Practical Solutions • Workplace Success 

1 

Service Animals in the 

Workplace 

Accommodation and Compliance Series
Practical Solutions • Workplace Success 

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Preface 

The Job Accommodation Network (JAN) is a service of the Office of Disability 

Employment Policy of the U.S. Department of Labor. JAN makes documents available 

with the understanding that the information be used solely for educational purposes. 

The information is not intended to be legal or medical advice. If legal or medical advice 

is needed, appropriate legal or medical services should be contacted. 

JAN does not endorse or recommend any products or services mentioned in this 

publication. Although every effort is made to update resources, JAN encourages 

contacting product manufacturers/vendors and service providers directly to ensure that 

they meet the intended purposes. This guarantees that the most up-to-date information 

is obtained. 

The following document is not copyrighted and reproduction is encouraged. Section 

105 of the Copyright Law provides that no copyright protection is available for works 

created by the U.S. Government. Therefore, all works created by JAN fall under this 

provision. While individuals may use such work with impunity, individuals may not 

claim copyright in the original government work, only in the original material added. 

Individuals may access the full text of the law from the U.S. Copyright Office 

http://www.loc.gov/copyright. Please note that specific information cited by JAN may be 

copyrighted from other sources. Citing secondary sources from a JAN publication may 

violate another organization's or individual's copyright. Permission must be obtained 

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are not altered, and that proper credit is given to JAN as the source of the information. 

For further information regarding this or any other document provided by JAN, please 

contact JAN. 

Authored by Linda Carter Batiste, J.D., and Carmen Fullmer, M.S. Updated 06/17/11. 
Practical Solutions • Workplace Success 

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JAN’S ACCOMMODATION AND COMPLIANCE SERIES 

Introduction 

JAN’s Accommodation and Compliance Series is designed to help employers determine 

effective accommodations and comply with title I of the Americans with Disabilities Act 

(ADA). Each publication in the series addresses a specific medical condition or topic 

and provides information about the condition or topic, ADA information, accommodation 

ideas, and resources for additional information. 

The Accommodation and Compliance Series is a starting point in the accommodation 

process and may not address every situation. Accommodations should be made on a 

case by case basis, considering each employee’s individual limitations and 

accommodation needs. Employers are encouraged to contact JAN to discuss specific 

situations in more detail. 

For information on assistive technology and other accommodation ideas, visit JAN's 

Searchable Online Accommodation Resource (SOAR) at http://AskJAN.org/soar. 

Information about Service Animals 

What is a service animal? 

A service animal is an animal that performs a task or tasks for a person with a disability 

to help overcome limitations resulting from the disability. Federal law defines service 

animal as “any dog that is individually trained to do work or perform tasks for the benefit 

of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or 

other mental disability. Other species of animals, whether wild or domestic, trained or 

untrained, are not service animals for the purposes of this definition. The work or tasks 

performed by a service animal must be directly related to the individual ́s disability" 

(DOJ, n.d.). 

What types of work or tasks do service animals perform? 

According to the Department of Justice (n.d.), "examples of work or tasks include, but 

are not limited to, assisting individuals who are blind or have low vision with navigation 

and other tasks, alerting individuals who are deaf or hard of hearing to the presence of 

people or sounds, providing non-violent protection or rescue work, pulling a wheelchair, 

assisting an individual during a seizure, alerting individuals to the presence of allergens, 

retrieving items such as medicine or the telephone, providing physical support and 

assistance with balance and stability to individuals with mobility disabilities, and helping 

persons with psychiatric and neurological disabilities by preventing or interrupting 

impulsive or destructive behaviors. The crime deterrent effects of an animal ́s presence 

and the provision of emotional support, well-being, comfort, or companionship do not 

constitute work or tasks for the purposes of this definition.” 
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What is the difference between service, therapy, companion, and social/therapy 

animals? 

According to the Delta Society, a human-services organization dedicated to improving 

people's health and well-being through positive interactions with animals: 

Service animals are legally defined under title III of the Americans with 

Disabilities Act and are trained to meet the disability-related needs of their 

handlers who have disabilities. The ADA protects the rights of individuals with 

disabilities to be accompanied by their service animals in public places. Service 

animals are not considered 'pets' (Delta Society, n.d.). 

Therapy animals are not legally defined by federal law, but some states 

have laws defining therapy animals. They provide people with contact to 

animals, but are not limited to working with people who have disabilities. 

They are usually the personal pets of their handlers, and work with their 

handlers to provide services to others. Federal laws have no provisions for 

people to be accompanied by therapy animals in places of public 

accommodation that have "no pets" policies. Therapy animals usually are 

not service animals (Delta Society, n.d.). 

A companion animal is not legally defined, but is accepted as another term 

for pet (Delta Society, n.d.). 

Social/therapy animals have no legal definition. They often are animals 

that did not complete service animal or service dog training due to health, 

disposition, trainability, or other factors, and are made available as pets for 

people who have disabilities. These animals might or might not meet the 

definition of service animals (Delta Society, n.d.). 

Service Animals and the Americans with Disabilities Act

Because more people are using service animals, employers are asking more questions 

about service animals in the workplace. The following is a summary of some of those 

questions. The answers are based on informal guidance from the Equal Employment 

Opportunity Commission (EEOC) and do not represent the EEOC’s formal position on 

these issues or legal advice. 

Does title I of the ADA require employers to automatically allow employees with 

disabilities to bring their service animals to work? 

Title III (public access) of the ADA requires a public accommodation to modify policies, 

practices, or procedures to permit the use of a service animal by an individual with a 

disability (DOJ, n.d.). Title III also requires public accommodations to make reasonable 

modifications in policies, practices, or procedures to permit the use of a miniature horse 
Practical Solutions • Workplace Success 

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by an individual with a disability if the miniature horse has been individually trained to do 

work or perform tasks for the benefit of the individual with a disability (DOJ, n.d.). 

But what about title I (employment) of the ADA? According to the EEOC, title I does not 

require employers to automatically allow employees to bring their service animals to 

work. Instead, allowing a service animal into the workplace is a form of reasonable 

accommodation. 

What this means for employers: Employers must consider allowing an employee with a 

disability to use a service animal at work unless doing so would result in an undue 

hardship. In addition, the ADA allows employers to choose among effective 

accommodations, although providing a substitute accommodation for a service animal 

could bring up other tricky issues (see question 4 below). 

What is the definition of service animal under title I of the ADA? 

As mentioned previously, title III (public access) regulations define service animal as 

“any dog that is individually trained to do work or perform tasks for the benefit of an 

individual with a disability, including a physical, sensory, psychiatric, intellectual, or 

other mental disability. Other species of animals, whether wild or domestic, trained or 

untrained, are not service animals for the purposes of this definition. The work or tasks 

performed by a service animal must be directly related to the individual ́s disability. 

Examples of work or tasks include, but are not limited to, assisting individuals who are 

blind or have low vision with navigation and other tasks, alerting individuals who are 

deaf or hard of hearing to the presence of people or sounds, providing non-violent 

protection or rescue work, pulling a wheelchair, assisting an individual during a seizure, 

alerting individuals to the presence of allergens, retrieving items such as medicine or 

the telephone, providing physical support and assistance with balance and stability to 

individuals with mobility disabilities, and helping persons with psychiatric and 

neurological disabilities by preventing or interrupting impulsive or destructive behaviors. 

The crime deterrent effects of an animal ́s presence and the provision of emotional 

support, well-being, comfort, or companionship do not constitute work or tasks for the 

purposes of this definition” (DOJ, n.d.). 

But what about title I (employment) of the ADA? According to the EEOC, there is no 

specific definition of service animal under title I, and title III regulations do not apply to 

questions arising under title I. 

What this means to employers: Because there is not a specific definition of service 

animal under title I, employers may have to consider allowing an employee to bring in 

an animal that does not meet the title III definition of service animal, such as a therapy 

or emotional support animal. However, employers do not have to allow an employee to 

bring an animal into the workplace if it is not needed because of a disability or if it 

disrupts the workplace.
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What kind of documentation can employers ask for related to a service animal? 

What if the employee's doctor was not involved in the acquisition of the service 

animal or the employee trained his own service animal and nobody else was 

involved so the typical kind of medical documentation that employers ask for is 

not be available? What might be considered sufficient documentation in this type 

of situation? 

Under the ADA, employers have the right to request reasonable documentation that an 

accommodation is needed (EEOC, 2002). However, according to informal guidance 

from the EEOC, employers need to be aware that sometimes reasonable 

documentation is not always going to be from a doctor or some other health care 

professional. In some cases the documentation should come from the appropriate 

provider of a service. In the case of a service animal, the appropriate documentation 

might be from whoever trained the service animal. 

The goal of an employer is to understand why the service animal is needed and what it 

does for the person, so the training is important. If an employee has a service animal in 

a workplace where there could be lots of different kinds of distractions, lots of things 

going on, the employer has the right to require that the service animal be fully trained 

and capable of functioning appropriately, not just for the employee with the disability, 

but also in terms of the setting. An employee who trains his or her own service animal 

needs to be able to document or demonstrate that the service animal is in fact trained 

and will not disrupt the workplace. 

What this means for employers: When an employee with a disability requests to use a 

service animal at work, the employer has the right to request documentation or 

demonstration of the need for the service animal, that the service animal is trained, and 

that the service animal will not disrupt the workplace. However, this documentation may 

not be available from a healthcare provider so the employer may need to consider other 

sources for the documentation. 

If an employee wants to bring his service animal to work to help with personal 

medical needs (e.g., an employee with diabetes wants to bring his service animal 

to work to help monitor his blood sugar level), can the employer deny the request 

and ask the employee to take care of his medical needs in another way?

According to the EEOC, if the service animal has been trained to help with the 

employee’s medical needs, the employee has a right to ask that, as a reasonable 

accommodation, the service animal be allowed to accompany him to work. 

The employer has a right to know that the animal is actually trained and what the animal 

does for the employee. However, the employer probably cannot insist that the person 

take care of his medical needs in a different way if this is the way the employee does it; 

under the ADA an employer cannot require employees to use other medical 

treatment/procedures. 
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What this means for employers: In general, employers should not be involved in 

employees’ personal medical decisions so an employer should not deny an employee’s 

request to use his service animal at work if the animal helps the employee with his or 

her personal medical needs, unless the employer can show undue hardship. 

Who is responsible for taking care of a service animal at work? 

The employee is responsible for taking care of the service animal, including making 

sure the animal is not disruptive, keeping it clean and free of parasites, and taking it out 

to relieve itself as needed. 

What this means for employers: Employees are responsible for the care of their service 

animals, but employers may have to provide accommodations that enable the 

employees to do so. When an employee is allowed to bring a service animal to work, 

the employer should consult with the employee to find out what accommodations are 

needed to care for the animal. For example, an employee might need to adjust his 

break times to take his service animal outside. 

Do employers have to create a relief area for a service animal when an employee 

with a disability uses the service animal in the workplace?

The EEOC does not have any formal guidance regarding whether an employer must 

create an animal relief area for an employee who uses a service animal, but this should 

rarely be an issue because there is almost always a place outside, close to the worksite, where the animal can relieve itself. For example, the animal could relieve itself in 

an alley behind the work-site, a grassy area close to the work-site, or even close to a 

sidewalk leading to the building. Of course the employer could require the employee to 

clean up after the animal. 

 

To date, the EEOC has not addressed what an employer's obligation would be to create 

a relief area in the event there is absolutely no existing place for the service animal to 

relieve itself. 

What this means for employers: From a practical standpoint, an employer faced with a 

request to create a relief area for a service animal might want to consider doing so even 

though it is not clearly required as an accommodation under the ADA because 

otherwise the employee is not going to be able to use his or her service animal at work. 

Do employers have to allow employees to train service animals in the workplace? 

Under the ADA, only employees with disabilities are entitled to reasonable 

accommodations so if an employee without a disability is training a service animal for 

someone else, there is no accommodation obligation under the ADA. For employees 

with disabilities, an employer has a valid concern about the potential disruption a 

service animal in training might create so might not have to allow the employee to bring 
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in the service animal until it is fully trained or at least until it can be in the workplace 

without disruption. Some states have laws addressing access for service animals in 

training, so employers also should check their state laws. 

What this means for employers: When an employee asks to bring in a service animal in 

training, the employer should check state laws first. If state law does not address 

access for service animals in training, then the employer should next determine whether 

the employee who is making the request has a disability and needs the service animal 

because of the disability. If the employee does have a disability, then the employer 

needs to get more information to determine whether the service animal will be disruptive 

(e.g., the employer could have the employee demonstrate the animal’s behavior and 

current level of training). 
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Accommodating Employees Who Use Service Animals 

Note: People use service animals for a variety of reasons, so their accommodation 

needs will vary. The following is only a sample of the accommodation possibilities 

available. Numerous other accommodation solutions may exist. 

Questions to Consider: 

1. What limitations is the employee who uses a service animal experiencing? 

2. How do these limitations affect the employee and the employee’s job performance? 

3. What specific job tasks are problematic as a result of these limitations? 

4. What accommodations are available to reduce or eliminate these problems? Are all 

possible resources being used to determine possible accommodations? 

5. Has the employee who uses the service animal been consulted regarding possible 

accommodations? 

6. Once accommodations are in place, would it be useful to meet with the employee 

who uses the service animal to evaluate the effectiveness of the accommodations and 

to determine whether additional accommodations are needed? 

7. Do supervisory personnel and employees need training regarding the use of service 

animals? 

Accommodation Ideas: 

Using a service animal at work: 

 Allow the employee with a disability to bring his or her service animal to work. 

 Allow the employee to take leave in order to participate in individualized service 

animal training. 

 Provide the employee with a private/enclosed workspace. 

 Provide the employee with an office space near a door and/or out of high traffic 

areas. 

 Establish an accessible path of travel that is barrier-free. 

 Allow equal access to employee break rooms, lunchrooms, rest rooms, meeting 

rooms, and services provided/sponsored by the employer. 

Caring for a service animal at work: 

 Provide a designated area where the employee can tend to the service animal’s 

basic daily needs, e.g., eating or bodily functions. 
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 Allow periodic breaks so the employee can care for the service animal’s basic 

daily needs. 

 Provide a designated area the service animal can occupy until the employee’s 

shift ends if the employee only requires the service animal to travel to and from 

work. 

 Provide general disability awareness training on the use of service animals in the 

workplace. 

Dealing with coworkers who are allergic to the service animal: 

 Allow the employees to work in different areas of the building. 

 Establish different paths of travel for each employee. 

 Provide one or each of the employees with private/enclosed workspace. 

 Use a portable air purifier at each workstation. 

 Allow flexible scheduling so the employees do not work at the same time. 

 Allow one of the employees to work at home or to move to another location. 

 Develop a plan between the employees so they are not using common areas - 

such as the break room and restroom - at the same time. 

 Allow the employees to take periodic rest breaks if needed, e.g., to take 

medication. 

 Ask the employee who uses the service animal if (s)he is able to temporarily use 

other accommodations to replace the functions performed by the service animal 

for meetings attended by both employees. 

 Arrange for alternatives to in-person communication, such as e-mail, telephone, 

teleconferencing, and videoconferencing. 

 Ask the employee who uses a service animal if (s)he is willing to use dander care 

products on the animal regularly. 

 Ask the employee who is allergic to the service animal if (s)he wants to, and 

would benefit from, wearing an allergen/nuisance mask. 

 Add HEPA filters to the existing ventilation system. 

 Have the work area - including carpets, cubicle walls, and window treatments - 

cleaned, dusted, and vacuumed regularly. 

Interacting with a service animal: 

 Address the person when approaching a person with a disability who is 

accompanied by a service animal. 

 Remember that service animals are working and are not pets. 

 Do not touch, pet, or feed treats to a service animal without the owner’s 

permission. 
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Situations and Solutions: 

A state employee with a mobility impairment uses a scooter and a service animal. The 

employer was concerned about how the employee would tend to the service animal’s 

basic daily needs. JAN provided product information on a scooper with a long handle so 

the employee could use his scooter to go outside and tend to his service animal's 

“restroom” breaks. 

An insurance agency employee with multiple sclerosis and anxiety requested that the 

employer permit her to use a service dog on the job for mobility and stress reduction. 

The employer agreed to allow the employee to bring her service animal to work, 

provided training to staff on service animals as workplace accommodations, and 

installed new doors that were easier for the individual to open. 

A newly hired teacher with a seizure disorder used a service animal to alert her that a 

seizure was coming on. The school had a “no animal” policy. The school allowed the 

teacher to bring her service animal to work and to keep it with her in her classroom. She 

was also provided breaks to take the service animal outside and given the opportunity 

to educate coworkers about the use of service animals. The employer reported that the 

accommodation cost nothing and it was good for the students to see a service animal at 

work. 

A truck driver who used a service animal requested that his dog be left in his truck 

during maintenance and cleaning, meetings, and the completion of paperwork. The 

employer purchased a dog kennel for the times when the driver had to leave his vehicle 

and remain in the office building for extended periods of time. 

A dental office hired a receptionist with a vision impairment to work in the front office. 

The new employee had acquired a service animal, but did not yet have accrued 

vacation time that could be used for service animal training. The employer allowed the 

receptionist to take unpaid leave to attend service animal training. 

Products: 

There are numerous products that can be used to accommodate people with limitations. 

JAN's Searchable Online Accommodation Resource (SOAR) at http://AskJAN.org/soar 

is designed to let users explore various accommodation options. Many product vendor 

lists are accessible through this system; however, upon request JAN provides these 

lists and many more that are not available on the Website. Contact JAN directly if you 

have specific accommodation situations, are looking for products, need vendor 

information, or are seeking a referral. 
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References 

Delta Society (n.d.) Service animal basics. Retrieved June 15, 2011, from 

https://www.deltasociety.org/Page.aspx?pid=303 

Department of Justice (n.d.). Title III regulations. Retrieved June 15, 2011, from 

http://www.ada.gov/regs2010/titleIII_2010/titleIII_2010_withbold.htm 

Equal Employment Opportunity Commission. (2002). Reasonable accommodation and 

undue hardship under the ADA. Retrieved June 15, 2011, from 

http://www.eeoc.gov/policy/docs/accommodation.html 
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Resources 

Job Accommodation Network 

West Virginia University 

PO Box 6080 

Morgantown, WV 26506-6080 

Toll Free: (800)526-7234 

TTY: (877)781-9403 

Fax: (304)293-5407 

jan@AskJAN.org 

http://AskJAN.org 

The Job Accommodation Network (JAN) is a free consulting service that provides 

information about job accommodations, the Americans with Disabilities Act (ADA), and 

the employability of people with disabilities. 

Office of Disability Employment Policy 

200 Constitution Avenue, NW, Room S-1303 

Washington, DC 20210 

Toll Free: (866)633-7635 

TTY: (877)889-5627 

Fax: (202)693-7888 

http://www.dol.gov/odep/ 

The Office of Disability Employment Policy (ODEP) is an agency within the U.S. 

Department of Labor. ODEP provides national leadership to increase employment 

opportunities for adults and youth with disabilities while striving to eliminate barriers to 

employment. 

Animal Legal & Historical Web Center 

Michigan State University College of Law 

East Lansing, MI 48824-1300 

Direct: (517)432-6800 

Editor@animallaw.info 

http://www.animallaw.info 

The Animal Law and History Web Center is a project of Michigan State University 

College of Law. It first opened in August 2002. Their goals are: to provide a Web Library 

of legal and policy materials as relates to animals, to provide expert explanation of 

materials for both the lawyer and the non-lawyer, to be an education center for this 

material, offering courses at different levels of education with and without credit, and to 

provide an historical perspective about social and legal attitudes toward animals and 

how we got to our present perspective. 
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Delta Society 

875 - 124th Avenue NE #101 

Bellevue, 98005 

Direct: (425)679-5500 

Fax: (425)679-5539 

info@deltasociety.org 

http://www.deltasociety.org/ 

The Delta Society is the leading international resource for the human-animal bond. 

Delta Society has been the force to validate the important role of animals for people's 

health and well-being by promoting the results of research to the media and health and 

human services organizations. 

Guide Dog Foundation for the Blind, Inc. 

371 East Jericho Turnpike 

Smithtown, NY 11787-2976 

Toll Free: (800)548-4337 

Direct: (631)930-9000 

Fax: (631)361-5192 

info@guidedog.org 

http://www.guidedog.org 

Since 1946, the Guide Dog Foundation for the Blind, Inc. has provided guide dogs free 

of charge to blind people who seek enhanced mobility and independence. 

Psychiatric Service Dog Society 

PO Box 754 

Arlington, VA 22216 

Direct: (571)216-1589 

joan.esnayra@mac.com 

http://www.psychdog.org/ 

The Psychiatric Service Dog Society is a 501(c)3 nonprofit organization dedicated to 

responsible Psychiatric Service Dog (PSD) education, advocacy, research and training 

facilitation. The Society provides essential information for persons disabled by severe 

mental illness, who wish to train a service dog to assist with the management of 

symptoms. 

Seeing Eye, The 

P.O. Box 375 

Morristown, NJ 07963 

Direct: (973)539-4425 

Fax: (973)539-0922 

info@seeingeye.org 

http://www.seeingeye.org 
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The Seeing Eye, Inc., is the oldest existing dog guide school in the world. Twelve times 

a year, as many as 24 students at a time visit the Morristown, N.J., campus to discover 

the exhilarating experience of traveling with a Seeing Eye dog. 

Service Animal Registry of America (SARA) 

PO Box 607 

Midlothian, TX 76065 

Toll Free: (866)841-9139 

saraorg@aol.com 

http://www.affluent.net/sara 

SARA's mission is to promote the use of service animals by the disabled; to increase 

public awareness of the disabled rights concerning service animals; to encourage and 

support positive federal, state, and local legislation involving service animals; to serve 

as advocates against restrictive legislation for service animals, service animals in 

training, service animal trainers, and mandatory certification of service animals; and to 

maintain a national database of service animals, service animal trainees, and therapy 

animals in use in the United States. 

U.S. Department of Justice Disability Rights Section 

Civil Rights Division Disability Rights Section 

950 Pennsylvania Avenue, NW 

Washington, DC 20530 

Toll Free: (800)514-0301 

TTY: (800)514-0383 

Fax: (202)307-1197 

www.usdoj.gov/crt/about/drs 

The primary goal of the Disability Rights Section is to achieve equal opportunity for 

people with disabilities in the United States by implementing the Americans with 

Disabilities Act (ADA). Through its multi-faceted approach toward achieving compliance 

with the ADA, this Section works to make this goal a reality. The Section's enforcement, 

certification, regulatory, coordination, and technical assistance activities, required by the 

ADA, combined with an innovative mediation program and a technical assistance grant 

program, provide a cost-effective and dynamic approach for carrying out the ADA's 

mandates. 
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This document was developed by the Job Accommodation Network, funded by a 

contract agreement from the U.S. Department of Labor, Office of Disability Employment 

Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the 

position or policy of the U.S. Department of Labor. Nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. Department of 

Labor.