I read an article this week and actually said out loud, “Wait. What?”
SHRM—the Society for Human Resource Management—is headed to trial over an ADA accommodation case involving a job applicant with diabetes and her trained medical alert service dog.
According to the reporting, SHRM says it engaged in the interactive process and explored alternative accommodations, including allowing the applicant to use her continuous glucose monitor and insulin pump, take breaks as needed, and keep food and drinks at her workstation. SHRM also reportedly asked her to speak with her physician about alternatives to the service dog.
And I have to tell you, this one surprised me.
There is a phrase we use all the time in ADA work: An employee isn’t necessarily entitled to the accommodation of their choice. That’s true. When more than one accommodation is effective, an employer may be able to provide an effective alternative.
But when we’re talking about a legitimate, task-trained service animal, my practical advice to employers is different.
If an employee uses a guide dog, seizure-alert dog, diabetic-alert dog, or another service animal trained to perform a specific task related to that person’s disability, I generally don’t begin by asking, “What can we give them instead of the dog?”
My starting point is that the service animal will be accommodated in the workplace. If leadership raises a legitimate concern about having the animal there, then we work through that concern.
There certainly can be situations where the presence of a service animal creates a real problem. The ADA allows employers to consider undue hardship—significant difficulty or expense—and direct threat, which requires a significant risk of substantial harm that cannot be eliminated or reduced through reasonable accommodation. Think about environments such as certain sterile or medical settings, particular food-production operations, or workplaces where an animal could create an actual health or safety risk. Those situations require an individualized analysis.
But absent a legitimate issue like that? My advice has generally been pretty simple:
Accommodate the service animal.
That’s why I keep coming back to one question as I read about this case:
What was the problem with the dog?
What was the hardship? What was the safety concern? What operational problem would this particular trained medical alert dog have created for someone working as a Senior Specialist in product management?
Maybe there was one. I wasn’t involved in this case, I haven’t seen the evidence, and there may be important facts that haven’t been publicly reported.
But that’s the information I want to understand.
A properly trained service dog isn’t a pet someone wants to bring to work. The dog is working. Many service dogs spend much of the workday quietly at or near their handler’s feet, appearing to do absolutely nothing—which, frankly, is exactly what a well-trained working dog may look like until it needs to perform its task.
And in this case, according to the reporting, SHRM appears to have understood that the applicant had diabetes and that the dog performed a medical-alert function.
So when I read about glucose monitoring, insulin pumps, food, breaks, and other possible alternatives, my first question wasn’t, “Could one of those potentially be an effective alternative accommodation?”
My first question was:
Why were we looking for an alternative to the service dog in the first place?
That distinction matters to me.
There are plenty of accommodation requests where exploring alternatives is part of what we routinely do. An employee requests permanent work from home, for example, and we may identify several other effective ways to address the disability-related limitation while allowing the employee to work onsite.
A legitimate, task-trained medical service animal is different in my practice.
When someone tells me that their trained dog alerts them to a dangerous change in blood sugar, warns them before a seizure, or guides them because they are blind, I’m not starting from, “Let’s find something else.”
I’m starting from, “Let’s understand the service this animal performs and figure out how we make this work.”
That doesn’t mean employers shouldn’t ask questions or establish expectations. Quite the opposite.
My usual practice is to first understand and confirm the disability-related function the animal performs. Then the employer will want to meet with the employee and, when appropriate, the service animal before it begins working onsite. We want to see that the animal is under the employee’s control and talk through the very ordinary logistics of having a working animal in the workplace.
Where will the service animal eat and relieve itself? Who is responsible for cleanup? What happens if the service animal is unavailable one day? Can the employee work without it, or will another accommodation or leave be needed?
We can also discuss what will be communicated to coworkers. It may be as simple as:
“Please be advised that a working service animal will begin in the workplace on [date]. The animal is working and should not be approached, distracted, or petted. If you have questions about the service animal, please contact [HR/contact information].”
That advance communication also gives HR an opportunity to learn about legitimate concerns from other employees, including allergies, phobias, or another disability-related issue.
If another employee raises a disability-related concern, that’s another accommodation request to work through. It doesn’t automatically mean the service animal disappears. Now we have two employees whose needs we need to understand and a workplace solution to figure out.
That’s the work.
And that’s also why I don’t put every request involving an animal into the same bucket.
An emotional support animal often requires a different analysis from a dog individually trained to perform a disability-related task. We need to understand what the animal does, what disability-related need it addresses, what is happening in the actual workplace, and what issues—if any—the animal’s presence creates.
But when I have confirmed that we’re dealing with a legitimate ADA service animal performing a trained task for a person with a disability, my orientation changes.
I’m not looking for a reason to replace the animal. I’m looking for a way to support the animal being in service in the workplace—unless the facts give me a legitimate reason that it cannot be.
And perhaps that’s what makes this SHRM case so interesting to me.
SHRM is one of the organizations HR professionals across the country look to for guidance about difficult workplace issues. So seeing the country’s most recognizable HR association headed to trial over the handling of a request involving a trained diabetic-alert service dog made me stop and think.
Again, I don’t know what happened behind the scenes. I wasn’t involved, I haven’t seen the evidence, and facts may come out at trial that make SHRM’s reasoning much clearer.
But based on what has been publicly reported so far, I’m left with a question I would want every ADA practitioner to ask:
If we’ve established that this is a legitimate service animal performing a trained disability-related function, what problem are we actually trying to solve by replacing it?
If the answer is undue hardship, let’s analyze the hardship. If it’s direct threat, let’s identify the objective evidence of the significant safety risk and determine whether it can be reduced or eliminated. If there’s another legitimate workplace concern, let’s understand it and work through it.
But if we don’t have one?
Maybe we already have a perfectly reasonable accommodation sitting quietly under the employee’s desk.
And this is exactly why I created the ADA Decision Lab.
You could spend an entire career managing workplace accommodations and encounter only one or two service-animal requests. The first time you really think through diabetic-alert dogs, seizure-alert dogs, guide dogs, emotional support animals, coworker allergies, animal behavior, workplace communication, and all the strange little logistical questions that accompany these cases shouldn’t have to be when an employee is sitting across the table waiting for your answer to start a job or continue working fully and safely.
We can practice first.
That’s what we do in the Lab. We work through situations that may not land on your desk every day so that when they do, you’re not encountering them for the first time.
Because knowing the ADA matters. But knowing what to do with it when a real human being and a very real set of facts show up at your door? That’s where competence, curiosity, confidence, and courage matter.
I don’t know what did or didn’t happen inside SHRM in this case. I’m interested to see what we learn as it moves forward.
But I do know what my advice continues to be:
When you confirm that an employee has a legitimate, task-trained service animal, don’t begin by looking for an alternative to the animal. Begin by figuring out how to make the service animal work in your workplace.
If you’d like a place to practice these decisions with me before they land on your desk, I’d love to have you in the 2027 ADA Decision Lab.
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