Federal Reporting of Pet Injuries

A new national accident reporting regulation for the airline industry took effect in May.  The system provides consumers with easy access to accurate data on deaths and injuries related to air travel so that they can make informed decisions about risk before purchasing tickets. 

The rules apply to any air carrier that provides scheduled passenger transportation.  No exemptions for big airlines.  No exemptions for air carriers that operate in certain regions of the United States.  No exemptions for certain types of air transportation, say helicopters vs. planes or propeller-driven planes vs. jets.  No exemptions at all.  Imagine that. 

Passenger air carriers are required to submit monthly reports to the U.S. Department of Transportation describing all deaths and injuries of household pets, warm- or cold-blooded, occurring between check-in of the animal prior to departure and the time the animal arrives at the final destination.  Yes, I said pets, and no, I'm not making this up.  For each reportable incident, the air carrier is required to provide the following information:

• Carrier and flight number.  Note that this identifies the specific aircraft involved in the incident as all air craft are required to be registered with the federal government.
• Date and time of the incident.
• Description of the animal.
• Narrative description of the incident.
• Narrative description of the cause of the incident.
• Narrative description of any corrective action taken in response to the incident.
• Name, title, address, and phone number of the individual filing the report on behalf of the air carrier.

According to an article in Forbes, "carriers say that they fly millions ... each year and deaths are rare.  But some ... advocacy groups have argued that reporting standards are necessary to give consumers information about an airline's record..."  Sounds like a familiar argument, doesn't it?  Oddly enough, Congress sided with consumers in this case.  H.R. 1000, The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century, was passed by the House and Senate in March of 2000.  Final rules were published in the Federal Register in February of this year. 

An article last week by the Associated Press summarized the first published report as follows:  "The figures released Thursday by the Transportation Department bolster airlines' claims that the vast majority of animals survive flying without a problem."  Six U.S. Airlines reported a total of 10 incidents, including five injuries, one lost pet, and four fatalities.

• Cave, an 8-year-old black lab mix with a pre-existing heart condition, died in the air between Honolulu and Newark, New Jersey.
• An unnamed pet rat died of natural causes on a commuter flight in Texas.
• A Sheltie named Kelly ingested a toxic substance en route from Germany to Washington and had to be euthanized.  A US Airways investigation failed to discover what happened.
• Tango, an Abyssinian cat, was attacked and killed in the cargo hold by a dog that escaped from his kennel.  Alaska Airlines found that the dog was placed in a kennel not strong enough to hold him.  The dog's owner was arrested and banned from the airline for a year.  The dog was banned permanently.

Congress and the ASPCA have, in their infinite wisdom, provided the perfect model of a consumer-focused data collection system for human injury data related to U.S. amusement rides.  If you think about it, pets probably experience airline travel in much the same way that humans experience thrill rides.  Death and injury scenarios are likely to overlap as well.  For example:

• Some small percentage of pets will suffer ill effects from the physical and/or emotional stresses experienced in an accelerating aircraft, particularly older animals and those with pre-existing conditions like Cave, the black lab mix.
• Pets, like small children, are not always well-restrained within their carriers, and may suffer injuries associated with poor anthropomorphic fit.
• Deliberate misconduct can be a problem, as Tango the Abyssinian discovered.
• Injuries related to load and unload, while statistically rare, are to be expected.

The FAA's new pet injury reporting regulation is intended simply as a data gathering system for consumer use.  Deaths and injuries are reported regardless of what caused the event or who the airline deemed to be at fault for the incident.  Trauma-related pet deaths and injuries are reported, but so are pet deaths and illness from heart arrhythmia or bleeding in the brain. The sole purpose of the system is to find out what types of pets are vulnerable to which types of injuries while flying in specific types of air craft, so that consumers can make responsible, informed decisions about whether a particular aircraft flight is safe enough for their own pets.

Consumer access to the FAA's pet injury data will be infinitely easier than current consumer access to amusement ride injury data, because the statute was crafted without exemptions and with explicit requirements to publish the data "in a manner comparable to other consumer complaint and incident data".  Mandatory reporting of aircraft accidents involving human death and injury or machinery malfunction has been in place for a long time, and the data can be easily accessed online. 

The federal government now collects better data on gerbils and lizards injured in airplanes than is collected on human beings who are killed or injured on commercial thrill rides.  It is worth noting that the pet injury reporting law for airlines had strong bipartisan support, while the idea of a human injury reporting system for amusement parks has virtually no support in Congress, with the notable exception of Rep. Markey.