When an employee tells your practice she is pregnant, the law points you toward accommodation, not exclusion.
If you have 15 or more employees, the Pregnant Workers Fairness Act requires reasonable accommodations for pregnancy-related limitations, and a blanket bar on radiology or anesthesia work for her own protection is the kind of policy the Supreme Court struck down in 1991.
The hazards are manageable: a declared-pregnancy dose limit, gas scavenging, and lactation breaks.
Rules vary by state and change
This guide explains federal rules and the state rules it names, as of the date above.
Employment law and veterinary practice rules differ by state and are revised often, so confirm current requirements with your state veterinary board, labor agency or employment counsel before you act on them.
It is general information, not legal advice.
PWFA: reasonable accommodations at 15 or more employees
The Pregnant Workers Fairness Act (PWFA) applies to private employers with 15 or more employees.
It took effect June 27, 2023, and the EEOC's final regulation took effect June 18, 2024.
For a practice at or above that headcount, the law requires covered employers to reasonably accommodate known limitations related to pregnancy, childbirth or related medical conditions — unless a specific accommodation would impose an undue hardship, which the law defines as significant difficulty or expense.
In a clinic those limitations are concrete: a technician who can no longer hold large dogs for radiographs, an assistant who can't lift the heavy cattery casework, a receptionist who needs a stool and more frequent breaks, a kennel attendant who needs the schedule adjusted on deep-cleaning days.
The conversation is about those specific limitations and what would let her keep working — not about pregnancy in the abstract.
Two rules bound your side of the conversation.
You may not require her to take leave, paid or unpaid, if another reasonable accommodation can be provided — so "just stay home until the baby comes" is not a compliant default when reassigning radiograph restraint or anesthesia monitoring would work.
And you may not require her to accept an accommodation other than one arrived at through the interactive process: sit down with her, ask what the limitations are, and build the arrangement together instead of handing her a decision.
Put the process on paper as you go.
After each conversation, send her a short note recording what she flagged, what you offered, and what you agreed to try — the interactive process is what the statute describes, and a written trail keeps a schedule change six weeks later from quietly becoming the accommodation she never agreed to.
If a requested accommodation truly won't work in your practice, say why in the same note and offer the closest alternative that would.
You can't exclude a pregnant employee from duties "for her own protection"
Benching a pregnant technician from radiology and anesthesia feels protective, and it is the exact move the Supreme Court rejected.
In UAW v. Johnson Controls (1991), the Court held that Title VII, as amended by the Pregnancy Discrimination Act, bars employer fetal-protection policies.
Its words are worth reading plainly: decisions about the welfare of future children must be left to the parents who conceive, bear, support, and raise them rather than to the employers who hire those parents.
Title VII's pregnancy protections reach employers with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.
Within that coverage, a blanket policy — no pregnant staff in radiology, none inducing anesthesia, none handling cats — treats pregnancy itself as the disqualifier, which is the pattern the Court barred.
The workable alternative keeps her in the decision.
Give her the actual exposure information for each duty, work through the accommodations she asks for, and let her weigh the options with her prenatal care provider.
That is also where the PWFA pushes a practice with 15 or more employees: accommodation by default, exclusion only by her choice.
Radiation: declared pregnancy and the fetal dose limit
Under NRC rules, the dose to the embryo/fetus from a declared pregnant woman's occupational exposure must not exceed 0.5 rem (5 mSv) over the entire pregnancy.
The limit attaches to a "declared pregnant woman," and the declaration is hers: it depends on her voluntarily declaring the pregnancy in writing.
Until she declares, the fetal dose limit isn't triggered — the trigger is a note to whoever runs your radiation program, not a visible bump or break-room gossip.
Who regulates your machine decides which exact rule applies.
X-ray machines are regulated by the states, not the NRC — NRC rules cover radioactive materials — so the dose limits for your radiology room come from your state radiation control program.
In California, the state's radiation regulations incorporate the NRC's 10 CFR Part 20 standards (20.1001–20.2402) by reference, and the listed exceptions do not include the embryo/fetus limit in 20.1208.
Only California was verified for this guide, so confirm the rule that binds your practice with your state radiation control program.
The practice-wide system around the machine — facility registration, the radiation safety officer, dosimetry, operator training — is its own compliance project, and we walk through it in radiation safety and OSHA.
The pregnancy-specific additions are narrow: her written declaration on file when she chooses to give it, monitoring handled the way your state program directs, and an informed choice about restraint and positioning work instead of an automatic removal from radiology.
Waste anesthetic gases and other drug hazards
OSHA names veterinary clinics directly on this one: staff in hospitals, operating rooms, dental offices and veterinary clinics are potentially exposed to waste anesthetic gases and at risk of occupational illness, with possible effects the agency lists including miscarriages and birth defects.
There is no OSHA standard specifically addressing waste anesthetic gases — what exists is guidance, and it aims at how the gases are captured rather than at who works the room.
Two numbers from NIOSH give you a target.
NIOSH recommends that no worker be exposed at ceiling concentrations greater than 2 ppm of any halogenated anesthetic agent — isoflurane, for example — over a sampling period not to exceed one hour.
When nitrous oxide is used as the sole inhaled anesthetic agent, the NIOSH recommendation is 25 ppm measured as a time-weighted average.
Note what those are: recommendations, not enforceable limits, because OSHA has none for these gases.
Treat them as the working target for your own program.
The control OSHA points to is scavenging: the basic principles of scavenging used to capture excess anesthetic gases in hospital surgical suites are appropriate for application in veterinary anesthesia.
Practical version — confirm every anesthetic machine actually has a working scavenge circuit, fix the leaking fittings and worn cuffs that let gas pool where people breathe, and keep induction areas ventilated.
If she would rather step back from induction and monitoring while the pregnancy proceeds, that request runs through the same PWFA interactive process above; the scavenge work is what you do for the whole team either way.
Drugs beyond the anesthetic gases raise separate questions — chemotherapeutics and other hazardous drugs in oncology work among them.
Exposure rules for those weren't verified for this guide, so don't fold them into these conclusions: route them to your workplace safety regulator or an industrial hygienist who can look at your actual protocol.
Zoonoses: toxoplasmosis and pregnancy
CDC lists pregnant women as a group at risk from toxoplasmosis, and warns that infants born to mothers newly infected with Toxoplasma gondii during or just before pregnancy are at risk of severe disease.
The parasite spreads to people through contact with cat feces or contaminated soil that contains Toxoplasma.
In a veterinary practice the exposure map is specific: litter pans, feline ward cleaning, and the soil tracked into outdoor runs.
None of that is grounds for moving her off cats against her wishes: a blanket no-cats rule removes her because she is pregnant, which is the fetal-protection pattern the Court barred in Johnson Controls.
The baseline is hygiene: gloves for litter and fecal-soil work, handwashing, and the clinic's ordinary sanitation.
If she would rather hand off litter duty for the length of the pregnancy, that is a straightforward accommodation request to grant — her call to make, your scheduling fix to arrange.
Other organisms come with their own pregnancy questions, and this page covers only what CDC states about toxoplasmosis.
For the rest, the answer is organism-specific: use the CDC guidance for each one, and let her prenatal care provider weigh in on any actual exposure.
PUMP Act lactation breaks and state paid leave
After the birth, the PUMP Act adds its own rights.
Under the FLSA, most nursing employees are entitled to reasonable break time and a place, other than a bathroom, that is shielded from view, to express breast milk — a right available up to one year after the child's birth.
Employers with fewer than 50 employees are exempt only if compliance would impose an undue hardship — so look at what a pumping space would actually take before reaching for the exemption, not after.
And since April 28, 2023, an employer who violates these rights is liable for legal or equitable remedies under the FLSA.
Space is the first constraint to solve in a clinic.
A private office or consult room with a door that shuts, a chair, an outlet and a small refrigerator is shielded from view and isn't a bathroom, which is what the rule requires; a bathroom never qualifies.
Block the breaks into the schedule the way you block surgery time — a nursing employee whose breaks exist only on paper isn't getting the right the law describes.
Accommodation and pump breaks are not parental leave, and paid leave is a separate, state-level question.
Three programs we verified:
| Program | What it provides |
|---|---|
| Oregon Paid Leave | Up to 12 weeks of paid leave in a 52-week period, plus up to 2 more weeks in some pregnancy situations |
| Colorado FAMLI | Up to 12 weeks of paid leave per year, with additional weeks for NICU parents and pregnancy complications |
| Washington, D.C. Paid Family Leave | Benefits began July 1, 2020; effective October 1, 2026, up to 2 weeks prenatal, 12 weeks parental and 10 weeks medical leave |
That is not an exhaustive list of states with programs — check your state labor agency for what applies where your practice operates, and how it stacks with any leave you offer.
Pregnancy accommodation is one thread in a bigger HR system; the veterinary hiring hub holds the rest of the employer guides, from offer letters through day one.
When an employee tells you she's pregnant
- Start the interactive process the same week: ask what her limitations are and write down what you discussed.
- Bring specific accommodation options — restraint swaps, anesthesia-monitoring changes, schedule shifts, seating — rather than defaulting to leave.
- Don't reassign or bench her "for her own protection"; exclusion is her decision, not a policy you can set.
- If she declares her pregnancy in writing, route it to whoever runs your radiation program and follow your state radiation control program's fetal-dose rules.
- Service the anesthetic machines: a working scavenge circuit on every machine, leaks fixed, induction areas ventilated.
- Set up a private, non-bathroom pumping space before she returns — door that shuts, chair, outlet, refrigerator.
- Check your state's paid family leave program and any notice it requires before her due date.