When Should Service Dogs Be Admitted into the Lab?

“The day I was going to commit suicide I sat down with my [life] insurance policy in my lap and a gun,” she tells The Scientist. But a nearby book with a golden retriever on the cover caught her attention. “I picked it up that day and started reading this book on the floor of my office with a gun on my lap.”

It was the story of a service dog that had helped a military veteran recover from severe symptoms of PTSD, and it gave her hope. She decided she would look into getting a service dog to help her reintegrate into society and ultimately launch a research career studying PTSD.

“I was like, maybe I can understand,” says Ramp. “I was within minutes of taking my own life, and I made the decision to instead try to rebuild one.”

Now with her own golden retriever service dog Sampson by her side, the 54-year-old is earning her second bachelor’s degree while working in the neuroscience lab of Justin Rhodes at the Beckman Institute for Advanced Science and Technology at the University of Illinois at Urbana-Champaign (U of I). With skills in brain sectioning, immunoassays, and genotyping under her belt, rave reviews from faculty, and an undergraduate thesis in the works, Ramp next wants to earn a PhD.

I was within minutes of taking my own life, and I made the deci­sion to instead try to rebuild one.

—Joey Ramp, University of Illinois

But her research career faces a major hurdle: at the University of Illinois, Sampson is not permitted into laboratories that study live mammals.
So far, the institution has prevented Ramp from taking a psychology laboratory course involving rat experiments and has kept her out of the Rhodes lab’s mouse facilities. “The next hurdle comes with my graduate work,” she says. “I [could] be up against the same resistance, and maybe won’t be able to follow the graduate direction that I had intended.”

Ramp’s situation raises a difficult question: When should service animals be permitted—or not permitted—in scientific laboratories? As is the case with most difficult questions, the answer is: it depends. Institutions must consider the rights of people with service animals, but also the safety of everyone involved, the integrity of the experiments, and federal regulations for animal care and use.

“It’s a very delicate balance,” says Patricia Redden, a professor of chemistry at Saint Peter’s University in New Jersey who raises service dogs and has served on American Chemical Society committees developing guidance on the admission of service dogs to chemistry labs. “You can’t really come out and say, ‘No, we absolutely categorically will not allow them.’ But on the other hand, you don’t want to come out and say, ‘Absolutely, you can bring your service dog in.’”

Bringing dogs into labs

Wherever Ramp goes, Sampson goes too. In addition to the physical support he provides—helping her up stairs and picking up items off the floor, for example—Sampson is trained to alert Ramp to signs that she is becoming overwhelmed. If she starts rubbing her hands together or tapping her finger, Sampson will get her attention by nudging her leg or hands, and Ramp can assess the situation—and remove herself from it, if necessary.

“He keeps me aware,” says Ramp. “If I don’t have him, and he doesn’t alert [me] to those types of things, I will continue to let those symptoms get worse.” In extreme cases, she continues, “I can completely dissociate to a point of not even being aware of my surroundings. And I will continue to function, drive, act, and do everything in a complete state of psychological fugue.”

For these reasons, Ramp says, she can’t be without Sampson. She first realized that this arrangement would present some challenges in her quest to become a neuroscientist when she started at Parkland College, a two-year community college in Champaign, Illinois, in the fall of 2012. The faculty and administrators had no experience with service animals in the laboratory. After several discussions, they arranged for Ramp and her service dog, then a Labrador retriever named Theo, to attend general chemistry lab courses. Some equipment was moved to ensure that Ramp wouldn’t have to crisscross the lab, and Theo had to wear goggles and shoes like the students did. “Everyone involved wanted to see if we could make it work,” says Parkland chemistry professor Andrew Holm.

When she started at U of I in 2015, Ramp expected things to be easier. With the institution’s 70-year history of disability services, “I didn’t foresee a problem,” she says. But like the employees at Parkland, the U of I faculty and staff had never fielded such a request, and the university didn’t have clear guidelines on admitting service dogs into laboratories.

LAB PARTNER #1: Theo was the first service dog allowed in a chemistry teaching lab at the University of Illinois.

lara curry

U of I is not unique in this respect. Universities typically don’t have rules regarding service dogs. And policies that do mention service animals generally do not detail procedures for their admission into teaching or research labs, says Jan Novakofski, associate vice chancellor for research compliance at U of I. School policies that mention the prohibition of service animals from the laboratory, such as those of Boston University and Brown University, are vague or allow for exceptions. “There’s no clear guidance on how to identify a service dog, more fundamentally, no less where can you take it,” says Redden. “It seems to be pretty much a school-by-school decision.”

Most of the time, accommodations can be made. In some cases, people who are able to be apart from their service animal might opt for that while in a lab, to ensure that their dog does not come into contact with any harmful agents or other dangers, says Jean Earle, CFO for a nonprofit organization that helps people with disabilities get education and work. Earle’s daughter, for example, is raising a service dog puppy while attending the University of Pennsylvania School of Veterinary Medicine, but chooses not to bring the dog into her labs, her mother says.

In other cases, the risks can be mitigated such that service dog teams can feel comfortable entering laboratory environments. In early 2016, after a year of discussions, Ramp’s dog Theo became the first service dog ever permitted in a chemistry lab at U of I. The following semester, Sampson accompanied Ramp for a molecular biology techniques course. But a psychology course that she wanted to take involved experiments with live rodents, and Janice Juraska, faculty supervisor for the course, was concerned that the rats would react to Sampson as if he were a predator. As a result, allowing Sampson into the laboratory space with live rodents would violate federal laws protecting research animals, says Robin Kaler, associate chancellor for public affairs at the university.

For lab exercises involving rats, Juraska and her colleagues said Sampson could stay in a nearby storage room while Ramp attended the session. But if Sampson wasn’t going into the lab, Ramp wasn’t going in either.

Vague legislation

The US Department of Agriculture’s Animal Welfare Act and Animal Welfare Regulations state that separation according to species may be necessary for the humane handling, care, and treatment of animals, while the Guide for the Care and Use of Laboratory Animals, put out by the National Research Council of the National Academies, recommends the separation of species “to prevent interspecies disease transmission and to eliminate the potential for anxiety and physiologic and behavioral changes due to interspecies conflict.”

These laws don’t address the presence of service animals in the laboratory specifically, and the National Institutes of Health’s Office of Extramural Research notes that there are many possible exceptions to the recommendation that different species be housed separately. But when it comes to service dogs, “generally they should not be brought into an animal facility or laboratory to ensure biosecurity,” according to a statement from the office emailed to The Scientist.

Kaler says the university staff’s hands are tied by the federal regulations. And while each request is evaluated individually, and thus there is not a university-wide ban per se, Kaler says, “we would not allow service animals in labs with live mammals.”

In addition to animal welfare regulations, a university must also take into consideration the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act. Both laws protect the right of people with service animals to enter areas that are open to the public. Yet neither the Animal Welfare Act nor the NRC Guide provides rules regarding the admission of service animals to teaching and research labs. “That’s where it’s become so gray,” says Redden. “The law is not totally clear on it.”

See “Ready, Willing, and Able”

When enforcing these federal regulations on campus, there are two relevant exceptions to the laws’ protection, says L. Scott Lissner, the ADA and 504 compliance officer at Ohio State University. The first is if there is a direct threat to the health and safety of others. “The very commonsense rule of thumb . . . is if people have to suit up to go into the lab, then usually the dog can’t go in.” For some labs, such as those associated with chemistry and biology courses, protective gear for the dog may suffice. Labs that maintain sterile facilities or contain hazardous pathogens, on the other hand, are typically off limits.

The second exception is if there is evidence that the animal’s presence would “fundamentally alter the nature of the work in the lab that was being done,” Lissner continues. “If we couldn’t properly do the experiment, then we couldn’t teach the class, or we couldn’t do the research.”

The nature of these rules necessitates universities’ case-by-case approach to requests to admit service dogs to the lab. “You just take every single situation and assess it carefully,” says Earle, who has advocated for access for her older daughter’s service dog to environments such as hospital rooms, so they could be together during recovery from surgery. “[The appropriate solution] would vary with every single lab, and every single topic; it could even vary with the particular curriculum and goals for that day.”

There’s no clear guidance on how to identify a service dog, more fundamen­tally, no less where can you take it.

—Patri­cia Redden, Saint Peter’s University

When it came to Ramp’s request to bring Sampson into the psych lab, Juraska had safety concerns. She thought that the dog risked exchanging pathogens with the rats, but more worrisome, his presence might affect the rats’ behavior. Becoming anxious or fearful, the rats might get agitated and bite a student, she says. Even a less extreme reaction could disrupt the experiments the students were running, and the rats could suffer in a way that went against animal welfare guidelines.  “Wolves, and by extension dogs, are known predators, and there is research [showing] that their presence can cause anxiety and aggression in a prey species,” Juraska tells The Scientist in a written statement.

LAB PARTNER #2: Sampson was the first service dog to enter a University of Illinois biology teaching lab, a molecular and physiology research lab, and a behavioral genetics and neuroscience research lab.

Thompson McClellan Photography

Ramp isn’t satisfied with the university’s justification. She’s been told by veterinarians that the risk of pathogen transmission between service animals and lab animals is very low, and she’s skeptical that Sampson, who has been specifically trained for the lab environment, will stress the rodents any more than a classroom full of students. But she has not been able to convince U of I. “It really became lots of resistance and no problem solving,” she says. “And I’ve been fighting that issue for the last year and half now.”

Accusations of discrimination

Although there is some evidence that wild rats respond to dogs as predators, Ramp could not find compelling research on the effect of dogs on lab rats. “These are not wild rodents,” Rhodes says. “They’re domesticated and have no experience with dogs.” But there doesn’t seem to be any research addressing this question.

Recognizing this problem, Ramp applied for and received a $50,000 grant from an independent donor through the university’s Disability Resources and Educational Services (DRES) for a two-year study to explore this question. She joined Rhodes’s lab and enlisted his help in writing a protocol for the study to submit to the Institutional Animal Care and Use Committee (IACUC).

The researchers proposed an experiment in which Ramp and Sampson would enter a room housing mice, and Sampson would lie on a mat. Ramp would record for ultrasonic vocalizations and assess the animals’ anxiety through behavioral tests. These results—along with levels of blood corticosterone—would be compared with the outcomes of the same experiments conducted by Ramp without Sampson present. (Ramp says she would work to ensure that the environment would be free of possible triggers and that she’d have help from Sampson immediately if she started to have symptoms. “The experiments would take place in short 10- to 15-minute increments so that I would only be separated from him for a short period,” Ramp explains.)

Service Dogs in the Lab When a student with a service animal chooses to take a laboratory course, she should contact the institution’s disability services office to help arrange accommodations. In consultation with the faculty and staff in charge of the lab sessions, the case worker and student can devise a plan to ensure the safety of everyone involved. Laboratory accommodations for service dogs Training a service dog for a laboratory environment See full infographic: WEB | PDF

The study could provide data to guide appropriate policies regarding service animals in labs with live animals, Ramps says, and either give her confidence to pursue research that involves rodents or push her in a different direction. But to her and Rhodes’s surprise, the IACUC rejected the protocol—twice.

The first rejection, from last December, simply cites “insufficient justification for the use of live vertebrate animals (mice).” Assuming the committee had misunderstood their proposal, Ramp and Rhodes had multiple meetings with Pat Malik, the director of DRES, and also spoke with IACUC head Josh Gulley. Rhodes then went before the entire committee to explain the scientific rationale and assure them that the experiment would be “pretty much innocuous” for the mice involved—IACUC’s main concern being for the welfare of the animals and the scientific justification for any harm they might endure. But again in March, the committee denied the request.

“I didn’t understand why,” Rhodes says. “I’m still surprised.”

The second rejection letter listed four main objections, including concerns related to the study’s purpose, the lack of a hypothesis, and the possible biosecurity risk. But none of the arguments “held any water,” Rhodes insists. “It’s the kind of experience where you think you’re going crazy. . . . There doesn’t seem to be any legitimate reason why they would block us.”

Rhodes has never had another protocol rejected by the IACUC at U of I—and he’s written a dozen or more—nor does he know anyone who has had a protocol rejected. B. Taylor Bennett, senior scientific advisor at the National Association for Biomedical Research, says that IACUCs “rarely reject a protocol outright unless it involves projects that they are not equipped to support, or where the biosecurity of the animals would be an issue.”

Gulley says he is not able to comment on specific IACUC submissions. Juraska, who has not read the protocol, has concerns about Ramp conducting the experiment herself. “That would not be correct scientific practice,” she writes to The Scientist. “A disinterested person should do the actual experiment, one who does not have a stake in the outcome and does not even know whether the dog is in the room.”

ALWAYS THERE: Sampson accompanies Ramp to a ceremony for a Fred S. Bailey scholarship she was awarded.

Courtesy of joey ramp

Ramp says she suspects that Sampson’s ban from the psych lab and the IACUC’s rejection of their proposal are related, and stem from prejudice against people with service dogs. In May, she filed a complaint with the US Department of Education’s Office for Civil Rights (OCR) alleging discrimination by the university, the IACUC committee, and Juraska.

“We think that the entire response of the university reflects discrimination and in some respects may reflect retaliation for her efforts . . . to bring her dog in [to the lab],” says Ramp’s lawyer Matt Cohen, who specializes in disability rights.

The university declined to participate in mediation, Cohen says, and the OCR has initiated an investigation on the IACUC’s rejection. (The agency is not investigating Sampson’s ban from the psychology lab course because the complaint was filed more than 180 days after the incident.) The university would not confirm or deny the complaint or investigation.

Ramp paves the way

Regardless of the outcome of her legal case, Ramp is hoping that her story will motivate the development of better guidelines for making accommodations for people with service dogs in the sciences, whether in laboratory classes or research facilities with animals.

Service animals are becoming more common—the number of active guide, hearing, and service dogs in North America, Australia, New Zealand, and Asia nearly doubled between 2009 and 2017, from 10,769 to 19,144, says Chris Diefenthaler, operations administrator at Assistance Dogs International. Thus, this is an issue that universities are likely to face more frequently.

According to Kaler, U of I is already developing an update to its policy on animals on campus. Administrators have been working for a year on a version that will specifically mention labs. The new policy has been reviewed by the university’s legal team and has begun the process of review by the university. Students, faculty, and other staff will have the opportunity to comment before it is added to the Campus Administrative Manual, she says.

Several institutions have already published new policies on having animals on campus in the last several years, and many more are on the way, says Novakofski. But given the rare and diverse nature of the requests to bring service dogs into the laboratory, it’s “hard to come up with hard and fast rules that are simple enough for everyone to follow and still are acceptable legally,” Earle reiterates. More important than concrete policies on service dogs in the lab, she adds, are guidelines on what to consider when making the decision and protocols for making accommodations when appropriate.

In March, Redden and Christopher Sweet at Cornell University’s Institute on Employment and Disability published a chapter in an ACS Symposium Series book on admitting service dogs to chemistry labs. And Ramp has put together a template based on her experiences with Theo and Sampson. (See infographic on page 47.) At Parkland College, her efforts are already making a difference, says Parkland’s Holm. The campus has since made accommodations for service animals to accompany their handlers to the gym and to a cadaver lab, and there is currently a student with a service dog taking the same intro chemistry lab that Ramp took with Theo. “Her pioneering—it’s paying off,” Holm says.

A career in research may not be in the cards for Ramp, though. While she awaits the OCR’s decision, she is considering her future. If she is unable to get IACUC approval for her study, she will lose her funding, and she will not have data to know whether she can conduct the mouse experiments she’d envisioned for her graduate research. One back-up plan on the table is attending law school. If science doesn’t work out, Ramp hopes that a law degree could allow her to help other individuals with service dogs navigate the legal system, and to change policies that discourage these people from pursuing an education in STEM.

“When a barrier becomes immovable then how do you maneuver around it?” says Ramp. “Perhaps this could be the way I could open doors for other scientists who follow me.” 

Service Dog Poses Hurdles for Pre-Vet Student Since she was four years old, Sydney Sheets has wanted to be a veterinarian. She joined 4H when she was nine and began training and showing dogs. Beginning in fifth grade, she volunteered at a local vet clinic, even scrubbing in for surgeries. And when she started college in 2015, she chose Texas A&M University because of its renowned veterinary medicine program. But at age 16, Sheets learned she had type 1 diabetes. Rocked by the diagnosis, she focused on something a nurse at the hospital had told her—she could get a service dog. She found her puppy, a Belgian tervuren she named HALO, through a certified breeder, and with the help of her dad and 4H leaders, trained him to alert her to dangerous swings in her blood sugar levels. By her sophomore year of college, Sheets didn’t go anywhere without him. Like Joey Ramp, Sheets is running into problems pursuing her dream job and the education that would make it a reality with a service dog by her side. Both at Texas A&M and at Tacoma Community College outside of Seattle, where she took classes during the summer, HALO attended biology and chemistry labs with Sheets. He even followed along to a course on reproduction in farm animals, which included palpating a cow to check to see if it was pregnant. The professors, TAs, and administrators at the school helped make the necessary accommodations to allow HALO to continue monitoring Sheets while she participated in such activities. But when she enrolled in an animal science research class that involved field trips to the Texas A&M’s horse, sheep, pig, and cattle facilities, the professor, Courtney Daigle, told Sheets that HALO was not allowed. Sheets filed a complaint with the school, which found that the professor had not been in compliance with the ADA, Sheets says. Still, she withdrew from the class, later switched her major to sociology, and is now rethinking her career direction. “[The incident] just kind of sucked a lot of the joy out of what I was doing,” says Sheets, who is set to graduate in December 2019 and hopes to pursue a PhD in psychology. The university could not confirm or deny the existence of the complaint or the experiences of an individual student; Daigle did not respond to requests for comment before deadline. Sheets’s experience, like Ramp’s, illustrates the challenges of bringing a service dog into the sciences. “It’s really discouraging,” says Sheets. “A lot of people are not going to do STEM just because some battles aren’t necessarily worth fighting that hard.” “For her to say I’m done [with veterinary medicine] was a little bit heartbreaking for all of us,” says Sydney’s mom Karin Sheets, “because this has always been her dream.” COURTESY OF SYDNEY SHEETS

A version of this story ran on the-scientist.com on September 18, 2018.