Purpose

The purpose of this policy is to provide the College community with guidelines for the use of service animals on campus.  This policy will assist in the following:

• Understanding the rights of students, employees, and visitors to use service animals on campus
• Providing a framework for managing service animals on campus

Accountability

Under the direction of the President, the ADA Coordinator (Diversity Compliance Officer) and the Director for the Center on Disability shall ensure compliance with the policy.  The Vice Presidents, Deans, and all other supervisory staff shall implement this policy.

Policy Statement

It is the policy of the Community College of Philadelphia that service animals assisting individuals with disabilities and service animals in training accompanied by their trainers are generally permitted in all facilities, programs, and activities where members of the public or students, as applicable, are otherwise permitted, except as described below or otherwise governed by applicable law. 

Definition of Service Animal

A “service animal” is generally defined as

• A dog that has been 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.
• The work or task(s) performed by the service animal must be directly related to the person’s disability.  Examples include, but are not limited to guiding individuals with vision loss, alerting individuals with hearing loss to the presence of people or sounds, providing non-violent protection or rescue work, pulling a wheelchair, or retrieving items.

Other animals, whether wild or domestic, trained or untrained, generally do not qualify as service animals.[1]

Application of Policy

This policy applies to service animals accompanying individuals with disabilities, and service animals in training accompanied by their trainer.  Individuals with disabilities and service animal trainers accompanied by service animals are referred to throughout this policy as “handlers.” 

Procedures

Students

Service animals may accompany their student handlers in all areas of the College open to the public or to students (except for “restricted areas” as set forth in this policy).  The College strongly encourages students with disabilities who use service animals to register with the Center on Disability as a resource in navigating any concerns related to disability. Details regarding the process for registering with the Center on Disability can be found on the College’s website.  Students can reach the Center on Disability at 215-751-8050 or go to Room BG – 39.  Additionally, students who plan to bring a service animal to campus should notify the College’s Department of Public Safety in advance at 215-751-8111 or Room MG-12.  Students should also notify their class instructors in advance if the service animal will accompany them to class.

Employees

Employee requests to have a service animal at work must be submitted to the Associate Vice President for Human Resources or the Diversity Compliance Officer in accordance with the College’s Disability Accommodations Policy.  A determination regarding the request will be made in accordance with the Disability Accommodations Policy.  Employees can view this policy at https://www.myccp.online/college-policies-and-procedures/disability-accommodations-policy and may contact the Diversity Compliance Officer at 215-751-8039 or go to Room M2-7 for information and assistance.

Visitors

Service animals are permitted to accompany their handlers who are visitors in all areas of campus that are open to the public (except for “restricted areas” as set forth in this policy).  Specific questions related to the use of service animals on the campus by visitors can be directed to the ADA Coordinator at 215-751-8039 or the Director for the Center on Disability at 215-751-8410.

Requirements for Service Animals

• The service animal must comply with all applicable laws such as Pennsylvania Dog Laws, including meeting the licensing requirements mandated by the Commonwealth of Pennsylvania or the state of residence for nonresidents, as applicable.
• The service animal should be in good health and must be vaccinated in accordance with Commonwealth of Pennsylvania vaccination requirements.
• The handler of a service animal must be in full control of the animal and the animal cannot pose a direct threat to the health or safety of others.
• The service animal must be harnessed, leashed, or tethered while on campus unless these devices interfere with the service animal’s work or the individual’s disability prevents use of these devices.  In that case, the handler must use voice, signal, or other effective means to maintain control of the animal.
• The handler of a service animal is liable for any damages to College premises or property or injury to persons caused by the service animal.
• The handler is responsible for caring for and supervising the service animal, which includes toileting, feeding, grooming, hygiene, and veterinary care. College personnel are not responsible for the care or supervision of the service animal. 
• The handler is solely responsible for cleaning up after the service animal and properly disposing of the service animal’s waste.
• The College recommends that all service animals wear identification such as a vest, harness, or ID tag, to identify them as service animals. 

Conflicting Disabilities

Students with a medical condition(s) affected by service animals should contact the Center on Disability if they have a health or safety related concern about exposure to a service animal.  The student registering the concern must provide medical documentation to the Center on Disability in accordance with documentation guidelines found on the Center on Disability’s website.  Employees should contact the ADA Coordinator in the Office of Diversity and Equity for similar procedures.

Restricted Areas

Service animals may be excluded in areas where the presence of a service animal would fundamentally alter the nature of a program or activity, would be disruptive, or would pose legitimate safety concerns.  Exceptions may be made on a case-by-case basis.  If it is determined that an area is unsafe, reasonable accommodations will be provided to assure equitable access to students.

Grounds for Exclusion of a Service Animal

Service animals may be required to leave a facility, program, or activity if:

• the animal’s behavior or presence poses a direct threat to the health or safety of others (for example, a service animal that displays vicious behavior towards people will be excluded from campus);
• the animal is out of control and the service animal’s handler does not take effective immediate action to control it; or
• the animal is not housebroken.

Students, employees, or visitors who believe that a service animal meets any of the above grounds for exclusion should contact the Department of Safety and Security.

When the College requires a handler to remove a service animal from College premises, the handler will be permitted to participate in college courses, events, and activities without having the service animal on the premises. The College will offer alternative accommodations when appropriate and supported by documentation.

Complaints and Appeals

Any claims of discrimination on the basis of a disability or use of a service animal, or failure to provide reasonable accommodations regarding the use of a service animal on campus may be brought by any student, employee, or visitor pursuant to the College’s Anti-Discrimination and Harassment Complaint Policy and/or the Disability Accommodations Policy, as applicable.  An individual who files a complaint or participates in an investigation will be protected against retaliation.

A person who disagrees with the complaint determination may appeal by providing written appeal to the College President.  The President or his/her designee will make a decision regarding the appeal within 14 business days and render a written decision to the person, the person’s supervisor (as applicable), and the Director of Diversity, Equity and Inclusion and Title IX Coordinator concerning the accommodation request or situation.  The decision of the President or his/her designee is final.

Questions

Individuals who have questions regarding whether a service animal is properly on campus or any other questions regarding this policy should contact the ADA Coordinator or the Center on Disability.