Incorporating Equity Into Workplace Health and Safety
Accommodations for Disabled Workers
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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,
OSHA’s policy is: • if an employee can perform their job functions in a manner which does not pose a safety hazard to themselves or others, the fact they have a disability is irrelevant, • to strive for working conditions which will safeguard the safety and health of all workers, including those with special needs and limitations.
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.
Being disabled is the only affinity group that anyone and everyone might join.
An ergonomic assessment for blind or visually impaired employees will be affected by the type of accommodation used. For example, if the employee relies on software that converts printed or computer text to an auditory output, the routine guidance for monitor height and distance would not apply. However, for an employee who uses a magnifier that attaches to the computer monitor, the guidelines for monitor height and distance would apply.
A workstation assessment can help an ill or injured worker return to work sooner, benefiting both the company and the worker. A worker recovering from shoulder surgery may benefit from replacing the traditional mouse—which is usually located to the side of the computer keyboard, forcing the shoulder away from the body—with a pointer, such as a touchpad or roller positioned behind the keyboard, which keeps the shoulder mid-body.
Back injuries, which can be a chronic condition, are increasingly common. This trend is likely to continue given the aging of the workforce: according to the Bureau of Labor Statistics, between 2000 and 2016 the portion of the United States labor force aged 25 to 54 years fell from 71.1 percent to 64.2 percent, while the portion aged 55 and up rose from 13.1 percent to 22.4 percent. For office workers with a back injury, sitting for lengthy periods can aggravate the problem, increasing stress on the lumbar spine. Providing a sit-stand desk that permits working from both sitting and standing postures might bring the employee back sooner as well as mitigate the risk of re-injury. For more information about sit-stand workstations, read “Ups and Downs” in the May 2017 Synergist.
For a non-office example of a workstation assessment, consider a shop technician who desires to return to work while still on crutches during recovery from a foot amputation. The existing shop layout requires the technician to stand while working and to reach for parts and tools stored at floor level. Moving these items to the top drawers of the work bench eliminates the need for the technician to bend over, and adding a laboratory-height chair eliminates the need for constant standing.
Onboarding a New Employee IHs can help onboard a new worker with a disability or manage the return of an employee whose health situation has changed. The earlier an organization provides an accommodation for these workers, the lower the costs. Fire safety and emergency evacuation should be evaluated particularly in cases of mobility limitations that require the use of a wheelchair or a walker, or sensory limitations such as hearing or vision impairments. Note that emergency planning includes not just evacuating the office building in case of a fire but also evacuating the area due to an impending weather event such as heavy rain or snow.
There will be subtleties in limitations that are not immediately obvious. For example, as discussed in a 2016 paper published in American Annals of the Deaf, deaf and hard-of-hearing (DHH) workers report fatigue and stress due to the concentration and hypervigilance needed to compensate for their hearing loss. A no-cost accommodation is rearranging furniture so DHH workers are aware when someone enters their workstation. According to a brochure published by the Cornell University Industrial and Labor Relations School, accommodations for employees with epilepsy frequently involve procedural considerations rather than physical changes to the work site or purchases of equipment. The employee will have the best understanding of symptoms, warning signs, and the appropriate response in case of a seizure. As noted by the U.K. Health and Safety Executive, administrative practices such as implementing routine work hours rather than rotating shifts may mitigate the risk of seizures.
A checklist for onboarding a new employee or for reboarding an employee whose health situation has changed should include the following areas: • Work area assessment: Using the specialized knowledge of IHs, assess the individual’s workstation including the furniture, equipment, and configuration. Space may be needed for special equipment, such as magnifiers for workers with low-vision needs, additional lighting, or headsets to block out ambient noise. Also evaluate access around the workstation such as aisles and elevators. Knowledge of ergonomics, hearing protection, and illumination provides a strong background for helping managers as well as employees.
• Daily operations: The layout of the workplace is not static. As new jobs come along and workplaces are remodeled, it is tempting to temporarily block accessways. Employees with mobility or sensory limitations should be kept up to date on both temporary and permanent access changes.
• Emergency planning: Work with the employee to plan in advance for any special evacuation provisions, such as providing a visual alarm, determining a rescue location, or assigning an evacuation buddy. The plan should include arrangements for medical emergencies. The employee is the person who best understands his or her limitations.
• Periodic review and assessment: Incorporate steps into routine health and safety walk-throughs to check that the existing accommodations are effective. Watch for employees who might be “self-accommodating”—that is, implementing homemade solutions that are frequently suboptimal.
Operational Environment Simple changes to the physical workplace as well as behavioral changes can serve as accommodations. For meetings or presentations, rearrange furniture in meeting rooms so DHH workers can comfortably see each speaker. The paper in Ursidae recommends that attendees at meetings face the other attendees, ensuring their mouths are visible when speaking. Remind attendees not to talk while facing the display screen. If minutes or ideas are being recorded on a flip chart or electronic display, have the scribe read them aloud so visually impaired employees will know what is written. Minimize ambient noise by keeping meetings focused on one discussion at a time, not several at once. Take side conversations outside of the room.
The incorporation of closed captioning for videos used in websites and training presentations is an example of an electronic accessibility accommodation. Another is attaching “alternative image text” to images such as scans, photos, or graphs in electronic materials. When visually impaired or blind employees use screen readers, this text can be converted to the audio stream. The alternative image text should describe the photo or graph as well as the desired point to be made and remembered. Distributing presentation and meeting materials either in hard copy or electronic form is another inclusive practice that benefits both the hearing and the visually impaired.
Effective training, whether instructor-led or computer-based, must be accessible to those with disabilities. According to a 2009 paper published in the American Journal of Public Health, learning disabilities include a group of information-processing problems that can manifest as difficulties with reading, math, memory, abstract reasoning, and spatial orientation. Workers with certain learning disabilities benefit from simultaneously reading and hearing the information presented. In the case of CBT, presenters can promote comprehension by providing an audio track along with a transcript of their presentation. For instructor-led training, provide a printed or electronic copy of the material for use during the course.
The checklists used for routine facility inspections can incorporate accessibility factors, particularly for common areas such as hallways, entryways, and restrooms. Inspections also provide the opportunity to look for self-accommodations. Employees may be hesitant to disclose a disability and the need for an accommodation out of fear of resentment over the expense.
INCORPORATE INCLUSION Being disabled is the only affinity group that anyone and everyone might join, either temporarily or permanently. Inclusive practices fit well with the classic industrial hygiene framework and provide value to the company: • anticipate: participate in onboarding a new employee with a disability or reboarding one whose health situation has changed • recognize: assess jobs and workstations to accommodate both permanent and temporary disabilities • evaluate: during regular inspections, add a review of existing, inadequate, or needed accommodations, and watch out for self-accommodations • control: use inclusive practices during meetings, presentations, and training • confirm: incorporate inclusion in routine reviews of employee and manager satisfaction with the company’s health and safety program
Per surveys conducted by the Job Accommodation Network for the U.S. Department of Labor, 56 percent of employers reported that accommodations cost nothing, while the rest reported a typical cost of $500. According to the survey responses, the direct benefits of effective accommodations include retention of a valued employee, increases in productivity and attendance, improved interactions with coworkers, and better overall morale. Successful accommodations contribute to the company’s bottom line, providing for a diverse workforce by enabling productivity for each employee regardless of individual limitations.
PENNEY M. STANCH, CIH, CSP, CPE, is a principal industrial hygienist with Baer Engineering and Environmental Consulting Inc. in Austin, Texas.
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American Annals of the Deaf: “Employment and Adults Who Are Deaf or Hard of Hearing: Current Status and Experiences of Barriers, Accommodations, and Stress in the Workplace” (July 2016).
American Journal of Public Health: “Work Injury Risk Among Young People with Learning Disabilities and Attention-Deficit/Hyperactivity Disorder in Canada” (August 2009).
CDC: “Disability Inclusion” (September 2020).
Cornell University: “Working Effectively with Employees Who Have Epilepsy” (January 2011).
Job Accommodation Network: “Workplace Accommodations: Low Cost, High Impact” (October 2020).
Journal of Business and Psychology: “The Participation of People with Disabilities in the Workplace Across the Employment Cycle: Employer Concerns and Research Evidence” (PDF, January 2019).
OSHA: Standard Interpretations: Employment of Individuals with Disabilities (August 1997).
The Synergist: “How to Make Online Information Disability-Friendly: The Basics of Section 508 Compliance” (December 2020).
The Synergist: “Ups and Downs: The Benefits and Challenges of Sit-Stand Workstations” (May 2017).
U.K. Health and Safety Executive: “Health and Safety for Disabled People and Their Employers” (PDF, February 2015).
Ursidae: The Undergraduate Research Journal at the University of Northern Colorado: “Employees Who are Deaf or Hard of Hearing: Perceptions of Workplace Accommodations” (April 2019).
U.S. Bureau of Labor Statistics: “Older Workers: Labor Force Trends and Career Options” (May 2017).
U.S. Department of Justice: “A Guide to Disability Rights Laws” (February 2020).
Web Development Group: “508 Compliance: Making Your Website More Accessible” (September 2017).