Why did the University create this new Guideline?

The Accessibility for Ontarians with Disabilities Act (AODA), a provincial law, has regulations that set mandatory standards for ‘customer service’ in the public sector, and these standards apply to the University of Toronto. It is these regulations that define what qualifies as a ‘service animal’ in Ontario. These regulations require organizations such as U of T to develop their own policy or guideline pertaining to the use of service animals. Such guidelines must reflect what is set out in the law.

Is the University of Toronto creating new rules about service animals beyond what is required by Ontario law?

For the most part, U of T’s new Service Animals Guideline affirms what is already required under Ontario law in terms of accommodation of individuals accompanied by service animals. An additional element that has been added to the University’s guideline and that is not required by law is an entirely voluntary/optional registration process for service animals that will frequently be on U of T campuses.

What qualifies as a service animal in Ontario?

Service animals are animals that provide a service to a person with some form of visible or invisible disability. It is primarily the AODA that defines what qualifies as a service animal in Ontario. Under the AODA’s Customer Service Standard, an animal qualifies as a service animal for a person with a disability if:

1. The animal can be identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as a vest or harness worn by the animal; or
2. The person with a disability provides documentation from one of 9 categories of regulated Ontario health professionals, confirming that the person requires the animal for reasons relating to that person’s disability. Health professionals that can provide this documentation include doctors as well as physiotherapists, optometrists, and nurses. The University’s Service Animals Guideline provides a list of the categories of health professionals that can provide this documentation.

Can any species of animal qualify as a service animal?

Municipal laws in Toronto, Scarborough and Mississauga restrict the types of animals that residents can temporarily or permanently “possess or control” (referred to as “keeping” an animal.) While the AODA does not restrict the types of animals that can qualify as service animals, municipal laws preventing the keeping of certain types of animals mean that it will be unusual for individuals to receive authorization from an Ontario health professional, enabling them to use a municipally-restricted animal as a service animal. Examples of animals that are prohibited under municipal laws in Toronto, Scarborough, and Mississauga include horses, ducks, peacocks, and monkeys. Pit bull dogs are also prohibited under Ontario law. Persons that have received confirmation from an Ontario regulated health professional indicating that they require a municipally-prohibited animal for reasons relating to a disability should contact the University’s AODA Office at aoda@utoronto.ca to discuss accommodation of their disability needs.

Members of the University community should remember, however, that various types of animals including cats, gerbils, small dogs, and rabbits could potentially serve as service animals.

To whom does this guideline apply?

This guideline applies to all members of the University of Toronto community, including students, all staff, faculty, librarians, post-docs, and all categories of instructors. It also applies to visitors to our campuses who seek to access U of T services or facilities, and to volunteers providing volunteer services at the University.

Where does this guideline apply? Are service animals allowed to go anywhere on our three campuses?

This guideline applies to University of Toronto-owned spaces on all three campuses. It also applies to University of Toronto-owned student residences, including Chestnut Residence (see question on student residences under Student Questions). The University is committed to accommodating individuals accompanied by service animals.

While service animals are generally welcome on all of our campuses, the law sets out some limited restrictions on where service animals can go. There may be some campus locations where health and safety requirements mean that the individual with the service animal may not be able to bring their animal into that location, and must be otherwise accommodated. For example, under Ontario law, all animals are restricted from areas where food is prepared, packaged, or handled (although they are permitted in areas where food is served, sold, or offered for sale). There are also certain campus locations that may raise particular safety concerns with regard to the service animal’s presence, such as some controlled and high hazard laboratories or medical clinics. In addition, in some instances the health and safety needs of other members of the University community must also be considered, and the AODA Office can assist with balancing different individuals’ rights as part of this process. Please see the Service Animals Guideline for greater detail, and for any questions, call the AODA Office at 416-978-7236 or email aoda@utoronto.ca.

Can I pet or feed a service animal?

Avoid petting or talking to a service animal while it is working: this distracts the animal from its tasks. Do not feed or offer treats to the animal unless its handler encourages you to do so.

I have other general questions/concerns about this guideline that are not addressed here. Who do I speak to?

If you have any general questions, concerns, or feedback about this guideline, please contact the AODA Office at 416-978-7236 or aoda@utoronto.ca. You may also speak with Health & Well-being (for staff and faculty) or with your campus’ accessibility services office (for students).

I am a student who lives off-campus, and I have received documentation from a regulated health professional in Ontario that I require a service animal. I’d like to bring my service animal to class with me every day, and to the library on weekends when I come to campus to study. What do I need to do?

Under the law, a person wishing to bring an animal that legally qualifies as a service animal to campus is welcome to do so– although some limited restrictions on their presence in some spaces may exist (see the Guideline for greater detail on these exceptions.)

While you may bring your service animal to most spaces on our campuses without specific permissions, the University encourages students accompanied by service animals to register their service animal with the University. This process is entirely voluntary/optional. The advantage of registering the animal is to minimize the need for you to produce documentation from a regulated health professional to employees of the University. Persons who register their service animal with the University will be provided with an updated T-Card with a symbol indicating that their service animal has been registered with the University. The T-Card should be easier and less obtrusive to produce to University employees than the health professional’s documentation (see ‘What qualifies as a service animal in Ontario?’). Registering the service animal also provides an opportunity for the University’s accessibility service offices to discuss your needs on campus, and to identify any potential issues that might arise in your daily life on campus (such as the possible need for you to be otherwise accommodated or for special arrangements to be made in a space such as a laboratory where specific hazards could arise.)

If you decide to voluntarily register your service animal with the University, you should visit your campus accessibility service office to register your animal, ideally at or before the start of the academic year. Contact details for the three campuses’ accessibility offices are located at the end of the Guideline.

If you choose not to voluntarily register your service animal, the University encourages you to speak to your instructors prior to bringing the animal to class, so as to ensure that the instructors are able to make any necessary arrangements for the class prior to the animal’s arrival in the classroom. The AODA Office or accessibility services advisors can assist you with navigating these discussions.

I am a student who is planning on living in a U of T residence in the coming year. I have just received documentation from a health professional stating that I require a service animal (a small dog) to assist me with a disability. Do these guidelines apply to residences? Do I have to let anybody know I plan on having my service animal with me in residence this year?

The Service Animals Guideline applies to all University of Toronto-owned residences on all three campuses, as well as Chestnut Residence. Generally speaking, students may choose to have an animal that legally qualifies as a service animal live with them in their residence. If you hope to have your service animal stay or live with you in residence, you should contact your residence prior to moving in, so that staff can make appropriate preparations and consider any needs of other students or staff who may also require accommodation. Students hoping to have a service animal live with them in residence should also consider registering their service animal under the voluntary registration process set out in the guideline. Contact your campus accessibility office for more information on registering your animal.

Remember that there are a limited number of restrictions on service animals set out in the guideline that must be followed. In addition, as the animal’s handler, you must also ensure that the service animal living in residence complies with reasonable standards regarding behaviour, noise, odour, and waste.

I have a phobia of dogs. There is a service dog accompanying a student in one of my courses this year. Is there anything I can do?

The University seeks to accommodate both those accompanied by service animals on the one hand, and those who have health or safety concerns (including phobias) or other human rights concerns or legal entitlements regarding animals. If you have such a serious concern regarding a service animal in one of your courses, please contact your registrar, so that they can investigate alternate arrangements to accommodate both you and the student accompanied by the service animal. For courses that have multiple sections, the registrar may seek to place you in a different section in order to ensure that both you and the service animal user are accommodated. Where this is not an option, your registrar can assess alternate options.

I am a faculty member/staff member/instructor and I have received documentation from an Ontario regulated health professional that I require a service animal (a cat). I’d like to bring my service animal to campus with me on a daily basis. What do I do?

Under the AODA, a person wishing to bring an animal that legally qualifies as a service animal to campus is welcome to do so– although some limited restrictions on their presence in some spaces for health and safety reasons will exist (see the University’s Guideline for greater detail on these exceptions.) While you may bring your service animal to most spaces on our campuses without specific permissions, the University encourages employees accompanied by service animals to contact their manager (for staff) or Chair or Dean (for faculty and instructors) prior to bringing their animal to campus for the first time. This will allow the manager, Chair or Dean to make any appropriate arrangements for the service animal’s presence. This may include accommodating other members of your unit who may have their own health and safety concerns (such as an allergy or phobia) around the animal.

Instructors who have a legally-qualified service animal who wish to bring the animal to class should also consider notifying students in the class prior to the first class that a service animal will be present in the class. This will allow students with a related health concern to speak with accessibility services to ensure that they are accommodated in the course.

The University also encourages staff, faculty and instructors to consider registering their service animal with the University. The advantage of registering the animal is to minimize the need for you to produce documentation from the regulated health professional to other employees of the University. Employees who register their service animal with the University will be provided with an updated T-Card with a symbol indicating that their service animal has been registered with the University, which should be less obtrusive to produce than the health professional’s documentation. Registering the service animal also provides an opportunity for the University’s Health & Well-being Programs and Services to discuss the employee’s disability-related needs on campus, and identify any potential barriers that might arise in the employee’s daily life on campus. The Health & Well-being office can also facilitate discussion with the employee’s manager (or Chair or Dean) to discuss any potential conflicts with other employees in the employee’s unit who may have competing accommodation needs.

Employees choosing to voluntarily register their service animal with the University should contact the University’s tri-campus Health & Well-being Programs and Services to register their animal at (416) 978-2149.

I am an instructor and I worry about having service animals in my classroom as I believe they could cause a distraction or impede students’ learning. What can I do?

Under the law in Ontario, if a student with a disability is accompanied by a service animal, a university must ensure that the student is permitted to access the university campus and keep the animal with them, unless the animal is otherwise excluded by law from a particular space. A student who receives documentation from one of nine types of Ontario regulated health professionals, indicating that the student requires a service animal for reasons relating to a disability, must be able to access the University’s services and facilities, including its classrooms, barring the small number of exceptions outlined in the Guideline. Put simply, the law requires us to welcome service animals on campus, and the University strongly endorses this welcoming approach in order to facilitate all students’ learning on our campuses. If a situation or conflict involving a student with a service animal appears to have arisen in your class, please contact the AODA Office at aoda@utoronto.ca or your campus’ accessibility service office for guidance on how to proceed.

Instructors should address any concerns or questions regarding service animals in the classroom confidentially and directly with the student who is accompanied by the service animal in the first instance, and not in front of others wherever possible. See question below regarding concerns that an animal may not legally qualify as a service animal.

I am an instructor and I have a phobia of dogs. I have received notification that there will be a service animal that is a dog in one of my courses this year. Is there anything I can do?

The University seeks to accommodate those using service animals as well as those who have health or safety concerns, including phobias, or other human rights concerns or legal entitlements regarding animals. If you have such a concern regarding a service animal in one of your courses, please contact Health and Well-being, your registrar, or your Chair/Dean, so that they can seek alternate arrangements to accommodate both you and the student. These offices or individuals will likely work with the AODA Office to assess such alternate arrangements.

I am an employee who manages staff members. One of these employees has a service animal (a cat), and works in the same room as someone who has a serious allergy to cats. How do I accommodate both employees?

There will be circumstances in which one employee’s need to be accompanied by a service animal may conflict with the health and safety needs or other human rights or legal interests of other employees. In such circumstances, managers and/or HR officers must analyze the specific situation and seek as much as possible to reconcile both employees’ legitimate accommodation needs. While balancing two individuals’ rights can be challenging, we encourage managers to seek assistance from their HR officer, or to speak directly to the AODA Office at 416-978-7236 or aoda@utoronto.ca.

If I suspect that a co-worker or student is bringing an animal to campus, and does not have a disability-related need for it, can I ask the person why they have an animal with them?

The first point to remember is that disabilities are more likely to be invisible rather than visible. Some individuals may have a disability such as a mental health disorder that is neither visible nor generally perceivable to others. As such, it is never safe to assume that a person does not have a disability simply because the disability is not apparent to you. If you have reason to suspect that the individual’s animal does not qualify as a service animal, however, and you have a health and safety or operational need to determine whether the animal qualifies as such, you may confidentially and politely ask the individual whether the animal is a service animal.

The University encourages those with service animals to register their animal with the University. Where an individual has registered the animal, the handler will have a small symbol on the back of their T-Card, and the handler can present the T-Card for inspection. Not all individuals will have registered their service animal with the University, however, as registration is voluntary. The individual may be willing to provide you with documentation from one of nine categories of Ontario health providers indicating that the animal is a service animal. Under the law, only certain categories of health professionals who are licensed in the province of Ontario are authorized to provide this documentation to individuals seeking to be accompanied by a service animal. Other types of notes or certificates do not qualify an animal to serve as a service animal under the AODA.

Remember that under the Ontario Blind Person’s Rights Act, a person reliant on a guide dog due to vision loss may instead carry an identification card indicating that their guide dog has been recognized by the provincial government. Such qualified guide dogs are classified as service animals.

If you still have questions about whether the animal qualifies as a service animal following your interaction with the person being accompanied by the animal, it is recommended that you contact Health & Well-being or your accessibility office, or the AODA Office to navigate this discussion and issue.