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Letter to Minister Lecce on Policy/Program Memorandum (PPM) No. 163 – School Board Policies on Service Animals

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September 30, 2019

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Hon. Stephen Lecce
Minister of Education
5th Flr, 438 University Ave
Toronto, ON M7A 2A5

Dear Minister Lecce,

I trust this letter finds you well. On behalf of the Ontario Human Rights Commission (OHRC), congratulations on your appointment as Minister of Education. In its 2017-2022 Strategic Plan, the OHRC identified education as a focus area and committed to identifying and addressing the systemic discrimination children and youth face in education.

I am writing today about the Ministry of Education’s newly released PPM No. 163 – School Board Policies on Service Animals. In May 2019, I wrote to your predecessor to make a submission to the Ministry’s consultation on the draft PPM. As I indicated in May, the OHRC generally supports the overall intent of the PPM. It appropriately recognizes that under the Code, school boards have a duty to accommodate the needs of students with disabilities up to the point of undue hardship, and that nothing in the PPM detracts from a school board’s legal obligations under the Code.

PPM No. 163 is generally consistent with the recommendations we made in our May submission. We said that school board policies must:

  1. Allow a student to use a service animal in school to accommodate disability needs whether or not related to learning needs
  2. Not automatically limit the species of animal or disability-related function that could be accommodated
  3. Not automatically exclude animals that lack designated professional training or certification
  4. Allow a student with a disability to take part in the process for determining an appropriate accommodation for their service animal, and make sure the process maximizes the student’s right to privacy.

We are pleased to see changes in the final PPM that address our first recommendation in particular. More specifically, PPM No. 163 now provides that school boards are to consider “how the service animal supports the student’s learning needs and/or disability-related needs.”

While not addressed directly in PPM No. 163, school board policies on service animals should also identify that schools and other parties in the process need to be open to exploring and testing solutions as part of the duty to accommodate. Students with disabilities should have the opportunity to take part in the accommodation process as well, based on their abilities, maturity and age.

We welcome any opportunity to meet to discuss this matter or other matters involving human rights and Ontario’s education system.


Renu Mandhane, B.A., J.D., LL.M.
Chief Commissioner

cc:       Hon. Doug Downey, Attorney General
Hon. Raymond Cho, Minister for Seniors and Accessibility
Rusty Hick, Executive Director, Ontario Public School Boards' Association
Isabelle Girard, Direction générale, Association des conseils scolaires des écoles publiques de l’Ontario
Nick Milanetti, Executive Director, Ontario Catholic School Trustees' Association
Janine Griffore, Directrice générale par interim, Association franco-ontarienne des conseils scolaires catholiques
Lynn Ziraldo, Chair, AODA Standards Development Committee for K-12 Education
OHRC Commissioners