No — the DOT’s January 1, 2015 expansion made animal-incident data more complete while breaking its comparability. Three definitional mechanics do the damage: a widened incident pool that folded in breeder shipments and excess-baggage pets, a newly created annual denominator from year-end total-animals-transported filings, and a custody-based exclusion for cabin animals the carrier never takes control of. The older 14 CFR 234.13 regime reached fewer carriers, had no matching species scope, and no annual volume count. A genuine before-and-after comparison cannot be built from what the DOT publishes.
The U.S. Department of Transportation‘s animal-incident reporting rule changed on January 1, 2015, and the change is easiest to describe by what it didn’t do: it didn’t make the new numbers comparable to the old ones. Every cat and dog flown by a covered U.S. carrier became subject to incident reporting. Pets traveling as excess baggage and commercial breeder shipments — previously outside the cargo-only scope of 14 CFR 234.13 — came into the count.
More animals became visible. More context arrived. And the ability to line up any of it against what came before quietly broke.
DOT animal incident reporting now describes a population with three definitional mechanics that scramble any before-and-after reading: a widened incident pool, a newly created annual denominator, and a custody-based exclusion for cabin animals the carrier never assumes control of. A Western traveler scanning the tables to judge which transpacific airline is safest for a pet is reading numbers that cannot answer that question as posed.
Airlines have little incentive to volunteer this nuance. Ask a DOT observer how often the annual total-animals-transported figure gets cited next to an airline’s incident count, and the honest answer is: almost never. That omission is the whole problem.
What January 1, 2015 actually changed
The old rule, 14 CFR 234.13, treated animal incidents largely as a cargo problem. Its successor, Part 235, governs incidents dated January 1, 2015 or later, and it erased the line that had once separated a personal pet from a commercial breeder shipment. Under the changed scope, both categories generate reportable incidents.
That single expansion is why a raw incident-count comparison across the 2015 boundary fails as an exercise in like-for-like. Pets as excess baggage and breeder shipments didn’t create more incidents — they brought more animals under a reporting umbrella that hadn’t counted them before. A carrier’s post-2015 total could rise for no operational reason at all.
The annual filing that creates a denominator
The most underreported part of the 2015 change is the denominator. Under Part 235, a covered carrier must state how many animals it transported in its annual filing — even if it recorded zero reportable loss, injury, or death all year.
A spotless year still produces a data point. That total animals transported report is what makes any per-carrier normalization possible.
The expansion’s stated aim was to give incident reports the context they otherwise lacked, and this is the mechanism. With a volume figure, you can at least ask whether an airline’s incident count reflects risk or just volume. Without it, raw totals float free of any meaningful comparison.
None of the DOT publications reviewed here puts a figure on how breeder shipments moved a carrier’s count or rate. The rule confirmed that the reportable pool expanded, but it never separated out the breeder subset, so that slice of any carrier-level trend stays hidden.
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The custody line that keeps some animals invisible
The pets in cabin vs. cargo distinction is definitional under Part 235. Air transport begins at handover before departure and closes at delivery at the destination. That span is what defines custody.
A pet that stays at the seat with its passenger, outside the carrier’s control, is excluded by the rule’s own wording.
This is the blind spot that survives even after the 2015 expansion. Once a pet passes into the carrier’s handling chain, the data can record it — but a cabin animal that stays beside its owner for the entire trip leaves no trace. A carrier that moves thousands of in-cabin pets has none of them reflected in its incident totals.
The exclusion works in a specific direction: an in-cabin pet a carrier does take into custody — perhaps during a transfer or an operational disruption — is reportable if loss, injury, or death occurs during that custody window. The line isn’t cabin versus cargo. It’s custody versus no custody.
Where the data’s edge sits
What counts as a covered carrier depends on the airline, not the aircraft. To qualify, a carrier must be U.S.-based, fly scheduled passenger service, and operate at least one plane built for more than 60 passenger seats. Clearing that bar is what matters: a report is still owed for a flight that used a smaller aircraft seating 60 or fewer, so a regional trip does not escape the requirement.
Non-U.S. carriers sit outside this entirely. An airline based in Japan, Singapore, or anywhere else beyond the United States does not belong to the DOT reporting population.
The International Air Transport Association issues its Live Animals Regulations, which cover livestock, laboratory animals, protected species, and household pets. Those are operating standards for moving live animals by air, not a log of incidents. Because no one system generates both, a U.S. carrier’s incident figures have no common yardstick against a foreign airline’s practices.
The scope table below makes the boundary concrete: the row for a cat or dog flown by a non-U.S. carrier marks both incident reporting and the annual denominator as outside DOT Part 235.
| Scenario | Incident reportable under Part 235? | Included in annual total-animals-transported figure? | Basis |
|---|---|---|---|
| Pet transported in cargo on a scheduled passenger flight by a covered U.S. carrier | Yes, if loss, injury, or death occurs during carrier custody | Yes, if transported by the carrier during the calendar year | Part 235 and 235.3 |
| Pet transported as excess baggage by a covered U.S. carrier | Yes, if loss, injury, or death occurs during carrier custody | Yes | Part 235 definition of air transport |
| Commercial breeder shipment of a cat or dog | Yes, if loss, injury, or death occurs during carrier custody | Yes | Part 235 expanded animal definition |
| In-cabin pet that the carrier takes into custody | Yes, if the animal is in carrier custody and a reportable loss, injury, or death occurs | Yes, if transported by the carrier | Part 235 custody definition |
| In-cabin pet that remains with the passenger and is never taken into custody | No under the express cabin exclusion | Not specified in Part 235 | Part 235 express exclusion |
| Service animal accompanying a passenger without carrier custody | No under the same cabin-custody exclusion | Not specified in Part 235 | Part 235 express exclusion |
| Animal other than a cat or dog | Not specified as a covered animal by the Part 235 definition | Not specified | Part 235 definition names cats and dogs |
| Cat or dog on a flight operated by a covered carrier using an aircraft with 60 or fewer seats | Yes, if the incident occurs during carrier custody | Yes, if transported by the carrier | Part 235 carrier threshold and 235.3 reporting clause |
| Cat or dog flown by a non-U.S. carrier | No DOT Part 235 report under the covered-carrier definition | No DOT Part 235 denominator | Part 235 applies to qualifying U.S. carriers |
| Source: U.S. Government Publishing Office / GovInfo | |||
How a report actually moves from the tarmac to the public
Covered carriers submit required incident reports through an online system the DOT set up. Incidents dated January 1, 2026 or later are filed through ACERS, per DOT’s 2026 guidance. The system’s existence is confirmed; a publicly queryable live database is not.
What reaches the public is DOT’s published incident material, which lists the airline and flight, the date, a description of the animal, a narrative, the cause, and any corrective action. That’s a curated set of fields, not raw submission data.
It’s enough to see what happened. It’s not enough to reconstruct a carrier’s full annual animal movement without the annual filing.
That gap is where the rules get very quiet. The online submission system shapes what gets published, and no confirmed material here says how quickly reports appear, how they are cleaned, or whether corrections are surfaced. For a traveler trying to read the data, the publication step is the last unknowable piece of the chain.
Key terms
- Part 235
- Part 235 is the U.S. Department of Transportation rule that requires covered airlines to report animal incidents and to file an annual count of the animals they transport. It applies to incidents dated January 1, 2015 or later, replacing the narrower 14 CFR 234.13 regime that had treated animal incidents mainly as a cargo concern. For anyone reading DOT pet-safety tables, Part 235 is the dividing line: its widened animal definition and new volume field are why the numbers on either side of 2015 describe different populations.
- 14 CFR 234.13
- 14 CFR 234.13 was the pre-2015 federal rule governing how U.S. carriers reported animal incidents. It reached fewer carriers and fewer animals than its successor, and it required no annual count of animals transported. Its narrower scope is the reason a pre-2015 incident total cannot be set against a post-2015 one as if the two measured the same thing.
- ACERS
- ACERS is the online system U.S. carriers use to file required animal-incident reports with the DOT. Incidents dated January 1, 2026 or later are filed through it, per DOT’s 2026 guidance. It is the current filing channel for the data this article examines, though no publicly queryable live database of those submissions is confirmed.
- Air transport
- Under Part 235, air transport is the window during which a carrier has custody of an animal, running from handover before departure to delivery at the destination. The definition decides whether an incident is reportable at all. It is also why in-cabin pets that never leave their owner’s side stay out of the DOT dataset entirely.
Questions? Answers.
Can today’s DOT animal-incident numbers be compared with figures from before 2015?
No. The earlier 14 CFR 234.13 regime reached fewer carriers, applied to fewer animals, and included no annual volume count. The matching species scope, carrier population, and denominator that a real year-over-year comparison needs do not exist in the pre-2015 data.
Does the 60-seat rule let a covered airline skip reporting incidents on its smaller regional flights?
No. Coverage follows the carrier, not the airplane. Once an airline qualifies as covered by having at least one aircraft designed for more than 60 seats, incidents on its regional flights are reportable even when the aircraft on a particular trip seats 60 or fewer.
Are in-cabin pets that never leave their owner’s side included in the DOT data?
No. Part 235 defines air transport as the window in which the carrier has custody. An in-cabin pet that remains with the passenger and is never taken into custody falls outside that definition by express exclusion.
Do non-U.S. airlines appear in the DOT animal-incident data?
No. Part 235 applies only to qualifying U.S. carriers in scheduled passenger service with at least one aircraft above the 60-seat design threshold. An airline based in Japan, Singapore, or anywhere outside the United States sits outside the DOT reporting population.
