Is task training required for an animal to be considered a service animal?
Doing work” or performing tasks. The NPRM proposed that the Department maintain the requirement first articulated in the l991 title III regulation that in order to qualify as a service animal, the animal must perform tasks or do work for the individual with a disability. The phrases perform tasks and do work describe what an animal must do for the benefit of an individual with a disability in order to qualify as a service animal. 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 cant be construed as
