As science and STEM laboratories rightfully become more inclusive for any person with a disability, the situation might arise when an employee or student would have a reasonable accommodation request for a service animal. In accordance with the Americans with Disabilities Act (ADA), there are procedures and expectations for the employer or for the institution to adhere to, in addition to providing a safer instructional space for both the student/employee and the service animal. Better legal safety standards and better professional safety practices are expected to be followed in all circumstances for both the student/employee and the service animal. 

Title I of the ADA covers employment and applies to private employers with 15 or more employees, as well as to state and local governments. Some state and local laws may require employers with fewer employees to provide reasonable accommodations. Title I ensures that employers do not discriminate against a qualified individual with a disability. This applies to job application procedures, hiring, advancement and discharge of employees, worker’s compensation, job training, and other terms, conditions, and privileges of employment. (See https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XIV/part-1630.) 

Title II applies to state and local government programs; they should not discriminate in the services provided to those with disabilities. Title III mandates that private businesses and nonprofit organizations should not exclude public accommodations to people with disabilities, including those using service animals in all areas of the facility where the public is allowed access. (See https://www.ecfr.gov/current/title-28/chapter-I/part-35.) 

As of March 15, 2011, under Titles II and III of the ADA, service animals are limited to dogs. However, businesses and state and local government employers are allowed to have miniature horses as a reasonable modification, subject to certain limitations. Emotional support animals, comfort or companion animals, therapy dogs, or other species of animals, either wild or domestic, are not to be constituted as a “service animal” under Title II and Title III. (See https://adata.org/guide/service-animals-and-emotional-support-animals.)

If an employee or student has a request for a reasonable accommodation relative to a disability, the employer or institution may ask for more extensive medical information about the employee’s disability and the need for a service animal to help better perform job duties to evaluate a request. In some situations, additional documentation about the service animal may need to come from some other source, such as whoever trained the service animal. Conversely, on the occasion that it is not obvious what assistance the service dog (or approved miniature horse) provides between employees or between faculty and student, under Title II and III of the ADA, only two questions are allowed to be asked: 1) Is the service dog (or approved miniature horse) required? and 2) What specific task does the service dog (or approved miniature horse) provide? Allergies to animal dander or fear are not valid reasons for an employer, institution, or faculty member to deny access or inclusion in the classroom or laboratory. (See https://www.ada.gov/service_animals_2010.htm.)

A reasonable accommodation by definition is any change to the application or hiring process, to the job, to the way the job is done, or the work environment that allows a person with a disability who is qualified for the job to perform the essential functions of that job and enjoy equal employment opportunities. (See https://adata.org/service-animal-resource-hub/work.)

There is an expectation that the employer or institution will grant the reasonable accommodation request under the following conditions: “a) the employee’s disability and the service animal’s function are related; b) the service animal will improve the worker’s ability to perform their job; c) the animal has had sufficient training to not be a disruptive presence in the workplace; and d) the accommodation does not present an undue hardship.” (See https://nwadacenter.org/index.php?q=factsheet/service-animals-employment-accommodation.)

If the accommodation is approved, the employee or student would be responsible for supervising and caring for the animal. It is critical that the monitoring and care for the animal by the employee or student is agreed upon with the employer or institution prior to accommodation approval. In the case of school employees, teachers must be assured that the service animal will not disrupt lectures, laboratories, meetings, or other events. (See Teaching Chemistry to Students with Disabilities: A Manual for High Schools, Colleges, and Graduate Programs, 4th Edition.)

The service animal is expected to be specially trained and obedient. All students working in a laboratory setting where there is a service animal must be advised not to approach or pet the animal. A service animal generally wears a special harness unit to identify it as a service animal and which the animal is trained to use. If the animal is wearing the special harness, it is considered “on duty.”

In general, the service animal in a lab should have an assigned area on a special mat during class time. The location needs to be found with the help of the faculty member. It is critical that the mat will not present an obstruction or trip/fall hazard to other students’ movement in the lab. It also must be within unobstructed eyesight between the employee or student requiring the service animal and the service animal itself. An alternative location for the service animal without a mat should be in an area that is most likely free of biological or chemical debris or potential glass debris.  

A number of potential biological, chemical, and/or physical hazards are present in the lab that could result in risks and injuries for service animals. Examples include, but are not limited to, dripping, spilled, or splashed chemicals; broken glass or other sharps on the floor; heavier-than-air vapors/fumes/particulates; solids brushed off a bench; high noise levels; projectiles; trip and/or slip fall hazards; and more. Any laboratory investigation that uses a risk group 2 or higher biological material would need to have a hazard analysis and risk assessment performed before the animal arrives. A needs assessment should be strongly considered for any approved service dog when a laboratory involving radioactive materials is planned; generally, service animals should not be permitted during these laboratories. 

A number of schools require the use of safety equipment (personal protective equipment) for the service animal. Included are protective foot booties, a protective coat (a raincoat would suffice), and indirectly vented chemical splash goggles or safety glasses as appropriate for the service animal. It is the financial responsibility of the student or employee with a disability to bear the costs of such devices for a service animal. (See Service Animals in Chemistry Laboratories A Guide for UL Chemistry Faculty.)

Some students and teachers with disabilities have had to face a number of struggles regarding acceptable accommodations in an academic laboratory and the use of service animals. In some cases, legal assistance was necessary to have approved entry into the lab or classes with their service dog. As author Nina Notman noted, “Many institutions remain underprepared for hosting assistance animals in the lab, leaving scientists without the support they need.” To learn more about these challenges, read Notman’s article, “Fit for a Dog: Clearing Barriers to Campus Canines,” published in 2021 in Nature and mentioned in this article: https://www.chemedx.org/blog/service-dogs-chemistry-lab.

Science/STEM teachers and supervisors who have not had the experience of providing accommodations for a student with a service dog in a lab at their school need to discuss the topic with their supervisors/administrator or with the designated Accessibility Counselor. This will help them respond appropriately to a student or employee who needs a service dog in their labs and classrooms. For additional guidance on this issue, see the following resource article by Patricia Ann Redden of St. Peter’s University, “Service Dogs and Safety in Academic Laboratories.”
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Safety Blog Acknowledgement. NSTA Chief Safety Blogger Dr. Ken Roy wishes to sincerely thank Brian C. Duffy, Ph.D., a nationally recognized Wayne Community College chemistry instructor, NSTA Research in Science Education Committee member, and former NSTA Safety Advisory Board Chair for his professional review of this commentary.

Submit questions regarding safety to Ken Roy at safersci@gmail.com. Follow Ken Roy on Twitter: @drroysafersci.