Service Animals and Emotional Support Animals at PLNU

Point Loma Nazarene University complies with the Americans with Disabilities Act (ADA) in supporting service animals and emotional support animals on campus by individuals with disabilities in appropriate circumstances and in accordance with the Point Loma Nazarene University Service Animal and Emotional Support Animal Policy.

Contact the DRC for assistance before bringing animals on campus to ensure appropriate supports.

Definitions

A. Service Animals: Service animals are defined under the Americans with Disabilities Act 

(“ADA”) as dogs that are individually trained to do work or perform tasks for people with disabilities. Service animals are working animals, not pets. The work or tasks performed must be directly related to the individual’s disability. 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. 

  1. Examples: Examples of work or tasks that service animals perform 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; pulling a wheelchair; assisting an individual during a seizure; alerting individuals to the presence of allergens; retrieving items such as books or the telephone; alerting a person to a sudden change in blood sugar levels; providing physical support and assistance with balance and stability to individuals with mobility disabilities; calming a person with Post Traumatic Stress Disorder (PTSD) during an anxiety attack; and helping persons with psychiatric and neurological disabilities by preventing or interrupting impulsive or destructive behaviors. 
  2. Miniature Horses: The University may permit the use of a miniature horse on the same basis as a service animal if the horse has been trained to do work or perform tasks for the benefit of the individual with a disability and after an assessment of the following factors: the type, size and weight of the miniature horse and whether the facility can accommodate these features; whether the handler has sufficient control of the miniature horse; whether the miniature horse is housebroken; and whether the miniature horse's presence in a specific facility compromises legitimate safety requirements that are necessary for safe operation. 

B. Emotional Support Animals (“ESAs”): An ESA is a companion animal which provides therapeutic benefit, such as alleviating or mitigating symptoms of a person’s disability. ESAs are not service animals. However, ESAs will be permitted in residential facilities if the animal is necessary to afford a person with a disability an equal opportunity to use and enjoy University housing, its presence in University housing is reasonable, and there is an identifiable relationship or nexus between the individual’s disability and the assistance the animal provides. ESAs are allowed in residential facilities only with prior approval from the DRC pursuant to the procedures and standards outlined below. 

C. Owner: A student who has an approved ESA in residential housing. 

D. Handler: A person with a disability that a service animal assists or a personal care attendant who handles the animal for a person with a disability.

Specific Procedures

A. Service Animals: Individuals with disabilities who wish to bring a service animal to campus – including residential facilities, classrooms, and other University buildings – may do so without prior approval. However, they are strongly encouraged to reach out to the DRC to ensure that their experience bringing the animal to campus is smooth. Advance notice of a service animal in housing facilities will enable the University to appropriately plan for the animal’s presence and allow more flexibility in meeting a student’s needs. 

B. Emotional Support Animals: Students who wish to bring an ESA into University housing as an exception to the “no pet” policy must go through the reasonable accommodation process with the DRC as outlined in the PLNU Disability and Reasonable Accommodations Policy for Current and Prospective StudentsWhile accommodation requests will be accepted and considered at any time, requests should be filed at least 90 days before the student intends to bring the animal to campus in order to ensure timely consideration. An ESA will not be allowed until formal DRC approval has been received. 

University housing is unique in several aspects, including the mandatory assignment of roommates for many individuals and the requirement that individuals share a room or suite in certain housing facilities. To ensure that the presence of ESAs are not an undue administrative burden or fundamental alteration of University housing, the University will consider each request for an ESA on an individualized basis. 

1. Upon receipt of a request for an ESA, the DRC will engage in communication with the student to determine if the use of the animal is a reasonable accommodation. 

2. In order for an ESA to be considered as a reasonable accommodation for a student with a disability, supportive documentation should be from a professional healthcare provider (on letterhead) and generally include the following information: 

  • A current diagnostic statement that identifies the disability, including date of initial and most current diagnosis, any evaluations/testing that support the diagnosis, and a description of the functional limitation of the disability;
  • Information regarding the relationship between the disability and the relief the animal provides; and
  • Information that demonstrates the animal is necessary in order for the student to use and enjoy his/her living arrangement.

3. If the ESA is approved as a reasonable accommodation, the Director of the DRC will arrange a meeting with the student and Office of Residential Life to discuss the student’s responsibilities for the animal under this Policy.

4. An Owner with an approved ESA must keep the animal within the Owner’s residence. Students are not permitted to bring ESAs into classrooms, libraries, other housing facilities, dining facilities, academic buildings, entertainment venues, or other University facilities and events.

General standards for the approval/disapproval/removal of service animals or emotional support animals

A. Decisions to remove a service animal or disapprove/remove an emotional support animal (ESA) will be made on a case-by-case basis, taking into account all surrounding circumstances. However, the following general standards reflect reasons why an animal may be removed or disapproved: 

  1. The animal poses a direct threat to the health or safety of others. For example, the animal displays vicious behavior towards others or has a serious illness.
  2. The animal causes or would cause physical damage to the property of others.
  3. The animal poses an undue financial and/or administrative burden.
  4. The animal would fundamentally alter the nature of the University’s educational or housing operations.
  5. The animal is out of control and the Handler/Owner does not take effective action to control it. If the out of control behavior happens repeatedly, the Handler/Owner may be prohibited from bringing the animal into University facilities until the Handler/Owner can demonstrate that he/she has taken significant steps to mitigate the behavior.
  6. The animal is not housebroken.
  7. The Handler/Owner does not abide by his/her responsibilities as outlined in “Responsibilities of Handles and Owners” section policy. 

B. The University considers the following factors in determining whether to approve the presence of an ESA in University housing facilities: 

  1. The size of the animal and whether it is too large for available assigned housing space; 
  2. Whether the animal’s presence would force another individual to move from his/her assigned housing space (e.g., serious allergies);
  3. Whether the animal’s presence would otherwise violate individuals’ right to peace and quiet enjoyment of their dwelling;
  4. Whether the animal is housebroken and able to live with others in a reasonable manner;
  5. Whether the animal’s vaccinations are up to date;
  6. Whether the animal poses or has posed in the past a direct threat to the Owner or others, such as injuring or acting aggressively; and
  7. Whether the animal causes or has caused damage to housing beyond reasonable wear and tear. 

C. When an animal has been properly removed pursuant to this Policy, the University will work with the Handler/Owner to determine reasonable alternative opportunities to participate in the University’s services, programs and activities without having the animal on the premises.

Responsibilities of handlers/owners

A. Laws, Ordinances and Policies: Handlers/Owners are responsible for fully complying with all state and local laws, rules, regulations and ordinances regarding animals, and are subject to all University policies and guidelines regarding Residence Life. 

B. Proper Identification: All animals are subject to local licensing and registration requirements. 

C. Health and Vaccination: All animals must be immunized against diseases common to that type of animal. All vaccinations must be current. All animals must wear a rabies vaccination tag and, in the case of ESAs, vaccination documentation must be provided to the DRC prior to the animal being allowed into any housing facility. 

The Handler/Owner is required to ensure the animal is well cared for at all times. Any evidence of mistreatment, abuse, neglect or leaving the animal unattended for unreasonably long periods of time may result in immediate removal of the animal and/or disciplinary action.

D. Caring for the Animal: The cost of care, arrangements and responsibilities for the well- being of the animal are the sole responsibility of the Handler/Owner at all times. The University will accept no responsibility for the care of any animal covered by this Policy. 

  1. Animals must be kept clean and well groomed. University facilities such as showers, bathtubs, sinks, kitchens, bathrooms and the like shall not be used for this purpose. 
  2. Animals cannot be left unattended overnight at any time without the DRC’s prior written approval. If the Handler/Owner must be away and DRC approval has not been obtained, they must either take the animal with them or make arrangements for the animal to be cared for elsewhere off campus. Animals cannot be confined to a vehicle, tethered or abandoned at any time. 
  3. Regular and routine cleaning of floors, kennels, cages, etc. must occur. The odor of an animal emanating from a residence hall room or any housing facility is not acceptable. 
  4. The animal’s food must be stored in an appropriately sealed container to avoid attracting insects or creating a foul odor. Food may not be stored or heated in shared kitchen areas and it cannot be live food. 
  5. The Handler’s/Owner’s living quarters may be inspected for fleas, ticks or other pests as part of the University’s standard or routine inspections. If fleas, ticks or other pests are detected, the residence will be treated and the Handler/Owner will be billed for any expense above and beyond standard pest management treatments done in the housing facility. 

E. Keeping the Animal Under Control: The animal should be fully controlled by the Handler/Owner at all times, including responding to voice and/or hand commands (if this can reasonably be expected of the type of animal at issue). If an animal is found loose or unattended, the animal is subject to immediate removal. 

F. Being Responsible for Damage Caused by the Animal: Handlers/Owners are personally responsible for any damage caused by their animals and must take appropriate precautions to prevent property damage. The Handler/Owner will be required to pay for any damages caused by the animal. 

  1. An individual with an animal covered by this Policy in a housing facility has an obligation to make sure that his/her residence is as clean and damage-free as such housing facility was before the Handler/Owner moved in, excepting normal wear and tear. When the individual moves out of residential housing or no longer owns the animal, the residence will be investigated to determine if damage to University property or extra cleaning costs are attributable to the animal. If so, the Handlers/Owners will be financially responsible for associated costs. The University has the right at any time to conduct facility inspections for the purpose of assessing damage caused by the animal or otherwise determining the Handler’s/Owner’s compliance with this Policy. 

G. Being Responsible for Waste: Cleaning up after the animal is the sole responsibility of the Handler/Owner and it must be done immediately. Waste must be bagged and discarded in designated outdoor receptacles. No waste may be flushed down toilets or discarded in interior waste bins. In the event that the Handler/Owner is not physically able to clean up after the animal, it is then the responsibility of the Handler/Owner to hire someone capable of cleaning up after the animal. The University has no obligation to provide any relief area on campus for animals. 

H. Leash Requirements: Service animals should be on a leash at all times, unless the Handler is unable to use a leash due to a disability or the use of the leash would interfere with the animal’s ability to perform its duties. In that case, the Handler must be able to control the service animal by other effective means such as voice controls or signals. ESAs must be on a leash or in a crate when leaving a housing facility, but while still on University property. 

I. Observing Good Animal Etiquette: To the greatest extent possible, the Handler/Owner should ensure that the animal does not display behaviors or make noises that are disruptive or frightening to others, unless it is part of the service being provided to the Handler (e.g., barking to alert the Handler of an impending seizure or other danger). The animal must possess friendly and sociable characteristics. 

J. Emergency Situations: The Handler/Owner is expected to follow all University housing procedures for emergency evacuation and participate in emergency evacuation drills. Individual needs must be arranged in advance with the residence hall director.

K. Other Conditions and Restrictions: In response to a particular situation, the University reserves the right to impose other reasonable conditions or restrictions on the use of service animals and/or ESAs as necessary to ensure the health, safety, welfare or reasonable enjoyment of University programs and activities by others. 

Other information specifically related to service animals

A. Permitted Inquiries 

1. In general, members of the University community should not ask about the nature or extent of a person’s disability. However, as permitted by the ADA, if it is not obvious that the animal is required because of a disability, the Handler may be asked: 

  • If the animal is required because of a disability, and
  • What work or task the animal has been trained to perform. 

2. The Handler should not be asked for documentation, such as proof that the animal has been certified, trained or licensed as a service animal. Generally, University community members should not make inquiries about a service animal when it is readily apparent that an animal is trained to do work or perform tasks for an individual with a disability (e.g., if the dog is observed guiding an individual who is blind or has low vision, pulling a person's wheelchair, or providing assistance with stability or balance to an individual with an observable mobility disability).

B. Areas Off Limits to Service Animals  

1. While service animals are generally allowed to go anywhere on campus that the Handler is allowed to go, there are certain areas where the presence of a service animal fundamentally alters the nature of a program or activity or is disruptive. Examples of the areas that are off limits to service animals include: 

  • Research Laboratories: The natural organisms carried by service animals may negatively affect the outcome of the research. At the same time, the chemicals and/or organisms used in the research may be harmful to service animals.
  • Mechanical Rooms/Custodial Closets: Mechanical rooms, such as boiler rooms, facility equipment rooms, electrical and telecommunications closets, elevator control rooms and custodial closets, are off-limits to service animals. The machinery, electrical currents, wiring and/or chemicals in these rooms may be harmful to animals.
  • Food Preparation Areas: Food preparation areas are off limits to service animals per health codes.
  • Areas Where Protective Clothing is Necessary: Any room where protective clothing is worn is off-limits to service animals. Examples impacting students include the kiln, chemistry laboratories, wood shops and metal/machine shops.
  • Areas Where There is a Danger to the Service Animal: Any room, including a classroom, where there are sharp metal cuttings or other sharp objects on the floor or protruding from a surface; where there is hot material on the floor (e.g., molten metal or glass); where there is a high level of dust; or where there is moving machinery is off-limits to service animals. 

2. Questions regarding areas that are off limits to service animals should be directed to the DRC, or in the laboratory setting, to the laboratory instructor. However, exceptions to these off-limit rules shall be made, if at all, only by the DRC and only in rare situations based on exceptional circumstances. 

 

C. Employee Requests: Employees with a disability who wish to utilize a service animal as a reasonable accommodation in a University office or other areas of campus buildings not open to the general public must submit the request to the University’s Human Resources Department at least 30 days before the animal is needed. 

D. Service Animals in Training: Service animals in training are permitted in all public facilities on the same basis as working service animals, provided that the dog is on a leash and is being led or accompanied by a trainer for the purpose of training the dog and the trainer has documentation confirming the trainer is affiliated with a recognized or certified service dog training organization. Service animals in training are not permitted in classrooms, offices or other areas of campus buildings not open to the general public without DRC’s prior approval through the reasonable accommodation process. 

Additional Matters

A. Roommates: Upon approval of an ESA, or if a student intends to have a service animal in residential housing, the student’s roommate(s) will be notified (if applicable) that the approved animal will be residing in shared assigned living space and to solicit their acknowledgement of such arrangement. 

  1. All roommates must sign an agreement allowing the approved animal to be in residence with them. In the event that one or more roommates have concerns, the Office of Residential Life will consult with all of the individuals involved and, based on the circumstances, determine the appropriate course of action, including a possible switch in housing assignments. 
  2. If at a point later in time, there is a conflict between roommates regarding the animal that cannot be resolved amongst the individuals involved, the Office of Residential Life should be contacted. Appropriate parties will be consulted in order to reach a solution. 

B. Animal No Longer Necessary: The DRC should be notified when an animal covered by this Policy will no longer be in residence or, in the case of ESAs, is no longer needed as an accommodation. 

C. Conflicting Disabilities: Some people may have allergic reactions, asthma, respiratory diseases, etc. to animals that are substantial enough to qualify as disabilities. The University will consider the needs of these people along with the needs of the Handler/Owner in meeting its obligations to reasonably accommodate all disabilities to resolve the problem as efficiently and expeditiously as possible. Students requesting allergy accommodations should contact the DRC. 

D. Concerns: Concerns regarding an animal covered by this Policy shall be brought to the attention of the Director of the DRC at (619) 849-2533. 

  1. Handlers/Owners with animals covered by this Policy in residential housing should understand that issues may arise with other residents. Handlers/Owners should be receptive to these concerns and, if necessary, contact their respective Residence Hall Director for assistance in resolving the situation. 
  2. Other residents with minor concerns about an animal in their housing facility may discuss the matter with the Owner/Handler or talk with their respective Residence Hall Director. Major concerns should immediately be brought to the attention of the Director of the DRC. 

Grievance procedure related to service animals and emotional support animals

If the decision is made to deny a request for an ESA or to remove any animal covered by this Policy, the affected individual may proceed with an informal grievance with the DRC or a formal written grievance with the ADA/Section 504 Coordinator pursuant to the grievance procedures contained in the University’s Disability and Reasonable Accommodations Policy for Current and Prospective Students. 

Reasonable modifications to this policy

Individuals wishing to request a modification or exception to this Policy as a reasonable accommodation should contact the DRC. 

Policy History

This Policy is effective as of August 23, 2019. This Policy is subject to change or amendment at any time.