The Importance of Vision Requirements
Occupational vision requirements are distinguished from
"essential job functions" in that an essential job function might
be "recognize inmates in the yard from the tower," while an
occupational vision requirement might be described as "applicants
must possess 20/20 far visual acuity." A bona fide occupational
vision requirement is one that is based on a demonstration that
20/20 visual acuity is actually needed to recognize inmates
in the yard from the tower.
Correctional officers directly supervise and control the most
violent and dangerous individuals who have been removed from
society. It is, therefore, surprising that the vision
requirements necessary to perform this critical public safety job
are rarely examined or scrutinized for job-relatedness. One
result of this is that individual correctional agencies have
difficulty justifying their vision requirements to persons
seeking employment with visual disorders or to judges and juries
in disability discrimination lawsuits.
But there are other ramifications from the use of non-job-related
vision requirements that are even more detrimental to
correctional work than the occasional ADA lawsuit. This is due
to the fact that many correctional agencies already hire persons
with vision disabilities so severe, that they cannot perform the
essential functions of the job now.
Correctional Tasks and Visual Abilities
Whether a person with a vision defect can perform the essential
functions of the job of a correctional officer is largely a
question of job performance and not a medical
issue per se. Once a diagnosis has been made, attention needs to
focus on how the vision deficiency will impact on job
performance. In other words, the central question that must be
addressed is, "At what level of visual decrement would a
correctional officer become unable to perform the critical visual
tasks required by the job in a safe and efficient manner?" In
order to respond to this question, several preliminary issues
must be considered including a determination of the critical
vision tasks that correctional officers are required to perform.
To determine this, the visual demands of the job must be
identified and characterized.
Many techniques exists to elicit essential job functions. At a
minimum, the technique must cover all of the primary vision
abilities and describe the job tasks in sufficient detail. The
analysis must provide reliable measures of task importance,
consequence of failed performance, frequency, and duration of
task performance. Once the critical tasks have been identified,
they need to be linked to basic abilities of the visual system.
These abilities and a sample of representative correctional tasks
are show below:
Sample Correctional Officer Vision Tasks
Peripheral Vision is the ability to perceive objects,
movement or sharp contrasts toward the edges of the visual field.
Peripheral vision is the ability to see these contrasts and gross
movements such as in noticing if a car is coming at you from the
extreme right or extreme left as you cross the street.
- While in a room with 70-100 inmates, see when a
prisoner is suddenly moving rapidly towards you
from the extreme left or right.
- See what is going on to your left when inmates
have set up a diversion to attract your attention
to the right.
- While at an intersection, see vehicles that are
entering the intersection from left to right and
right to left.
Near Visual Acuity is the ability to see clearly
objects and close surroundings that are 36 inches or closer.
Some tasks that require this ability are being able to see
the wear marks on a machine part or repair a watch.
- Read the name on a property tag.
- Match the fingerprints during release process.
- Read prisoner ID bracelet to confirm identity.
Far Visual Acuity is the ability to see clearly objects and
surroundings that are six feet or further away. Some tasks that
require this ability are seeing other vehicles while driving or
seeing approaching cars while flagging.
- Recognize inmates involved in a fight from the
tower.
- Recognize when an unknown individual has entered a
housing unit.
- Perform all events at the firearms qualifications
course.
Visual Color Discrimination is the ability to tell the
difference between shades of one color or the difference between
two or more colors. This ability includes being able to detect
differences in the brightness of colors. Some tasks that require
this ability are being able to distinguish between a red light
and a green light or match paint colors.
- While completing an inmate property inventory
form, identify clothing by color.
- Recognize and identify color of eyes and hair of
inmates.
- Identify inmate classification by looking at color
coded wrist bands.
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The tasks listed above are not the most critical tasks for any
corrections department or officer. The list merely shows sample
tasks that some correctional officers might perform in specific
circumstances in particular institutions.
If environmental factors are present such as smoke filled rooms,
high winds, fog, rain, snow, bright sunlight, dimly lit rooms,
twilight, or complete darkness, this information must be
documented as well. One checklist useful further characterize
visual tasks in such an analysis is shown below:
Partial Listing of Factors for Analysis of Workplace Visual
Skills
|
Working Distance |
Size of Detail |
|
Working Position |
Working Area |
|
Head Movements |
Object Movement |
|
Potential Dangers |
Binocular Vision |
|
Color Vision |
Near Acuity |
|
Far Acuity |
Peripheral Vision |
|
Visibility |
Lamination |
|
Type of Lighting |
Ocular Hazards |
|
Eye Protection |
Other Hazards |
Adapted from R.V. North (1993). Work and the
Eye. Oxford University Press
Correction by Means of Contact Lenses or
Glasses
Corrected and uncorrected vision requirements are common in
public safety occupations. This is based on the observation
that there are critical tasks that rely on vision after one's
contact lenses have been knocked out or after one's glasses have
been knocked off. It has been suggested that all corrected and
uncorrected vision requirements should be the same since optimal
performance is always required of a correctional officer. On the
other hand, corrected and uncorrected vision requirements need to
be considered in the context of the individual situation in which
loss of correction is likely to occur.
For example, it may require 20/40 visual acuity to safely
drive a car. And yet, one would not expect a corrections officer
- or anyone else - to have their glasses knocked off while
driving. Correctional officers may observe inmates from towers.
But what is the likelihood of losing one's glasses while
performing this activity? Uncorrected acuity requirements must
take into account the probability of having to perform the task
in a visually uncorrected state.
Type of correction must be considered. The probability of
losing glasses or hard contact lenses is much greater than for
soft contact lens. All of these factors must be considered in
relation to the performance of specific job tasks identified as
critical.
Another issue that needs to be addressed is that of goggles and
safety straps for persons with severe visual defects. In those
correctional settings where the inmates are nonviolent and
compliant, goggles and headbands for the visually disabled
correctional officer might be an acceptable form of reasonable
accommodation. In other settings were the inmates are
aggressive, such accommodations are unsafe since these straps can
be used to strangle the correctional officer during a physical
altercation.
Establishing Appropriate Acuity Requirements
Some corrections and many police departments have set their
uncorrected visual acuity standard at a level of 20/200, a level
defined as legal blindness by the Social Security Administration.
A person viewing with 20/200 acuity cannot recognize a face
beyond an arm's length, cannot determine if a person has a weapon
(or no weapon) at 20 feet in bright light, and cannot reliably see
a knife in the hand of an inmate in a dimly lit prison dorm room
from a distance of five feet. Having a 20/200 visual acuity
requirement is, for all practical purposes, the same as having no
vision requirement at all, since such persons cannot reliably
perform any critical visual task at all.
In those communities where criminal suspects and prison inmates
are nonviolent, compliant and cooperative, these vision
requirements may be entirely appropriate since the probability of
having one's glasses knocked off is extremely low. In other
locations where inmates or prisoners may be aggressive, hostile
or violent these vision requirements would, obviously, need to be
more stringent in order to be ensure officer safety.
In a correctional setting with combative or hostile individuals
there are critical tasks that a corrections officer might be
required to perform after having his or her glasses knocked off.
These tasks might include determining which inmate is leading an
assault against other inmates or which inmate has a knife or
other weapon in a day room. These critical tasks cannot be
reliably performed with vision worse than 20/20. At 20/40 a
considerable amount of error will occur and beyond that
performance is completely degraded.
The key to devising bona fide occupational vision qualifications
is job-relatedness. A visual skills analysis within the
institution, taking into account the level of potential violence
and other factors and environmental hazards, is the starting
point in evaluating the critical vision tasks necessary for
successful job performance.
Establishing Appropriate Peripheral Vision
Requirements
Peripheral vision in public safety occupations has been the
subject of much litigation in over the past year. In Pontiac,
MI, the EEOC forced the City of Pontiac to hire an individual for
a firefighting job who had monocular vision. In Omaha, Nebraska
a jury ordered the city to hire a one-eyed individual to be a
police officer, in part, because the job description did not
specifically state that peripheral vision was a job requirement
and because the city failed to link the peripheral vision
requirement to the job or provide convincing medical evidence to
support its position. In 1999 the cities of Aurora (CO), Kansas City
(MO), Rock Island (IL) and Los Angeles became involved in
similar ADA litigation over the employment of persons with only
one functioning eye for the job of police officer. Until the U.S. Supreme Court reduced the coverage of the ADA in three landmark decisions on June 22, 1999 (See
U.S. Supreme Court Decisions), the EEOC appeared determined to eliminate occupational vision requirements
in much the same way it crusaded against height and weight
requirements in the 1970's.
Do correctional officers need peripheral vision? According to
Tammy Douglas-Schatz, Riverside County Sheriff's Personnel
Officer, "When you are supervising in the pods or in a recreation
yard with the prisoners -- you are out in the open with them.
You really have to rely on your peripheral vision in order to
maintain your safety." Yet in 1992, a nationwide survey of
state departments of corrections found only five states to even
have a peripheral vision requirement. Most state agencies have
made no attempt to determine whether two functioning eyes are
needed in correctional work and many states left the employment
decision up to the industrial clinic performing the preplacement
medical examinations.
Interestingly, a significant amount of research has been
conducted that establishes the need for two functioning eyes in
corrections officers and demonstrates the degree of impaired job
performance by persons without full visual fields. For example,
in one study a work sample exercise was constructed to measure
the level of peripheral vision needed to supervise inmates in a
day room. Several events were constructed including 1) passing a
weapon from one person to another across a table; 2) passing a
pack of cigarettes across a table; 3) one inmate taking a swing
at another; 4) two inmates doing a "high five" across a table;
and 5) no event at all. The simulation procedure involved the
use of special goggles which allowed the visual fields of the
subjects to be narrowed to various levels. The results were
unequivocal. The drop-off in acceptable performance after 120
degrees was severe. This research resulted in the establishment
of a bona fide occupational requirement for peripheral vision for
correctional officers required to supervise inmates.
Limitations of visual fields affect more than the just limiting
the available sensory information needed to supervise inmates or
provide an early warning. Research carried out for the military
demonstrated a strong relationship between full visual fields and
the ability to maintain one's body in an upright position when
forces may be exerted against the body causing instability.
These experiments determined that individuals were most steady
when confronted with a full and richly articulated field and they
became progressively more unsteady as the field of view
diminished. Individual differences emerged from these studies.
Some persons exhibited a greater ability to maintain their
balance than others in conditions of reduced visual field.
However, performance for all subjects was markedly degraded as
the visual fields narrowed.
Based on the research described above, applicants for
correctional officer with limited visual fields will have more
difficulty maintaining their balance when in an unstable position
or when forces are attempting to knock them off balance. Job
analysis literature of correctional officers indicates that
attacks by inmates on correctional officers do occur and that the
maintenance of body balance, stability and control during these
attacks is considered critical.
Preemployment physical ability tests for correctional officers
typically overlook balance and equilibrium abilities in favor of
the more the traditional assessment areas of strength,
flexibility and endurance. This is unfortunate. It is possible
that a functional balance test could be validated for
correctional officers which would serve several purposes
including the testing of persons with visual field defects,
vertigo, acrophobia and other conditions relating to balance and
instability problems. Such an assessment could be made during
the preplacement medical examination or as an additional test in
a fitness for duty or functional capacity evaluation.
While perimetry measures the extent of an individual's visual
field loss, these measures alone do not provide any information
about the applicant's potential for successful or impaired
performance once placed on the job. Perhaps tests, such as the
stabilimeter or others that objectively demonstrate poor or
degraded performance of the functionally impaired applicant, will
be more prevalent in the future. Some have suggested
incorporating critical vision and even critical hearing tasks
into the physical performance test for initial correctional
officer selection.
Establishing Appropriate Color Vision
Requirements
Establishing a color vision requirement involves the
determination of the level of color vision necessary to perform
color vision tasks that correctional officers must perform.
Color vision tasks must be carefully selected since many items
can be identified without reference to color at all. For
example, a warning light might be red. However, if it is known
by all that the light is a warning light, it matters little that
this light might appear "dark" to some and "red" to others.
Tasks should be selected that must be performed accurately and
quickly. According to Chief Deputy Dotts of the Riverside County
Sheriff's Department, "We have so many people coming into and
going out of our jails that our correctional officers must rely
on the color coded ID bracelets and clothing." In conditions
where scores of inmates must transported and returned to the
correct location efficiently, color classification schemes with
bracelets and clothing are indispensable.
Persons who work in groups are less likely to need superior or
normal color vision since there are other nearby workers who can
be consulted in a color confusion situation. Tasks should be
selected that rely on color and cannot be altered. For example
if red fire extinguishers are used for one purpose and orange
fire extinguishers are used for another, there must be some
legitimate reason why the colors cannot be changed and why the
purpose of the fire extinguisher cannot be clearly labeled.
The color vision task must be one with a serious consequence if
error occurs. Correctional Lieutenant Nancy Kennon, of the
Riverside County Sheriff's Department, notes that the
"confirmation of hair, eyes and skin color of prisoners is
extremely important to ensure that the right person is being
released back into the community." An error in color matching
during the release phase could have catastrophic
consequences.
Having established a set of critical color vision tasks, it is
next necessary to determine whether persons with the several
types of color vision deficiency can perform the task.
About eight percent of the U.S. male population has some form
color vision deficiency. About half these individuals have color
defects that are so mild as to have no practical impact on the
performance of basic color naming tasks. Indeed, persons with
the most minor of color vision defects can easily name and
identify all of the colors typically encountered by corrections
officers.
Color vision plate tests, in which correctional applicants are
asked to name numerals found in series of round colored fields,
represent the kind of test most often used to discriminate
against persons with mild color defects that have no functional
significance. The use of plate tests and job requirements that
specify "normal color vision" exclude these job applicants
without cause. Fortunately, there are standardized, reliable and
inexpensive color vision tests that can differentiate between
persons who have severe problems in naming or matching colors and
persons who function the same as normals on everyday color tasks.
The use of such tests can ensure that only those persons who can
perform the essential color vision tasks are selected and that
those with severe deficiencies are rejected.
The rejection of qualified persons imposes a cost on correctional
agencies since all of the recruitment, testing, and selection
costs are lost and the qualified individual is rejected for
erroneous reasons. Moving down the hiring list for selection
also imposes a cost due to the selection of a lesser qualified
individual to the extent that placement on the list is reflective
of potential job performance.
Borrowing Vision Requirements
One flawed procedure is the establishment of vision requirements
through borrowing from other agencies. Over the past five years
more and more correctional and police departments have begun to
apply vision requirements established for firefighters by the
National Fire Protection Association. These vision requirements
(20/30 corrected; 20/100 uncorrected) were based on an empirical
vision study of firefighters conducted in Montgomery County,
Maryland in 1989. The original study examined corrections and
police vision research and concluded that law enforcement vision
requirements could not be transported to the fire service for a
variety of reasons including the fact that firefighters do not
have to make shoot no-shoot decisions with lethal weapons. In
fact, persons who must make shoot-no shoot decisions or rapidly
identify other serious threats to personal safety, require a much
higher level of vision than 20/30 corrected and 20/100
uncorrected acuity levels set for firefighters. Borrowing vision
standards led one state recently to adopt
more stringent uncorrected vision standards for
firefighters than for police officers despite the fact that
firefighters work in groups, do not carry guns, wear protective
head and eye gear and are much less likely to encounter hostile
individuals than police officers.
Relying on physician examiners or local industrial clinics to
ascertain whether visually disabled job applicants can perform
the visual functions of the job is ineffectual as these
professionals rely and depend on the agency to supply them with
the medical and physical requirements of the job. Without
clearly written medical and physical requirements specified by
the agency, job applicants almost never "fail" preplacement
medical examinations regardless of the job.
Conclusion
In 1992, the passage of the ADA led many corrections departments
to review their job descriptions and rewrite job tasks in terms
of "essential" or "marginal" functions. It is now being
recognized that the listing of essential functions without a
linkage to occupational requirements is incomplete at best. In
other words, while "supervising inmates" may be an essential job
function, the level of vision that is necessary to effectively
supervise inmates is the information that is truly needed to
establish a vision requirement.
Occupational vision requirements for correctional officers cannot
be borrowed from fire or police departments where often the
origin of the standards are unknown. The ramifications of
ineffective visual screening and visual requirements have two
significant and detrimental effects on corrections departments.
These include the hiring of persons with visual defects (such as
legal blindness) so severe as to curtail effective job
performance and the exclusion of qualified
persons for jobs they can successfully perform (such as in the
case of persons with mild color vision deficiency).
Previously,
the potential for ADA litigation caused many departments to
review job descriptions and describe essential functions or job
tasks. Now some departments are focusing-in on what abilities, and what level of these abilities, are necessary to perform essential vision tasks within their own
institutions.
© 2008 MED-TOX HEALTH SERVICES