Service Animals in Laboratories

The ADA is the first comprehensive civil rights law focused on persons with disabilities. The purpose is to protect the rights of Americans with disabilities by prohibiting discriminations against people with disabilities, their families, and friends. The ADA is broken down into the following five Titles:

• Title I – Employment
• Title II – State and Local Government
• Title III – Places of Public Accommodation
• Title IV – Telecommunications
• Title V – Miscellaneous

The ADA definition of disability is a legal term, not a medical term. Protects people who meet the definition of disability:

1. A person has a physical or mental impairment that substantially limits a major life activity

2. A person has a record of such an impairment; or

3. A person is regarded as having such an impairment.

Service Animals are usually dogs. However, a miniature horse can be a Service Animal. A Service Animal can be any breed, any size, any sex, altered or intact, and any mixes. A breed is often chosen based on a person’s work needs, lifestyle, preferences, and temperament. Service animals can come from a training program or can be trained by the individual. Trained tasks must directly relate to the person’s disability. 

Public and private entities covered by the ADA are required to modify policies, practices, or procedures to permit the use of a trained service animal by an individual with a disability.

• Title II – State and Local Governments à § 35.136 Service animals
• Title III –Public Accommodations (businesses, nonprofits, etc.) à § 36.302(c) Service animals

What about employers under Title I?

• Service animals are not specifically defined.
• Should be treated as an accommodation request.

You can legally ask two questions to make the determination:

1. Is the service animal required because of a disability?
2. What work or task has the service animal been trained to perform?

Do Not:

1. Interrupt a service animal that is working.
2. Touch a service animal.
3. Offer food, toys, or treats to a service animal.
4. Talk or make eye contact with the service animal.

Please be respectful to the handler's privacy. 

• Students who require the use of a service animal in hazardous environments assume responsibility for all risks involved in the use of their service animal in lab areas, including the risk of exposure to hazardous items to their service animal.
• The student will need to work with the instructor and DRC to develop a plan to ensure the safety of the service animal and others within the area while the student is participating or working within a hazardous environment. The plan will include emergency response measures, PPE selection, and other control measures, as necessary.
• Follow UofL’s policy for use of service and emotional support animals on campus.
• Connect with the DRC prior to the start of the laboratory class.
• Meet with the instructor and/or lab manager prior to the beginning of the semester to discuss expectations and protocol recommendations.
• Discuss location of student station and location for the service animal whether this is in the lab, or another agreed upon location.
• Ensure the service animal is well-behaved and does not cause a disruption, distraction, or injury to others in the area. The service animal should not interfere with the ability of others to use the space.
• Pay for any damage to the facility and/or equipment caused by the service animal.
• Provide any necessary personal protective equipment (PPE) for the service animal.

• Contact, as needed/required, the UofL Department of Environmental Health and Safety (DEHS) regarding lab protocols to address a possible hazardous environment.
• Work with the student, DRC, and as needed DEHS, to develop a plan to ensure the safety of the service animal and others within the area while the student handler is participating or working within a hazardous environment. The plan will include emergency spill response measures, PPE selection, and other control measures, as necessary.
• Any list given to all students regarding required PPE should also include a list of required PPE for any student bringing a service animal to the lab.
• Coordinate with DRC and the student to visit the lab prior to the start of class, as needed.
• Discuss location of the student station and location for the service animal whether this is in the lab, or another agreed upon location.
• Monitor the environment and respond to any disruptions by discussing the situation with the student.
• Contact the DRC office to report or discuss behavioral problems or safety concerns regarding the service animal.

• Coordinate with the student disclosing the need for a service animal in a laboratory.
• Facilitate student contact with instructor and appropriate lab manager.
• Meet with the instructor and student to identify appropriate expectations and protocol, such as recommendations around the service animal in the lab. This includes discussing appropriate personal protective equipment (PPE) for the service animal.
• Coordinate with instructor, student, and lab manager to visit the lab prior to the start of class, as needed.

Service animals in labs should be “wearing” at least the equivalent PPE that is required for students to wear when attending/participating in the lab. If appropriate PPE for the service animal is not brought to the lab by the student/handler, the service animal will not be permitted into the laboratory. Any PPE worn by the service animal will be purchased by the student/handler.

PPE may include the following: 

Minimum: 

• Goggles,
• Boots,
• Lab coat, and
• Mats

  Additional protective equipment: 

• Hearing protection,
• Harness,
• Leash and necessary controls.

Instructors who have labs may want to include the following language in their course description and syllabus. 

Due to the nature of this class, any student with a disability who has and plans to bring their service animal to the lab needs to coordinate with the instructor and the DRC as early as possible to ensure the safety of the service animal. The DRC may partner with the DEHS to ensure the safety of the animal. Students are  encouraged to connect with the DRC once registered for the class, and no later than before the class begins to ensure all necessary precautions are taken prior to the first day of the lab.

• Down/stay on command location for up to 4-hours.
• Stay “placed” on a mat or in a portable crate.
• Does not automatically retrieve items from the floor without command.
• Enter safety shower.
• Trained to find an exit.
• Not adversely reactive to loud noises (ex: dropped items, explosions, sirens, or fire alarms).
• The service animal must not vocalize, bark, or growl inappropriately.
  • If the service animal is trained to alert by vocalizing, the instructor/lab manager must be aware of the circumstances under which the service animal would vocalize. Disruptive, extended vocalizing or barking will not be permitted, unless in proper context.
• The service animal must not behave aggressively towards other people such as snapping, snarling, growling, charging, swiping, etc.
• The service animal must not jump up on other people.

• The animal is out of control, and the handler does not take effective action to control the animal.
• The animal is not housebroken.
• Poses a direct threat to health or safety of others or causes significant property damage.
• The Service Animal's presence results in a fundamental alteration of University program.
• The handler does not comply with stated responsibilities.
• Excessive barking.
• The Service Animal or its presence creates unmanageable disturbance or interference with the university community.

For questions or concerns about the removal of a service animal, please contact the Department Chair, DRC, DEHS, or ADA Office.

Not all laboratory environments are safe for Service Animals. Hazard identification, risk assessments, and lab safety plans are important components to evaluate. Hazards may include biological, chemical, radioactive, and equipment. The US Department of Health and Human Services provides technical guidelines on the level of PPE necessary for laboratory environments. UofL’s DEHS provides environmental, health, and safety services through technical and regularity compliance assistance.  UofL’s DEHS can assess the course and laboratory needs, evaluate the hazards and risks, and determine if a Service Animal can be in the laboratory.

Places where service animals are excluded:

• Biosafety Level (BSL) spaces classified as moderate risk, and high to maximum risk. Such as BSL-2, BSL-3, and BSL-4 spaces.
• Vivariums
• Sterile/Clean Rooms
• Radioactive Material Areas
• Cadaver Labs
• Operating Rooms
• Surgical Suites
• Sterile Areas
• Food Prep Areas

For questions or concerns about the exclusion of a service animal, please contact the Department Chair, DRC, DEHS, or ADA Office.