A fundamental component of Work Health and Safety (WHS) practice is the ability to identify hazards, assess associated risks and implement effective control measures.
For Occupational Therapists (OTs) working with assistance animals, risk management requires consideration of the interaction between:
- the person using the assistance animal;
- the assistance animal;
- the environment;
- the activity being undertaken;
- equipment;
- other animals;
- workers, support people and other stakeholders; and
- organisational systems.
Assistance animal practice involves particular risks because it combines disability support, animal behaviour and welfare, public access, environmental interaction and community participation.
Effective risk management enables Occupational Therapists to support safe and meaningful participation while protecting clients, assistance animals, workers, workplaces and the broader community.
Risk management is not about eliminating all risk. Rather, it involves identifying hazards, understanding their likelihood and potential consequences, implementing appropriate controls and reviewing whether those controls remain effective.
Within assistance animal practice, risk management should also recognise:
- client autonomy;
- dignity of risk;
- positive risk-taking;
- reasonable adjustments;
- occupational participation;
- least-restrictive effective controls; and
- assistance animal welfare.
Hazard Identification
What is a Hazard?
A hazard is anything that has the potential to cause injury, illness or other harm.
Hazards may arise from:
- animals;
- people;
- environments;
- equipment;
- work processes;
- substances;
- activities; and
- organisational systems.
Occupational Therapists should adopt a proactive approach to hazard identification by considering foreseeable risks before an incident occurs.
Hazards should be described as specifically as possible.
A person’s disability should not itself be described as the hazard.
For example, rather than recording:
“Client has reduced mobility,”
a more useful hazard description may be:
“The narrow doorway and positioning of equipment restrict safe movement for the client’s mobility device and assistance dog, increasing collision and falls risk.”
This identifies the actual interaction requiring assessment and control.
Hazard Identification in Assistance Animal Practice
1. Animal Behaviour and Welfare Hazards
Assistance animals may be highly trained; however, they remain living, sentient animals with individual physical, behavioural and emotional needs.
Potential hazards may include:
- stress or fear;
- fatigue or excessive workload;
- pain, injury or illness affecting behaviour or performance;
- inappropriate task expectations;
- inadequate training;
- inappropriate or poorly fitted equipment;
- unsafe interactions with other animals or people; and
- environmental conditions affecting animal welfare.
Example
An assistance dog experiencing stress in a crowded shopping centre may display:
- avoidance;
- scanning;
- reduced engagement;
- displacement behaviours;
- difficulty settling; or
- reduced task performance.
Possible controls may include:
- monitoring signs of stress;
- providing appropriate rest;
- reducing duration;
- changing the timing or route;
- environmental modification;
- modifying the task; and
- consulting an appropriately qualified trainer, behaviour professional or veterinarian where required.
2. Person–Task Interaction and Client Safety
Occupational Therapists should consider whether the interaction between the person, assistance animal, task, equipment and environment can be undertaken safely and sustainably.
Relevant considerations may include:
- falls risk;
- fatigue;
- pain;
- changing health or function;
- communication requirements;
- sensory requirements;
- equipment use;
- environmental barriers;
- existing skills;
- training needs;
- available formal or informal supports; and
- reasonable adjustments.
These factors should not be interpreted as meaning that the person’s disability itself is the hazard.
Assessment should identify:
- the person’s strengths;
- functional needs;
- existing strategies;
- preferred supports;
- specific task demands;
- environmental barriers;
- equipment requirements; and
- controls that may enable participation.
Example
A person using an assistance dog for mobility support may experience increased falls risk where:
- flooring is slippery;
- there is insufficient space for both the mobility device and dog;
- equipment obstructs movement; or
- the person has not yet had sufficient opportunity to learn a new handling technique.
Possible controls may include:
- environmental modification;
- equipment changes;
- additional training;
- task modification;
- additional support where appropriate; and
- review of the person–animal–environment interaction.
The need for support does not automatically mean that an assistance animal partnership is unsafe or inappropriate.
3. Environmental Hazards
The environment plays a significant role in assistance animal safety.
Potential hazards may include:
- slippery flooring;
- uneven surfaces;
- stairs;
- narrow spaces;
- excessive noise;
- crowds;
- inaccessible facilities;
- unsafe workplace layouts;
- extreme temperatures;
- traffic;
- other animals; and
- inadequate emergency access.
Example
A school environment may present risks relating to:
- unpredictable movement of students;
- children approaching the animal;
- food or other items on the floor;
- allergy concerns;
- high noise levels;
- inadequate space;
- insufficient rest opportunities; and
- emergency evacuation.
Possible controls may include:
- environmental assessment;
- education of staff and students;
- appropriate rest areas;
- environmental modification;
- scheduling;
- supervision; and
- emergency planning.
Where an environmental hazard is identified, practitioners should consider whether the hazard or environment can be modified before concluding that the assistance animal team cannot participate.
4. Public Access Hazards
Assistance animals frequently operate in public environments where risks may arise from:
- members of the public touching or distracting the animal;
- conflict regarding access rights;
- other animals approaching;
- crowded environments;
- unsafe flooring;
- inappropriate community interactions;
- environmental hazards; and
- animal stress or fatigue.
Occupational Therapists may support clients to develop strategies for:
- managing public interactions;
- communicating boundaries;
- maintaining animal focus;
- recognising emerging hazards;
- accessing support;
- responding to unexpected situations; and
- protecting animal welfare.
The presence of an assistance animal should not itself be treated as a public-access hazard.
Risk assessment should distinguish genuine safety concerns from:
- inconvenience;
- assumptions about disability;
- misunderstanding of assistance animals; or
- discriminatory attitudes.
5. Infection Control and Biological Hazards
Assistance animal practice may involve exposure to:
- animal waste;
- parasites;
- zoonotic disease;
- contaminated surfaces;
- bodily fluids; and
- biological contamination.
Risk controls may include:
- hand hygiene;
- cleaning and disinfection;
- safe management of animal waste;
- parasite prevention;
- preventive veterinary healthcare;
- appropriate management of animal illness;
- vaccination where clinically indicated or required by the relevant setting, program or applicable requirements; and
- appropriate PPE where required.
Infection-control measures should be proportionate to the identified risk and should support inclusion wherever reasonably practicable.
6. Manual Task Hazards
Manual-task risks may arise through:
- animal handling within professional competence;
- transporting equipment;
- working around mobility devices;
- fitting or positioning equipment;
- lifting supplies;
- repetitive tasks;
- awkward postures; and
- responding to unexpected movement or emergencies.
Potential injuries may include:
- muscular strain;
- sprains;
- repetitive strain injuries; and
- falls.
Risk controls may include:
- ergonomic assessment;
- safe task design;
- environmental modification;
- appropriate equipment;
- assistive technology;
- training;
- pacing; and
- additional assistance where required.
7. Psychosocial Hazards
Assistance animal practice may involve psychosocial hazards such as:
- excessive workload;
- low job control;
- inadequate support;
- poor role clarity;
- workplace conflict;
- bullying or harassment;
- occupational violence and aggression;
- public-access confrontation;
- discrimination;
- emotionally demanding work;
- traumatic incidents;
- lone or remote work;
- animal injury or illness;
- euthanasia or retirement;
- unsuccessful assistance animal partnerships;
- client trauma;
- moral distress; and
- inadequate organisational support following incidents.
Controls may include:
- workload design;
- role clarity;
- adequate staffing;
- supervision;
- safe home and community visit arrangements;
- check-in or duress systems;
- violence-prevention measures;
- clear escalation pathways;
- incident-management processes;
- training;
- appropriate recovery time; and
- professional support.
Individual strategies such as self-care or Employee Assistance Programs may provide additional support but should not replace controls directed at the source of the workplace hazard.
Risk Assessment Process
Once hazards have been identified, risks should be assessed where required.
Risk assessment involves considering:
- the likelihood that harm may occur;
- the potential consequences if harm occurs;
- who or what may be affected;
- existing controls;
- whether additional controls are required; and
- the residual risk after controls are implemented.
The formality of risk assessment should be proportionate to the circumstances and level of risk.
Not every activity requires a new formal written risk assessment.
Depending on the circumstances, risk assessment may involve:
- an existing organisational risk assessment;
- review of an existing assessment;
- a task-specific assessment;
- environmental assessment;
- pre-visit screening;
- dynamic assessment;
- professional judgement; or
- a formal documented risk assessment.
Risk Assessment Matrix
A risk matrix may assist practitioners to estimate risk by considering:
Likelihood
How likely is the event to occur?
Examples may include:
- Rare;
- Unlikely;
- Possible;
- Likely; and
- Almost Certain.
Consequence
How serious could the outcome be?
Examples may include:
- Insignificant;
- Minor;
- Moderate;
- Major; and
- Catastrophic.
The combination of likelihood and consequence may be used to determine an overall risk rating.
Risk matrices support structured reasoning but should not replace professional judgement.
Example Risk Assessment
Scenario
An assistance dog is being introduced into a primary school environment.
| Hazard |
Potential Outcome |
Likelihood |
Consequence |
Possible Controls |
| Students approaching the dog while working |
Dog distraction or stress |
Possible |
Moderate |
Education, interaction rules, staff supervision |
| Significant allergy risk |
Allergic reaction |
Possible |
Major |
Individual assessment, consultation, environmental planning and controls |
| Excessive workload |
Fatigue, reduced welfare and performance |
Possible |
Moderate |
Rest periods, quiet area, workload monitoring |
| Slippery flooring |
Falls or injury |
Possible |
Moderate |
Environmental assessment, maintenance, route or surface modification |
| Emergency evacuation |
Separation or difficulty evacuating safely |
Possible |
Major |
Accessible evacuation and continuity planning |
Controls should be individualised to the actual circumstances.
Risk Management, Participation and Dignity of Risk
Risk assessment should support informed decision-making rather than operate as a mechanism for automatically restricting participation.
Within assistance animal practice, practitioners should consider both:
the risks associated with participation
and
the risks and consequences associated with preventing participation.
Restricting or removing access to an assistance animal may itself affect:
- mobility;
- medical safety;
- independence;
- communication;
- employment;
- education;
- community participation;
- social inclusion; and
- occupational performance.
Risk management should therefore consider:
- the person’s goals;
- the benefits of participation;
- foreseeable harms;
- likelihood and consequence;
- existing controls;
- reasonable adjustments;
- available supports;
- animal welfare;
- the person’s preferences;
- the consequences of restriction; and
- whether a less restrictive option can adequately manage the risk.
The existence of risk does not automatically justify exclusion.
Similarly, disability, support needs, equipment use or reliance on another person do not themselves establish that an activity is unsafe.
Positive Risk-Taking
Positive risk-taking involves supporting meaningful participation while identifying and managing foreseeable harm.
It does not mean ignoring risk.
Instead, practitioners should consider:
- What does the person want to achieve?
- What are the benefits?
- What could reasonably go wrong?
- How significant is the risk?
- What controls are available?
- What reasonable adjustments could assist?
- What are the animal welfare implications?
- What residual risk remains?
- What are the consequences of preventing participation?
Positive risk-taking supports professional reasoning that is:
- individualised;
- collaborative;
- evidence-informed;
- proportionate; and
- responsive to both human safety and animal welfare.
Hierarchy of Risk Control
The hierarchy of controls provides a framework for selecting measures to eliminate or minimise risk.
Controls should generally be considered from the highest level of protection to the lowest.
More than one control may be required.
1. Elimination
Elimination involves removing the hazard where this is reasonably practicable.
Examples may include:
- removing damaged equipment from use;
- removing an unnecessary hazardous substance;
- removing a trip hazard from an access route; or
- discontinuing an unnecessarily hazardous component of an activity while preserving participation where possible.
Elimination should focus on eliminating the hazard—not automatically eliminating the person, assistance animal or activity.
For example, if an assistance animal team encounters an obstructed access route, eliminating the obstruction is preferable to simply excluding the team from the environment where this is reasonably practicable.
2. Substitution
Substitution involves replacing a hazard with a safer alternative.
Examples may include:
- using a safer cleaning product;
- changing equipment;
- using a safer route; or
- modifying a particular method of completing a task.
3. Isolation
Isolation separates people or animals from the hazard.
Examples may include:
- separating an assistance animal from an uncontrolled unfamiliar animal;
- providing a quiet rest space away from heavy pedestrian traffic; or
- restricting access to a genuinely hazardous work area while providing an accessible alternative route.
Isolation should target the hazard rather than unnecessarily isolating the disabled person from participation.
4. Engineering Controls
Engineering controls involve physical or environmental changes.
Examples include:
- accessibility modifications;
- barriers;
- improved flooring;
- improved layout;
- ventilation;
- equipment modification; and
- changes to access routes.
5. Administrative Controls
Administrative controls change the way work or activities are organised.
Examples include:
- policies;
- procedures;
- training;
- supervision;
- education;
- scheduling;
- communication systems;
- checklists;
- workload management; and
- emergency planning.
6. Personal Protective Equipment
PPE may reduce exposure to particular hazards.
Examples include:
- gloves;
- protective clothing; and
- other task-appropriate protective equipment.
PPE is generally a lower-order control and should not be relied upon where a more effective higher-order control is reasonably practicable.
Least-Restrictive Risk Management
Risk controls should be effective without imposing unnecessary restrictions on the person or assistance animal.
Where several effective options are available, practitioners should consider the option that:
- adequately manages the risk;
- supports the person’s goals;
- preserves occupational participation;
- respects autonomy;
- protects animal welfare; and
- creates the least unnecessary restriction.
Depending on the circumstances, controls may include:
- education;
- training;
- equipment;
- environmental modification;
- task modification;
- scheduling;
- additional support;
- communication;
- changes in workload;
- contingency planning; and
- emergency planning.
Excluding an assistance animal, preventing an activity or withdrawing a service should not be the automatic first response where less restrictive effective controls are reasonably available.
Residual Risk
Risk may remain after appropriate controls have been implemented.
The existence of residual risk does not automatically mean an activity is unacceptable.
Practitioners should consider:
- the nature of the remaining risk;
- likelihood and consequence;
- effectiveness of controls;
- benefits of participation;
- client preferences;
- animal welfare;
- risk to workers or others;
- applicable legal obligations; and
- whether further reasonably practicable controls are available.
Where significant risk remains that cannot be adequately controlled, the practitioner should clearly document:
- the specific hazard;
- the risk;
- controls considered or attempted;
- consultation undertaken;
- reasons further participation cannot presently proceed in the proposed manner;
- alternative ways of achieving the goal where possible; and
- circumstances in which the decision should be reviewed.
A decision that a particular activity cannot presently proceed safely should not be converted into a broad conclusion that the person is inherently “unsafe”, “incapable” or “unsuitable”.
Reviewing Risk Controls
Risk management is an ongoing process.
Controls should be reviewed when:
- circumstances change;
- the person’s needs or goals change;
- the animal’s health or behaviour changes;
- an incident or near miss occurs;
- new hazards are identified;
- equipment changes;
- the environment changes;
- a control is ineffective; or
- a restriction may no longer be required.
Review should consider whether controls:
- remain necessary;
- remain effective;
- have created unintended barriers;
- remain proportionate;
- continue to support animal welfare; and
- can now be reduced or removed.
A restrictive control should not continue indefinitely simply because it was once considered necessary.
Communicating Risk Information
Occupational Therapists should communicate relevant hazards and risk controls clearly to appropriate stakeholders.
Information should be:
- accurate;
- accessible;
- understandable;
- proportionate;
- relevant; and
- appropriate to the audience.
Stakeholders may include:
- clients;
- families or support people where appropriate;
- employers;
- schools;
- support workers;
- trainers;
- veterinarians;
- other health professionals;
- managers; and
- WHS representatives.
Communication should consider:
- preferred communication methods;
- disability-related communication requirements;
- literacy;
- language;
- cultural considerations;
- cognitive accessibility; and
- consent and privacy.
Risk communication should support informed decision-making rather than use fear or exaggerated risk to obtain compliance.
Documenting Risk Decisions
Risk documentation should identify:
- the actual hazard;
- who or what may be affected;
- relevant evidence;
- likelihood and consequence where assessed;
- existing controls;
- additional controls considered;
- reasonable adjustments;
- client preferences and goals;
- animal welfare considerations;
- consultation;
- residual risk;
- decisions made;
- responsibilities;
- review requirements; and
- professional reasoning.
Avoid vague documentation such as:
- “client unsafe”;
- “handler lacks capacity”;
- “dog unsuitable”; or
- “environment inappropriate”
without explaining the specific circumstances and evidence supporting that conclusion.
Good documentation should make the reasoning process transparent.
Key Practice Principle
Effective risk management allows Occupational Therapists to balance:
- the rights and autonomy of people with disability;
- meaningful occupational participation;
- worker and community safety;
- assistance animal health and welfare;
- dignity of risk;
- positive risk-taking; and
- legal and professional responsibilities.
A competent assistance animal Occupational Therapist does not eliminate participation simply because risk exists.
Instead, they:
- identify the actual hazard;
- assess the significance of the risk;
- consider the benefits of participation;
- consult the person;
- identify reasonable adjustments;
- apply the hierarchy of controls appropriately;
- use the least-restrictive effective controls;
- protect assistance animal welfare;
- consider residual risk;
- document professional reasoning; and
- review controls as circumstances change.
The objective is not a risk-free life.
The objective is safe, ethical and meaningful participation through proportionate, evidence-informed risk management.