Georgia Piedmont Technical College (GPTC) is committed to creating an accessible and inclusive environment where individuals with disabilities can participate fully and independently in the College experience. In accordance with the Americans with Disabilities Act (ADA), the Americans with Disabilities Act Amendments Act (ADAAA), Section 504 of the Rehabilitation Act of 1973, and applicable Georgia law, this page provides guidance on service animal access, individual rights and responsibilities, and disability-related animal accommodations while promoting dignity, independence, and equal access throughout the GPTC community.

1. Service Animals

Under the ADA, a service animal is a dog that has been individually trained to do work or perform tasks for an individual with a disability. The work or tasks performed must be directly related to the individual's disability.

Examples may include, but are not limited to:

• Guiding an individual who is blind or has low vision;
• Alerting an individual who is Deaf or hard of hearing to sounds;
• Retrieving items;
• Providing physical assistance or balance support;
• Alerting to or responding to seizures;
• Alerting to changes associated with a medical condition;
• Interrupting or responding to disability-related behaviors;
• Reminding an individual to take medication; or
• Performing trained tasks related to a psychiatric disability.

A service animal is a working animal and is not a pet.

2. Psychiatric Service Animals

A dog individually trained to perform work or tasks related to a psychiatric disability may qualify as a service animal under the ADA.

A psychiatric service animal is different from an emotional support animal. A dog that has been trained to take a specific action to assist an individual with a psychiatric disability may qualify as a service animal. An animal whose presence alone provides comfort, emotional support, or companionship does not qualify as a service animal under the ADA.

3. Service Animals Do Not Require SAS Approval

Students using service animals are *not required to register the animal with SAS, request an accommodation letter, provide medical documentation, provide proof of training or certification, or obtain prior approval from SAS before bringing a service animal into areas of the College where the student is otherwise permitted to go.

Students may voluntarily contact SAS for assistance with access planning, particularly when participating in laboratories, clinical experiences, technical training environments, internships, field placements, or other environments that may present unique safety or access considerations.

Voluntary contact with SAS does not constitute a requirement for service-animal access.

4. Permissible Questions

When it is readily apparent that a dog is trained to perform disability-related work or tasks, College personnel should not question the individual regarding the animal.

When the need for the service animal is not readily apparent, College personnel may ask only:

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

College personnel may not require the individual to disclose their diagnosis, explain the nature or extent of their disability, demonstrate the animal's task, or provide documentation, certification, identification, or proof of training as a condition of access.

Questions regarding uncertain or complex situations should be referred to SAS rather than handled through additional disability-related questioning.

5. Miniature Horses

Although the ADA's definition of a service animal generally applies to dogs, GPTC will consider reasonable modifications to permit an individually trained miniature horse to perform disability-related work or tasks.

Consideration will be given to applicable ADA factors, including the miniature horse's type, size and weight; whether the handler has sufficient control; whether the animal is housebroken; and whether the animal's presence can be accommodated without compromising legitimate safety requirements necessary for the safe operation of the facility.

Students seeking to use a miniature horse are encouraged to contact SAS so the College can evaluate the particular environment and determine reasonable access.

6. Areas Where Service Animals Are Permitted

Service animals generally may accompany individuals with disabilities in College facilities and areas where students, visitors, or members of the public are otherwise permitted.

This may include, as applicable:

• Classrooms;
• Libraries;
• Student service areas;
• Testing areas;
• Advising and counseling areas;
• Offices open to students;
• Common areas;
• Dining or food-service areas;
• College events and activities;
• Campus transportation, when provided;
• Laboratories and technical instructional environments, unless a specific legitimate safety requirement applies; and
• Other College programs, services, and activities.

Access decisions must be based on the particular animal, environment, and actual circumstances rather than assumptions, stereotypes, fear, or generalized concerns about animals.

7. Laboratories, Clinical Settings, Technical Programs, and Other Specialized Environments

Some GPTC programs involve laboratories, healthcare environments, clinical experiences, shops, kitchens, machinery, chemicals, sterile environments, or other specialized settings.

The presence of a service animal should not be prohibited solely because an environment is characterized as a laboratory, clinical setting, or technical training area.

When a legitimate safety concern exists, GPTC will conduct an individualized assessment based on objective evidence and the actual requirements of the environment.

SAS may collaborate, as appropriate, with the student, academic program, faculty, clinical or field-site personnel, Environmental Health and Safety personnel, and other appropriate College officials to determine whether reasonable measures can provide access while maintaining legitimate health and safety requirements.

Possible measures may include identifying a safe location for the animal during a particular procedure, establishing protective measures, adjusting positioning within the environment, or considering another reasonable approach.

A service animal may be excluded from a specific area when its presence would create a legitimate safety risk that cannot be sufficiently mitigated or would fundamentally alter the nature of the program, service, or activity, consistent with applicable law.

8. Clinical Sites, Internships, and External Placements

Students participating in clinical experiences, internships, apprenticeships, field experiences, or other programs at external locations should contact SAS when disability-related access planning may be necessary.

Because an external site may have its own policies and legitimate health or safety requirements, SAS may work collaboratively with the student, academic program, and external site to address access while maintaining the student's rights under applicable disability law.

Decisions should be individualized and should not be based solely on generalized assumptions about service animals.

9. Handler Responsibilities

The service animal must remain under the control of its handler.

The animal generally must be harnessed, leashed, or tethered unless the use of such a device interferes with the animal's safe and effective performance of its disability-related work or the individual's disability prevents use of the device. In those circumstances, the handler must maintain control through voice commands, signals, or another effective means.

The handler is responsible for:

• Maintaining control of the animal;
• Providing appropriate care and supervision;
• Feeding and toileting the animal;
• Cleaning up after the animal;
• Complying with generally applicable animal licensing, vaccination, and public-health requirements; and
• Addressing damage caused by the animal consistent with the same standards applied to other individuals who cause damage to College property.

GPTC employees are not responsible for the care, supervision, feeding, toileting, or handling of a service animal.

10. Removal of a Service Animal

A service animal may be required to leave a particular College area when:

• The animal is out of control and the handler does not take effective action to control it;
• The animal is not housebroken;
• The particular animal poses a direct threat to the health or safety of others based on an individualized assessment; or
• The animal's presence in a particular circumstance would fundamentally alter the nature of a College service, program, or activity.

Removal decisions must not be based on breed, size, appearance, assumptions, fear, or stereotypes.

When a service animal is appropriately removed, the individual with a disability should be provided an opportunity to continue participating in the College program, service, or activity without the animal when feasible.

SAS should be consulted when an incident raises ongoing questions regarding a student's disability-related access.

11. Disruptive Behavior

Occasional appropriate animal behavior should not automatically result in removal.

However, repeated or uncontrolled barking, aggressive behavior, uncontrolled wandering, jumping on others, or other behavior demonstrating that an animal is not under the handler's control may warrant intervention.

Whenever possible, the handler should first be given an opportunity to bring the animal under control before removal is required.

12. Allergies, Fear of Animals, and Competing Disability-Related Needs

Allergies and fear of dogs are not, by themselves, sufficient reasons to deny an individual access with a service animal.

When a student, employee, or other individual has a disability or health condition affected by proximity to a service animal, GPTC will consider the needs of both individuals.

SAS and other appropriate College offices may explore reasonable measures such as:

• Different seating locations;
• Increased distance within a classroom or testing environment;
• Different sections or rooms when feasible;
• Adjustments to scheduling;
• Air-quality or cleaning measures when appropriate; or
• Other individualized solutions.

The goal is to provide effective access to both individuals without automatically excluding either person.

13. Emotional Support, Comfort, and Assistance Animals

Animals whose sole function is to provide emotional support, comfort, companionship, or a therapeutic benefit through their presence do not meet the ADA definition of a service animal.

Because GPTC does not provide student residential housing, the housing-specific assistance-animal provisions associated with residential housing generally do not apply to GPTC campus facilities.

Accordingly, an emotional support, comfort, therapy, or other assistance animal that does not qualify as a service animal under applicable law is generally not permitted in classrooms, laboratories, libraries, testing areas, offices, or other College facilities where animals are otherwise prohibited.

Students who believe they need a disability-related accommodation should contact SAS to discuss their functional limitations and potential reasonable accommodations through the College's interactive process.

14. Therapy Animals and Animals Used in College Programs

An animal brought to campus as part of a College-sponsored therapeutic, educational, instructional, or other approved program is not automatically a service animal.

College-sponsored or program-approved animals may be subject to separate institutional requirements regarding authorization, supervision, health, safety, insurance, and use of College facilities.

These requirements do not alter the rights of individuals who use service animals under the ADA.

15. Service Animals in Training

Georgia law provides certain access rights involving individuals engaged in training or raising qualifying guide or service dogs.

Questions concerning service animals in training should be referred to SAS or the appropriate College administrator for review under applicable Georgia law.

The federal ADA provisions applicable to fully trained service animals should not be used to improperly restrict any additional rights independently provided by Georgia law.

16. Vaccinations, Licenses, Identification, and Registration

GPTC does not require a service animal to be certified, registered, or professionally trained by a particular organization as a condition of ADA access.

GPTC also does not require a special vest, identification card, harness, tag, or certificate establishing that a dog is a service animal under the ADA.

Service animals remain subject to generally applicable state and local animal licensing, vaccination, and public-health requirements to the same extent those requirements apply to other dogs.

GPTC may offer voluntary procedures designed to assist with emergency planning or campus access coordination, but participation cannot be required as a condition of service-animal access under the ADA.

17. Fees and Damage

GPTC will not impose a surcharge or additional fee solely because an individual uses a service animal.

An individual may be held responsible for damage caused by a service animal when the College would similarly charge an individual without a disability for damage that individual caused.

18. Emergency and Evacuation Considerations

Students who use service animals are encouraged, but not required, to discuss disability-related emergency or evacuation needs with SAS when additional planning may be beneficial.

Emergency planning should account for the student's ability to remain with and control the service animal whenever reasonably possible.

Voluntary emergency planning or identification procedures shall not become a prerequisite for service-animal access.

19. Faculty and Staff Guidance

Faculty and staff should not independently request disability documentation, service-animal certification, training records, or information about a student's diagnosis.

When the service-animal status is not apparent, only the two questions permitted under the ADA may be asked.

Faculty and staff who encounter questions involving specialized environments, competing disability-related needs, safety concerns, repeated disruptive behavior, or uncertainty regarding application of this policy should contact SAS for guidance.

A student's use of a service animal should not be identified or discussed with other students except when necessary to address an immediate operational or safety matter and consistent with applicable privacy requirements.

20. Student Accessibility Services Review and Consultation

Students do not need SAS approval to use a qualifying service animal in areas where service animals are permitted under applicable law.

SAS is available to provide consultation regarding:

• Service-animal access questions;
• Specialized academic environments;
• Laboratories and technical training areas;
• Clinical and field placements;
• Competing disability-related accommodation needs;
• Disability-related emergency planning;
• Faculty or staff questions;
• Animal-related accommodation requests that fall outside ordinary ADA service-animal access; and
• Other disability-related access concerns.

When an individualized accommodation review is necessary, SAS may engage in the interactive process and request documentation appropriate to the accommodation being considered. This documentation process should not be used to require documentation or certification of a qualifying service animal when such documentation is prohibited by the ADA.

21. Complaints and Accessibility Concerns

Students who believe they have been denied appropriate service-animal access or otherwise experienced a disability-related access barrier should contact Student Accessibility Services.

Students may utilize GPTC's applicable disability accommodation reconsideration, appeal, grievance, or nondiscrimination procedures.

Nothing in the College's internal process prevents an individual from exercising rights available under applicable federal or state law.

22. Applicable Law

This policy is intended to be interpreted consistently with:

• Title II of the Americans with Disabilities Act;
• Section 504 of the Rehabilitation Act of 1973;
• U.S. Department of Justice regulations implementing Title II of the ADA, including 28 C.F.R. § 35.136;
• Applicable provisions of Georgia law, including O.C.G.A. Title 30, Chapter 4; and
• Other applicable federal, state, and local requirements.

When federal and state requirements differ, GPTC will apply applicable law in a manner that preserves the rights and protections available to individuals with disabilities.

References

• U.S. Department of Justice, Civil Rights Division, Disability Rights Section. Frequently Asked Questions about Service Animals and the ADA (2016).
• U.S. Department of Justice, Civil Rights Division, Disability Rights Section. Revised ADA Requirements: Service Animals (2016).

Contact Information

Students are encouraged to contact SAS with questions regarding disability-related access, accommodations, or application of this policy.

Student Accessibility Services (SAS)
Email: accessibility@gptc.edu Phone: (404) 297-9522 ext. 1385