The classic decision-making framework for hazard assessment and exposure management calls for industrial hygienists to anticipate, recognize, evaluate, control, and confirm. This same framework can be used to incorporate equity into environmental health program management through inclusion of disabled employees. According to CDC, greater than one quarter of adults in the United States live with some sort of disability. Reasonable accommodations for disabilities remove workplace barriers, but sometimes neither the disabilities nor the barriers are obvious. Mobility limitations and sensory impairments tend to be noticeable due to the presence of assistive technology such as wheelchairs, hearing aids, and white canes. Other disabilities such as diabetes, rheumatoid arthritis, and learning disabilities include a wide range of physical and psychological conditions that may not have visible manifestations. In addition, as noted in a paper published in 2019 by the Journal of Business and Psychology, disabilities and their symptoms will change over an employee’s career.

REGULATIONS The Americans with Disabilities Act (ADA), which was signed into law in 1990, defines an individual with a disability as “a person who has a physical or mental impairment that substantially limits one or more major life activities, a person who has a history or record of such an impairment, or a person who is perceived by others as having such an impairment.” Title I of the ADA requires employers with 15 or more employees to provide qualified individuals with disabilities equal opportunity for employment, including “reasonable accommodation to the known physical or mental limitations of otherwise qualified individuals with disabilities, unless it results in undue hardship.” Title II (state and local governments) and Title III (public accommodations and commercial facilities) provide requirements for accessible design so that products, services, and facilities can be independently used by people with a variety of disabilities. Still in force today, Section 508 of the Rehabilitation Act from 1973 mandates accessibility for electronic and information technology of the federal government, contractors, and recipients of federal funds. Today, such electronic information includes websites, databases, computer-based training (CBT), and virtual meeting tools. More information about Section 508 appears in the December 2020 Synergist. According to OSHA, which has no regulation specifically regarding the employment of disabled employees, the ADA governs employers’ obligations. Per the agency’s 1997 standard interpretation memorandum, ACCOMMODATIONS A 2019 paper published in Ursidae: The Undergraduate Research Journal at the University of Northern Colorado observes that just as industrial hygiene incorporates different types of controls to mitigate hazards, different types of accommodations are available for disabilities, including environmental, technological, and administrative. For example, in the context of emergency response planning, environmental accommodations for a mobility disability are doorways and hallways wide enough to provide adequate emergency egress for wheelchairs. A technological accommodation in a building with traditional audible fire alarms would be the addition of a flashing light in the office or cubicle of a deaf employee to ensure he or she is notified of a fire. An administrative accommodation would be assigning each disabled employee an evacuation buddy and backup in the organization’s emergency response plan and updating the plan whenever the worker’s job environment changes. As health and safety professionals, industrial hygienists are trained to understand emergency evacuation requirements and ergonomics principles. This training prepares IHs to protect the health and safety of each worker, regardless of ability or disability. IHs help remove barriers to, and develop accommodations for, a disabled worker’s job by assessing workplace environmental factors such as noise level, illumination, and the physical layout of a workstation. Accessibility can be readily incorporated into that classic framework. Discussed below are three processes in which IHs should be primed to offer accommodation solutions: assessing workstations, onboarding new employees with disabilities, and improving the operational environment. Workstation Assessments One important part of a job hazard analysis is reviewing the physical workstation, whether during a routine inspection or as the result of a request for assessment. In the case of a paraplegic worker in a wheelchair, providing desk clearance for knees may be as simple as removing the middle pencil drawer. For a worker with a hunched back from Scheuermann’s kyphosis who may have difficulty looking straight ahead, removing the computer monitor from its mount and placing it flat on the desk can allow the worker to view it more comfortably and minimize the risk of developing a musculoskeletal disorder.