Service Animals in Academic Spaces

In discussing Service Animals in classrooms and other academic environments, it is important to make a clear distinction between Service Animals and Emotional Support Animals (ESAs) because they serve different purposes and have different access rights.

Service Animals and Emotional Support Animals

Service Animals do not require approval or registration through the Office of Access and Learning Accommodation (OALA). Students who use Service Animals may voluntarily connect with OALA for communication, coordination, and support related to access in academic or campus environments. Voluntary registration with OALA is not required and does not determine a Service Animal's right of access to Baylor spaces where Service Animals are otherwise permitted.

Emotional Support Animals are different. ESAs provide disability-related emotional support but are not required to be individually trained to perform disability-related work or tasks and do not have the same public-access rights as Service Animals under the Americans with Disabilities Act (ADA). At Baylor, ESAs are considered through OALA as disability-related housing accommodations in accordance with the Fair Housing Act.

An approved ESA is a housing accommodation and does not authorize the animal to accompany the student into classrooms, dining facilities, libraries, academic buildings, offices, athletic facilities, or other non-residential campus spaces where animals are otherwise prohibited.

Students seeking information about an ESA should review the Housing Accommodations page for information about the accommodation process, documentation, annual requests, and owner responsibilities.

What Is a Service Animal?

Under the ADA, a Service Animal is a dog that has been individually trained to perform work or tasks for an individual with a disability. The work or tasks performed by the dog must be directly related to the individual's disability. An animal whose presence provides comfort or emotional support but that has not been individually trained to perform disability-related work or tasks is not a Service Animal under the ADA.

The ADA does not require a Service Animal to:

be professionally trained
complete a particular training program
be certified or registered
possess an identification card or documentation
wear a vest or other identifying equipment
be registered with OALA

An individual with a disability who uses a Service Animal may generally bring the animal into the same areas of campus where the individual is otherwise permitted to go, including classrooms and academic spaces, subject to applicable health and safety requirements.

Although the ADA definition of a Service Animal is limited to dogs, federal regulations contain a separate provision requiring reasonable consideration of miniature horses that have been individually trained to perform work or tasks for an individual with a disability. Factors that may be considered include the type, size, and weight of the miniature horse, whether the facility can accommodate the animal, whether the animal is housebroken and under the handler's control, and whether its presence would compromise legitimate safety requirements.

OALA and Voluntary Registration

OALA does not approve or certify Service Animals. Students who use a Service Animal may, however, voluntarily register the animal with OALA for purposes of communication and access coordination.

When a student voluntarily connects with OALA, our office can help:

identify potential barriers within classrooms or academic environments
coordinate questions involving laboratories or other specialized environments
communicate with faculty or other appropriate campus partners when helpful
provide the student with a courtesy notice explaining the presence of the Service Animal and ways to support the animal's ability to perform its trained work or tasks

The student may choose, but is not required, to share this notice with faculty or other members of the Baylor community.

A courtesy notice from OALA is not an approval or certification of the Service Animal and is not required for the animal to access Baylor spaces where Service Animals are otherwise permitted.

What May Faculty or Staff Ask?

When it is not readily apparent that a dog is a Service Animal, Baylor personnel may ask only the following two questions:

Is the dog required because of a disability?
What work or task has the dog been trained to perform?

Faculty and staff should not ask the individual to provide:

the nature or diagnosis of the disability
medical documentation
certification, registration, identification, or training documentation
a demonstration of the dog's work or task.

The ADA specifically limits inquiries to these two questions when the dog's status is not apparent.

Service Animal Responsibilities and Behavior

The owner or handler is responsible for the care, supervision, control, and conduct of the Service Animal.

Service Animals must generally be harnessed, leashed, or tethered unless the individual's disability prevents use of such a device or use of the device would interfere with the animal's trained work or tasks. In those circumstances, the animal must remain under effective control through voice, signals, or another effective means. Concerns should be based on the actual behavior of the specific animal, not assumptions about Service Animals generally.

Baylor may take appropriate action when, for example:

an animal creates a persistent or unreasonable disruption and the handler does not take effective action
the animal is not housebroken, or its biological needs are not appropriately managed
the animal engages in aggressive, threatening, dangerous, or uncontrolled behavior
the animal is not under the effective control of its handler
the specific animal poses a direct threat to the health or safety of others that cannot be eliminated or sufficiently reduced through reasonable measures

Faculty should contact OALA when concerns involving a Service Animal arise in an academic environment rather than making assumptions about whether the animal should be excluded.

For additional information, please review Responsibilities of Owners/Handlers for Animals on Baylor Property.

Allergies, Phobias, and Competing Disability-Related Needs

An allergy, fear, or phobia does not, by itself, provide a basis for automatically excluding a Service Animal.

If the presence of a Service Animal intersects with another student's or employee's disability-related need, the circumstances should be addressed individually. OALA should be contacted for student-related access concerns and Human Resources should also be involved when an employee's disability-related needs are involved. The goal is to determine how the access needs of both individuals can be appropriately addressed rather than automatically excluding the Service Animal.

Service Animals in Training

Service Animals in training are treated differently from fully trained Service Animals.

Texas law permits Service Animals in training to access public facilities when accompanied by an approved trainer. Baylor may require verification that the individual is an approved trainer before allowing a Service Animal in training into university spaces where animals are otherwise prohibited.

Students Training With Their Future Service Animal

In some circumstances, part of a Service Animal's training protocol includes a period in which the individual with a disability works directly with the animal that will ultimately assist them. This may include transition, handler, or in-home training. Students in this situation are encouraged to voluntarily connect with OALA so that disability-related access needs, classroom logistics, or communication with faculty and campus partners can be addressed when helpful.

Students Who Are Training an Animal for Someone Else

A different circumstance exists when a Baylor student or other member of the campus community seeks to bring an animal into university facilities solely because the individual states that they are training the animal to become a Service Animal for someone else. A student's statement that they are raising, socializing, or training a dog does not, by itself, establish that the student is an approved trainer or that the animal is entitled to access University buildings or other spaces in which animals are otherwise prohibited.

A student seeking access to university facilities on the basis that they are an approved trainer of a Service Animal in training may be asked to provide information establishing that status consistent with applicable Texas law and university policy. Simply referring to an animal as a "Service Animal in training," raising or socializing an animal, or intending that the animal become a Service Animal in the future does not, by itself, establish campus access.

Questions regarding Service Animals in training should be directed to Office of General Counsel before the animal is brought into a space where animals are otherwise prohibited.

Service Animals in Laboratories and Specialized Academic Environments

Service Animals may accompany students into academic environments, including laboratories, unless the actual conditions of a particular environment create a legitimate health or safety concern that cannot reasonably be addressed.

Laboratory environments may require appropriate protective measures for the Service Animal based on the hazards present. Depending on the environment, protective equipment may include:

protective booties
a protective covering or laboratory coat
eye protection
other equipment necessary to protect the animal from identified hazards

The handler is responsible for providing appropriate protective equipment for the Service Animal, ensuring that the animal can safely use the equipment, and maintaining control of the animal.

Restrictions should be based on the actual conditions and legitimate safety requirements of the particular environment rather than a categorical exclusion of Service Animals from laboratories or academic spaces. There may be limited locations where an animal's presence cannot safely or appropriately be accommodated. Examples may include certain sterile environments, areas where the presence of the animal would compromise legitimate research or equipment requirements, locations presenting unavoidable danger to the animal, or other environments governed by legitimate health or safety requirements.

Faculty should contact OALA when questions arise regarding a Service Animal in a laboratory or other specialized academic environment so that the particular circumstances can be reviewed.

Additional Accommodations Related to a Service Animal

A student does not need an academic accommodation from OALA simply to use a Service Animal. However, a student may need a separate accommodation to address a disability-related barrier associated with using the Service Animal in a particular academic environment.

For example, a student may need a particular seating location that provides sufficient space for the Service Animal to remain near the student and safely perform its trained work or tasks. When an additional accommodation is needed, the student should submit an application to OALA to begin the accommodation process.

Questions or Concerns

Faculty and other members of the Baylor community are encouraged to contact OALA when questions arise regarding:

Service Animal access in classrooms or academic spaces
laboratory or specialized-environment safety
animal behavior or control
competing disability-related access needs
additional accommodations related to the use of a Service Animal
the distinction between a Service Animal, an Emotional Support Animal, and a Service Animal in training.

Please also review Responsibilities of Owners/Handlers for Animals on Baylor Property for Baylor's general expectations regarding the care, supervision, control, and conduct of animals permitted on university property. Service Animals do not require OALA approval or mandatory registration, while ESAs must be approved through OALA before being brought into Baylor University housing. ESA owners must also review, sign, and comply with the expectations outlined in the Emotional Support Animal (ESA) Agreement.

Questions may be directed to the Office of Access and Learning Accommodation at OALA@baylor.edu