Work or tasks under the ADA

Origin of the work or tasks phrase

The Department of Justice's ADA rule, 28 CFR 36.104, defines a service animal as a dog individually trained to do work or perform tasks for the benefit of a person with a disability. The work or tasks must be directly related to the person's disability.

"Work" and "tasks" overlap. A task is usually a discrete action, such as retrieving an item. Work can describe ongoing jobs, such as guiding. In practice, both mean something the dog has been trained to do because of your disability.

Work or tasks examples

The rule offers a list of examples. Several apply to psychiatric disabilities directly, and others, like retrieving items, are useful across many conditions.

• Helping people with psychiatric and neurological disabilities by preventing or interrupting impulsive or destructive behaviors.
• Retrieving items such as medicine or the telephone.
• Assisting during a seizure or alerting to the presence of allergens.
• Providing physical support and assistance with balance and stability.

What doesn't count as work or tasks

The same definition says two things are not work or tasks: the crime-deterrent effects of an animal's presence, and the provision of emotional support, well-being, comfort or companionship. This is why an emotional support animal, however helpful, is not a service animal under the ADA.

The Department of Justice explains the psychiatric distinction this way: if a dog has been trained to sense an anxiety attack is about to happen and take a specific action to help avoid it or lessen its impact, that would qualify. If the dog's mere presence provides comfort, it would not.

Answering the second question

When it isn't obvious what a service dog does, staff may ask what work or task the dog has been trained to perform. You don't need to name your diagnosis. A short, specific answer works best, such as "He's trained to interrupt panic attacks with deep pressure" or "She wakes me from nightmares."

Airlines may ask the same two questions under DOT rules, and the DOT Service Animal Air Transportation Form also asks you to attest to your dog's training.

Related terms

Task training explains how dogs learn these behaviors, and the two questions rule page covers what staff may and may not ask. If your dog provides comfort without trained tasks, the emotional support animal entry explains the different rules that apply to ESAs, mostly in housing.