After a lengthy rulemaking process, the US Department of Transportation’s new amendments to the Air Carrier Access Act finally went into effect on 11 January. The amendments ensure airlines are not required to recognize emotional support animals as service animals, and narrow the definition of service animals to dogs only.
Among the changes is the adoption of standardized forms that airlines can require service animal handlers to submit before they fly. These consist of a Service Animal Air Transportation form and a Relief Attestation Form for segments longer than eight hours. The forms must be available to download on the airline’s website, meet accessibility guidelines, and be able to be submitted electronically.
As an accessibility specialist, I was happy to see the requirement for accessible forms and electronic submission. However, I was still concerned about just how accessible the forms would be to screen reader users like myself.
Obtaining the electronic forms
Leading up to the effective date, five airlines amended their policies to align with the new regulations. The ‘traveling with service animals’ informational pages for American, Delta, United, and JetBlue make forms available as downloadable, electronically-fillable and signable PDFs that can be completed, saved, and uploaded through each airline’s website.
Alaska’s page for traveling with service animals instead linked to a web-based version of the service animal air transportation form which can be completed and submitted completely online. Neither Alaska nor JetBlue offered the relief attestation form, but neither carrier operates flights longer than eight hours.
Understanding forms and screen readers
Using a screen reader to fill out a form is a bit different than filling one out for a sighted computer user. While sighted users can easily associate a form field with an adjacent text label, screen readers rely on special coding associated with the field, known as a programmatic label, to identify the field and tell the user what they should enter. If no programmatic label exists, screen reading software may try to guess what a label should read based on adjacent content.
When completing a form, a screen reader user would enter “forms mode”, allowing the user to enter text, mark checkboxes, and other items. To move between form controls, the user can use the tab or shift+tab keys to move forwards and backwards through the form in the same way a sighted user can in web-based forms. While navigating the form, the screen reader will read the programmatic label, if any, for the control and identify it as a text box, check box, or other type of control. Touchscreen devices like phones and tablets offer similar functionality but rely on gestures instead of keyboard input.
Studying the forms
I could find no significant issues with the PDF forms made available by American, Delta, and JetBlue. Each form had programmatic labels for all form controls which did a good job of identifying what information should be entered. The verbiage of these labels varied slightly by airline and did not match the visual experience of completing the form, but that experience would be hard to replicate because of how the form is written.
The forms obtained from United’s website, however, had problems. Both forms had multiple form controls with missing or confusing labels and appeared to be missing some checkboxes that would need to be marked. In addition, an e-signature button was in the place where a passenger would be expected to enter their veterinarian’s name. When reached for comment, a United spokesperson informed me that the airline was using forms provided to them by the DOT and that their accessibility team was investigating and would make adjustments to the forms as needed. The spokesperson also noted that United will not require the forms until 1 February.
Alaska’s web-based form also contained issues with the programmatic labels. When tabbing through the text boxes, some forms were identified by hints on how to enter the information (such as a phone number), but most were simply identified as “Field XX”, where XX was a different number for each form field.
After reaching out to Alaska for comment, I was contacted by the vendor handling the carrier’s online form. The vendor apologized for the issues and let me know that they are working on improvements to the current form. The vendor also told me that the form will be moving to a new, custom-built platform in the next few months once development is complete. In the meantime, the vendor said it would work with passengers to complete the form in other ways, such as over the phone, by email, or at the airport.
Even though I had issues with Alaska and United’s forms, I am encouraged by everything I learned. I know better than to expect perfection and try to judge companies on their willingness to address accessibility issues when brought to their attention, not on the existence of accessibility issues in the first place.
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