Psychiatric Service Dogs (PSDs)

The following comments were submitted from DBSA to the Department of Justice (DOJ) regarding language in the Americans with Disability Act (ADA) regulations regarding Psychiatric Service Dogs (PSDs).

(August 14, 2008 - Chicago, Ill.) - The Depression and Bipolar Support Alliance (DBSA), the would like to thank and commend the Disability Rights Section at the U.S. Department of Justice for its review of the ADA regulations regarding Service Animals.  DBSA strongly believes that the use of Psychiatric Service Dogs (PSDs) has afforded many mentally disabled individuals to reach a new level of wellness and the opportunity to lead happy and productive lives. 
 
The Depression and Bipolar Support Alliance is the nation’s leading patient-run organization focused on depression and bipolar disorder. The organization, which has more than 1,000 support groups nationwide, fosters an understanding about the impact and management of these life-threatening illnesses by providing up-to-date, scientifically-based tools and information. Assisted by a 65-member scientific advisory board, comprised of the leading researchers and clinicians in the field of mood disorders, DBSA supports research to promote more timely diagnosis, develop more effective and tolerable treatments and discover a cure. More than 4 million people receive information and assistance each year. 
 
As part of the mental health community, we know firsthand the challenges of living with a disability. PSDs play an important role in helping the consumer manage and alleviate severe symptoms such as anxiety, hallucinations and mania.  For example, a person living with bipolar disorder whose judgement capacity while driving is diminished may be prompted by their service dog to slow down and get off the road as soon as possible.  Trained PSDs are useful for those suffering from a range of psychiatric diagnoses including but not limited to major depression, anxiety, agorophobia, autism posttraumatic stress disorder and other psychiatric conditions.
 
DBSA appreciates that service animals and emotional support animals play two separate and distinct roles and differ in the way they provide health benefits to people.  Many who confuse emotional support animals (ESAs) with psychiatric service animals (PSAs) do not understand the phenomenology of a psychiatric service dog ‘doing work’ simply because they do not understand the symptomology of mental illness and its remedies.  Thus, we kindly request that DOJ retain the ‘do work’ part of the service animal definition.  All persons with psychiatric disabilities rely upon their service animal to ‘do work’ whereas only a minority rely upon trained physical tasks.  This is an important distinction between utilizing a service dog for a mental health disability versus using one for a physical disability. 
 
DBSA also recommends that the words ‘nonspecific’ and ‘generalized’ be added to the emotional support animal definition as modifers for the terms ‘emotional support’ and ‘emotional wellbeing’.  Furthermore, we ask that the words “therapy” or “therapeutic benefit” be removed from the emotional support animal definition as these concepts overlap too much with legitimate psychiatric assistance which is, by definition, therapeutic  Retention of these words will only serve to confuse others.
 
Service animals provide those living with a psychiatric disability, a dignified way to remain in their communities and lead happy and productive lives. PSDs provide their owners with enhanced functional ability and an improved quality of life, especially for those who think their life is over.  Therefore, we would like to sincerely thank the Department of Justice for giving us the opportunity to speak out about this necessary and skilled form of canine assistance.
 
Thank your for you consideration,

Peter Ashenden
President/CEO
The Depression and Bipolar Support Alliance