by Bradley W. Morris, MA
Do service dogs have to be task trained? Is service dog work nothing more than tasks chained together? Find out why these service dog community misconceptions miss the mark in “Not Tasks, but Work or Tasks”!
For our latest work and task article and a short history of all them, see Service Dog Work and Tasks: A Cue-Based Analysis. Our popular Work and Task List and relatable Work & Task Stories are available through our main Work & Tasks page.
Those with an advanced understanding of the United States legislative process should note that while this article is written as if portions of the Code of Federal Regulations are identical with the Americans with Disabilities Act (ADA), and as if the Department of Justice is the only executive agency to produce regulations interpreting the ADA, this manner of writing is merely for convenience of expression.
The printable (pdf) version of this article is accessible via the following link:
Members of various service-dog-related communities have, for many years, made a rough “work vs. tasks” distinction within the many disability-mitigating services a dog can provide. Attempts to draw this distinction seem to originate in 1991 with title III of the Americans with Disabilities Act (28 CFR §36.104). My perspective is that categorizing such assistive behaviors has been attributed disproportionate importance because some parties try to exclude a category (work), either by active lobbying, silent omission, annexation into the task category, or by boldly claiming the Americans with Disabilities Act requires task-training. I’d like to assume we’d all agree that what’s most important outside of this discussion is how joltingly helpful service dog behaviors can be, by whatever name!
With that preliminary understanding, in this article I address two opinions I have heard publicly voiced among some followers of our sister organizations: that service dog work is nothing more than tasks chained together, and that service dogs must be task-trained.
I agree that some of what is called “work” can at least vaguely be viewed as chained tasks. We could think of this work as “molecular”, where tasks are atoms composing the molecules. This may be where some of the unclarity can arise about whether to classify a particular mode of assistance as a task or as work. On the other hand, it does seem like there are assistive behaviors that people in the community say are not tasks, or composed of tasks.
For reference, there are at least two groups that have views of “work” in which ways of working are not just molecules comprising task-atoms: the Department of Justice, and Psychiatric Service Dog Partners. In the interest of full disclosure, I’m a member of PSDP, but am writing views that I have independent of whether PSDP shares them. PSDP has a community-generated “Work and Task List” with many examples of work, some of which one would be hard-pressed to fit into the molecular theory if one weren’t trying hard to filter them through that theory.
Also, it is quite clear from a cursory glance at PSDP’s “Work and Task List” that there is a surprisingly high number of ways in which a service dog can be trained to “work” to help mitigate the user’s disability. Any one of these work items that significantly improves the handler’s ability to engage in life despite their disability is a service that should—and does—combine with public access readiness to earn the dog the title of “service dog”. To speak with due plainness and without intent to offend, this means that insisting a service dog must be task-trained must come either from a place of ignorance or of deception.
However, we needn’t be quick to agree with my reasoning, or any private organization’s, especially if you don’t find it clear and compelling. Taking someone’s word for it is just the sort of thing that got us in this mess in the first place! For those of us in the United States, we can just go to the source. The custodians of the Americans with Disabilities Act (ADA), the Department of Justice, provided a section-by-section analysis when they were carrying out the 2010 ADA revision. Here’s some of what they said in their analysis (feel free to look up the full Title II version:
“The Department received a number of comments in response to the NPRM proposal urging the removal of the term ‘‘do work’’ from the definition of a service animal. These commenters argued that the Department should emphasize the performance of tasks instead. The Department disagrees. Although the common definition of work includes the performance of tasks, the definition of work is somewhat broader, encompassing activities that do not appear to involve physical action.
“One service dog user stated that in some cases, ‘critical forms of assistance can’t be construed as physical tasks,’ noting that the manifestations of ‘brain-based disabilities,’ such as psychiatric disorders and autism, are as varied as their physical counterparts. The Department agrees with this statement but cautions that unless the animal is individually trained to do something that qualifies as work or a task, the animal is a pet or support animal and does not qualify for coverage as a service animal. A pet or support animal may be able to discern that the individual is in distress, but it is what the animal is trained to do in response to this awareness that distinguishes a service animal from an observant pet or support animal.”
From what some individuals and organizations write online, it sometimes seems as if they equate “work” with something like “multiple tasks”, or further, that they mean to say or imply that the ADA requires “task-training”—as opposed to work-training or task-training—of any service dog. Regardless of whether these parties mean to express either of these things, it’s helpful to the discussion to note that the paragraph above from the Department of Justice shows their view on both issues: work is not merely molecules of task-atoms, and the ADA does not require task-training, but either work-training or task-training.
So the facts are that (1) service dog work is distinguishable from tasks (or clusters of tasks) and worthy on its own in disability-mitigation, and (2) the ADA does not require task-training, but training of either tasks or work. The lesson apparent from one step back is simple: that we should be careful when trying to understand important, fundamental concepts to use only reliable sources, taking care to consult original sources and authorities when possible, especially when we choose to engage in a debate on the topic. I do not wish to denigrate the good work our parallel organizations do, nor to call them out by name. I only hope to encourage their members to hold their information-sources accountable to higher standards, as they are responsible for the dissemination of accurate information to people to whom that information dearly matters.