who found her friend unconscious and called 9-1-1. The patient has a mobility disability and a service dog sitting next to her. If you approach the patient, will the dog defend its owner and attack you?
This article will answer these questions and cover general information such as how to identify a service dog, ADA requirements, incident challenges, and the safe transport of service dogs.
Service Animals Defined
According to the United States Census Bureau, “About 56.7 million people—19% of the population—had a disability in 2010, according to a broad definition of disability, with more than half of them reporting the disability was severe.”1 While most people with disabilities do not use service dogs, a growing number do. There is no registry that specifically tracks service animals, so it is impossible to say how many people with disabilities are partnered with one. It is very likely that in your career as a prehospital provider, you will respond to a patient who has a disability and utilizes a service animal.
What exactly is a service animal? Is it just a “seeing-eye” dog? In 2011 the Department of Justice issued ADA regulations that revised the definition of service animal and added additional provisions. Its definition: A service animal is any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual or other mental disability. Other species of animals, whether wild or domestic, trained or untrained, are not considered service animals.2
The tasks performed by a service animal must be directly related to an individual’s disability. Examples could include assisting a blind individual with navigation and other tasks; pulling a wheelchair; or assisting someone suffering a seizure. The skill sets of service dogs are constantly expanding to allow their human partners to live independently in an increasingly complex world.
Crime deterrence and the provision of emotional support or companionship are not considered tasks for purposes of defining a service animal. Keep in mind, however, that different federal laws exist pertaining to service animal access in subsidized housing (Fair Housing Act) and air travel (Air Carrier Access Act). In those cases the FHA and ACAA permit people to have emotional support animals, which are not the same as service dogs.
The revised ADA regulations also address the provision of reasonable accommodations for individuals with disabilities who use miniature horses as service animals. The regulations identify four assessment factors to consider; however, the discussion of miniature horses is beyond the scope of this article.
Identifying a Service Dog
How can you identify a service dog? There is no requirement that it wear a specific type of uniform or equipment; however, a service dog will wear whatever is necessary to perform its work. In most situations there are visual clues to identify a service dog—for example, a guide dog wears a stiff harness with extended guide handle. Some service dogs wear a bright-colored vest and/or a sign reading No Petting—Working Dog.
Mobility service dogs, trained to assist people with physical disabilities, often wear jackets or backpacks. First responders may be accustomed to seeing guide dogs wearing leather guide harnesses. On these harnesses the handle relaxes when dropped by the human partner. The guide dog will stand to lead when the partner picks the handle up. Harnesses often have reflective or other visibility features to alert motorists. The “uniform” meets the practical needs of the service dog team. Keep in mind that Title III of the Americans with Disabilities Act does not require proof or certification of a service dog’s training. EMS or fire personnel may not ask for proof of license or certification.3
A service dog’s tasks must be related to its partner’s disability, and you may have heard the term “task-trained.” What does this mean? A service dog has been taught tasks to mitigate a specific disability. Like all working dogs, its job has a purpose.
Tasks and functions can include safely negotiating traffic and environmental obstacles for a blind handler; alerting deaf partners to smoke detectors, knocks at the door, and doorbells; providing stability or retrieving items for a gait-impaired partner; or rolling a seizure patient to create an open airway, getting help, or operating a call button.
It’s important to remember that service dogs are working animals, not pets. Specially trained service dogs are chosen for their temperament, sociability, confidence, and eagerness to work. They are well behaved and obedient off-leash and while working. To answer the questions in our scenarios, a service dog is socialized and conditioned to be very tolerant of the ordinary activities of humans and safe around people.
Service dogs and protection dogs are two different disciplines. A service dog team has legal protections and is permitted in all places of public accommodation, including theaters, restaurants, hospitals, ambulances, airports, and classrooms. Additionally, the CDC notes, “No evidence suggests that animals pose a more significant risk of transmitting infection than people; therefore, service animals should not be excluded from healthcare facilities, unless an individual patient’s situation or a particular animal poses greater risk that cannot be mitigated through reasonable measures.”4
Being a service dog implies a well-mannered dog that has gone through rigorous screening and training to assist a disabled person. Protection dogs have received an entirely different type of training and are not considered service dogs for purposes of the ADA.
Separating a disabled person from their service animal could cause serious mobility problems. ADA Title II 28 CFR Part 35.136 states that a person with a disability cannot be asked to remove his service animal unless 1) the dog is out of control and the handler does not take effective action to control it; or 2) the dog is not housebroken.
When there is legitimate reason to ask that a service animal be removed, first responders must continue to provide care to the patient with the disability. Further, the ADA requires responders to modify their practices and procedures as necessary to ensure that disabled people with service dogs are provided the same service as their nondisabled peers.
Providers may exclude a service animal from transport with its handler when the animal’s behavior is out of control and the handler does not or cannot take effective action to control it. For example, a service animal that displays vicious behavior toward first responders may be excluded. You may not make assumptions, however, about how an animal may behave based on your past experience with other animals.
Each situation must be considered individually. As you interview and assess your patient, remember that you are permitted to ask, “Is the service dog required because of a disability?” and “Is the service dog trained to perform a task?” You may not ask for proof of certification or questions such as, “Is your dog vicious?” “Does your dog bite?” or “Can’t you just take your cane and leave the dog?” Finally, remember that your state may also have its own laws. For example, Maryland service dog laws extend protections to service dogs in training.
Populations with high exposure to traffic will be at a greater risk of traumatic injuries from being struck by a vehicle, and their service dogs may also be injured. It would be extremely beneficial for EMS agencies to develop standing orders or procedures to address transportation to a 24-hour veterinary hospital.
In 2004 the Baltimore County fire and police departments issued a standing order to allow the transport of injured guide dogs to the local 24-hour veterinary hospital when their blind handlers had been transported to a hospital by the fire department. This policy was established after incidents in which blind pedestrians and their guide dogs had been struck by vehicles. Retired Fire Chief Jim Korn saw a need for better coordination and consulted with blind handlers when developing protocols for managing an injured service dog team.
Attacks on service animals by pet dogs are a common problem and can cause serious mobility problems for disabled handlers. Service dogs require immediate attention and may require more resources than in other dog-on-dog attacks. Because of their disability, the handler may be vulnerable to injury from the aggressor dog and left exposed to traffic and environmental hazards. Service dogs may be unable to defend themselves because they are harnessed and leashed.
Blind patients may ask you to demonstrate proof that you are a first responder. This is a reasonable request. Sound is paramount—you may briefly increase the volume on a portable radio so the patient can hear transmissions or even call your dispatcher and ask for a test count. A quick chirp of the siren may also help. Provide as much information as possible. Verbally explain processes (remember your practical exam, where you stated everything you were doing to the evaluator). Speak directly to the patient. Do not assume the patient is unable to answer your history questions.
Announce your entrance and departure from the room or incident. To facilitate communication and identification with a person who is blind and hearing-impaired, you may need to enlist a relay service. Alternatively, the patient may have a mobile communication device or other assistive technology you can type questions into.
Now it is time to transport the patient and dog. To do this, you should be familiar with some best practices. Questions that should be considered include:
Will the service dog be transported with the patient? Each incident will need to be evaluated individually. Remember that you cannot separate the guide or service dog simply because it presents an inconvenience. The decision to separate the service dog must be based on behaviors you directly observe. Refusal to transport a service dog should be documented in the patient care report. Include the actions taken to ensure the dog’s safety.
Can the guide or service dog be accommodated in the patient compartment? You will need to select the optimal location to which the dog can be safely transported, but there are no regulations to specify where it should be placed during transport. The size of the dog, condition of the patient, and space configurations of the apparatus will drive this decision.
Once it has been determined that the dog will be transported with its handler, it is extremely important to load the stretcher first, so the dog’s paws are not rolled over or otherwise injured in the patient compartment. You may need to modify the collar, leash, or other device. Be sure to place a leash on the appropriate collar ring to prevent injury or asphyxiation.
Another option is to tether the service dog using a canvas strap connected on one end to the harness or jacket and the other end to a fixture in the ambulance. Hook the leash around the stretcher for transport. Conversely, on arrival at the hospital, don’t forget to unhook the service dog’s leash from the stretcher prior to disembarking and allow the service dog to exit the side door of the patient compartment.
If the patient requires interventions en route to a hospital or lack of space prevents the service animal from transport in the patient compartment, the cab may be a viable option. This will again depend on how much floor space exists. The harness or backpack may need to be removed to allow the service dog to fit the space. If the dog is transported in the cab, it will be important to cover any sharp surfaces, especially in perforated running boards, to prevent lacerations to paws.
At the end of the call, it’s a good idea to document the disposition of the service dog on the PCR. For example, if the service dog was transported to a veterinary hospital or remained with its handler, be sure to include this in the report. If the call occurred at a residence, be prepared for closing questions such as, “Can you make sure everything is back in place?” “Would you shut the door loudly so I can hear it close?” and “Can you note my residence on any (CAD/9-1-1) caution notes?”
Some final take-home pearls:
- Like any other call, remember to check for caution notes if you receive a printout;
- On arrival, observe for visual clues of a service dog;
- Prior to encountering a disabled patient, develop strategies to identify yourself as a first responder or fire or EMS provider;
- During the patient assessment, remember the questions you can and cannot ask about the service dog;
- Make sure you know how to safely transport a service dog;
- Ensure that communication is intentional and the message understood.
With practice and preparation, responding to a call that involves a service animal should be no more complex than those without one.
1. Brault MW. Americans with Disabilities: 2010. U.S. Census Bureau, www.census.gov/content/dam/Census/library/publications/2012/demo/p70-131.pdf.
2. ADA National Network. Service Animals, https://adata.org/factsheet/service-animals.
3. U.S. Department of Justice, National Association of Attorneys General. Disability Rights Task Force letter, July 26, 1996, https://www.ada.gov/animal.htm.
4. Centers for Disease Control and Prevention. Guidelines for Environmental Infection Control in Health-Care Facilities, https://www.cdc.gov/infectioncontrol/pdf/guidelines/environmental-guidelines.pdf.
Cecilia Warren, MBA, MS, is director of emergency preparedness policy for the Maryland Department of Disabilities.
John Alexander, MS, NRP, is a retired fire captain and currently a volunteer in Baltimore County, Md. He has been a nationally registered paramedic for 30 years and involved in education for approximately 20 years.
Addendum: The authors added this info in reply to a reader's question on other service animals, including miniature horses:
The Code of Federal Regulations (CFR), Title 28- Judicial Administration- definitions- states, “Service animal means any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability… Other species of animals, whether wild or domestic, trained or untrained, are not service animals for the purposes of this definition.” The work or tasks performed by a service animal must be directly related to the individual’s disability. (https://www.gpo.gov/fdsys/pkg/CFR-2016-title28-vol1/pdf/CFR-2016-title28-vol1-sec36-104.pdf).The key to distinguishing between a service animal and other type of animal such as emotional support animal is that a service dog has been individually trained to perform a task that helps to mitigate the disability of the handler. Keep in mind that the Air Carrier Access Act and Federal Housing Act have different laws and do not apply to this particular article.
Miniature horses are discussed in a separate section of 28 CFR 35.136, which states that reasonable modifications shall be made when possible, based on an assessment of the following criteria: 1. The type, size, and weight of the miniature horse and whether the facility can accommodate these features; 2. Whether the handler has sufficient control of the miniature horse; 3. Whether the miniature horse is housebroken; and 4. Whether the miniature horse’s presence in a specific facility compromises legitimate safety requirements that are necessary for safe operation. https://www.gpo.gov/fdsys/pkg/CFR-2017-title28-vol1/pdf/CFR-2017-title28-vol1-sec35-136.pdf
The ADA law clearly distinguishes between service dogs and emotional support animals. An assessment of the factors identified above are needed to determine whether a miniature horse can be accommodated. Unfortunately, there has been no additional guidance to further enlighten this particular circumstance.