How OH can help to address this important question?

The increase in pet ownership in the UK has increased with an estimated 3.2m households now having a pet. Young people are the main drivers of this trend, with more than half of new owners aged 16 to 34.  Animal welfare organisations have been warning that pets may struggle to adjust to their owners leaving home all day when they return to the workplace post lockdown.  A survey of 1,003 employees conducted by comparethemarket.com in June found that almost half of respondents (42%) were hoping to bring their dog to the office.  It is therefore no surprise that employers are now starting to be asked by their employees ‘Can I bring my dog to work?’

In the UK, we have 3 types of assistance dog all trained and supported by the charity sector.  Guide dogs for visual impairment are trained and supported by Guide Dogs UK.  Hearing Dogs for Deaf People train and support dogs for those with hearing impairment. 

Assistance Dogs UK (ADUK) is a coalition of assistance dog organisations that have been accredited by Assistance Dogs International (ADI) and/or The International Guide Dog Federation (IGDF).  All ADUK members are non-profit organisations that work to the highest standards of guide dog and assistance dog training and welfare. Some of these organisations train and support mobility assistance dogs for those with a physical disability.  Mobility assistance dogs are considered a service dog which includes medical detection dogs for alerting partners to an impending medical event.  There are also autism assistance dogs provided to children and adults with autistic spectrum conditions.  There is no legal requirement for individuals to use any service provider and they may train their own service animal.  It would be expected that the individual will have received training in how to do this.

There is a separate sector of assistance dogs that are considered essential to those who require psychological assistance.  Emotional Support Animals (ESA) are not recognised within UK law around assistance dogs but the use of animals to help overcome disability related symptoms is an expanding trend. 

For businesses that do not have a dogs at work policy, a policy on bringing dogs into the workplace for any reason may be required.  Whether the policy can support a move towards allowing dogs to come into the workplace is likely to depend on the employees’ job and the work environment. 

Assuming the employer has a dog at work policy already in place, modification to the policy on dogs at work may be needed.  When considering the individual’s request to bring an ESA into work Employers may wish seek OH advice in relation to the need for an ESA at work.  This may not be obvious for those with an ESA rather than an assistance dog for visual, hearing or physical impairment.  The consideration of an ESA may be considered as an accommodation related to a disability. 

A business may refer to occupational health to seek advice on the need adjustments at work including an ESA.  The advice required is likely to be:

1. What limitations is the employee experiencing?
2. How do these limitations affect the employee and the employee’s job performance?
3. What specific job tasks are problematic as a result of these limitations?
4. What accommodations are available to reduce or eliminate these problems? Are all possible resources being used to determine possible accommodations?
5. Once accommodations are in place, would it be useful to meet with the employee to evaluate the effectiveness of the accommodations and to determine whether additional accommodations are needed?
6. Do supervisory personnel and employees need training?

In relation to an ESA:

• How does the ESA benefit the individual with psychological symptoms?

The benefits of an ESA could range from improving social interaction, self-esteem and independence to improving confidence and assertiveness.  ESA’s are thought to be able to reduce loneliness and depression through providing companionship.

Once the need for an ESA has been established, the employer will wish to establish if the ESA of choice has been sufficiently trained to be brought into a work environment.  Regardless of who has trained the ESA, the animal is likely to need to have the following attributes:

• will not wander freely
• will sit or lie on the floor next to the owner during work time
• will not foul in a public place
• will always be under control
• will not be a nuisance to anyone in the workplace
• will not jump up people
• will lie down when the owner sits to eat
• will have received extensive training which may be delivered by the owner but is likely to have required some training for the owner also

An employer will want to consider where the ESA is trained to be in a work environment and will be under the employees’ control at all times.  It is not likely that the employee will need to support an ESA if this causes undue hardship or nuisance to other staff or the ability to conduct business.  It is also important for employers to consider how having multiple dogs in the workplace will impact on an assistance dog and their handler.

With regard to other workers who are concerned about an allergy to the ESA, the requirement for a registered support animal as a reasonable adjustment should not be restricted by the allergies of another member of staff.  Steps should be taken to ensure that the member of staff with the allergy is protected from the hazard. A trial for the ESA may be considered and if this is not successful, more time could be allowed for training before a final decision is made.  It may be agreed that although an ESA would be beneficial, the ESA in question does not meet the requirements for that ESA to be present in the workplace.  Each case should be considered individually to ensure a fair and consistent process. Staywell are happy to support your decision making through our management referral service.

By Jane Lavery, Senior Occupational Health Advisor, Staywell Occupational Health