Toward an ADA-appropriate job analysis

TOWARD AN ADA-APPROPRIATE JOB ANALYSIS

Krystin E. Mitchell George M. Alliger

Richard Morfopoulos State University of New York-Albany

This article describes how current job analysis methods can be used to incorporate the mandates of the Americans with Disabilities Act (ADA) of (1990). First, terms in the ADA such as “qualified individuals with disabilities, ” “essential functions,” and “reasonable accommodation” are discussed in reference to their implications for job analysis. Second, survey results gathered from individuals with disabilities are presented to suggest some ways job analysis can be used to identify essential functions and reasonable accommodations. Third, some general suggestions are offered for performing an ADA-appropriate job analysis. Finally, several current job analysis techniques chosen to be representative of the field are evaluated on three criteria: (a) whether the technique has an outcome versus a process focus, (b) whether the technique identifies essential functions, and (c) whether the technique identifies potential reasonable accommodations for a particular job. The job analysis techniques evaluated include: (a) Functional Job Anal- ysis (FJA) (Fine 19881, (b) task analysis (e.g., CODAP, standard task analyses), (c) Threshold Traits Analysis (‘ITA) (Lopez et al. 1981), (d) the Posi- tion Analysis Questionnaire (PAQ) (McCormick, Jeanneret, & Mecham 1972), and (e) the Critical Incident Technique (CIT) (Flanagan 1954).

The Americans’ with Disabilities Act was passed in 1990 in an effort to fight discrimination against individuals with disabilities. Since that time, little has been written about the implications the ADA will or should have on job analysis, which is the cornerstone of nearly all personnel practices (Cascio 1991). Consequently, human resource practitioners may be uncertain how to use job analysis to meet the mandates of the ADA (19901, or even how to define vague terms in the ADA such as “essential functions” and “reasonable accommodation.” Unfortunately, these terms may eventually have to be defined in the

Direct all correspondence to: Krystin E. Mitchell, KFC, Organization and Management Development, 1441 Gardiner Lane, Louisville, KY 40213.

Human Resource Management Review, Copyright 0 1997 Volume 7, Number 1,1997, pages 5-26 by JAI Press Inc. AI1 rights of reproduction in any form reserved. IkSN:1053-4822

6 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7, NUMEER 1,1997

courtroom, as several recent court cases suggest (e.g., Chiari v. City of League City 1991).

Title I of the ADA presents unique challenges for human resource managers that differ from challenges presented by past civil rights legislation. The ADA requires that both essential functions and reasonable accommodations be identified. However, commonly used job analysis methods were developed prior to these ADA requirements, and thus may or may not meet the mandates of the ADA. Human resource managers are left to wonder if current job analysis methods are adequate, or if extensive modifications to these job analysis methods are required. We address how job analysis methods such as Functional Job Analysis (Fine 1988) and task analysis may be augmented to ensure essential functions are identified. In addition, we make suggestions for identifying potential reasonable accommodations for jobs based on these essential functions.

The overarching goal of this article is to examine job analysis practices relative to the requirements and definitions of the ADA. This article evaluates how well traditional job analysis methods meet the mandates of the ADA and suggests modifications for certain methods. These methods, however, must allow some flexibility when defining how the same outcomes can be achieved by different means by different individuals within the same job title. This “equifinality” approach accepts theo~tically what has already been supported em- pirically-namely that there is much within-job variability in job analysis results, and thus aggregating job analysis data within a job-title may mask systematic within-group variability (Alliger 1991; Harvey 1990).

The goals of this article are fourfold. First, some terms in the ADA are defined and discussed in the context of their importance to st~cturing job analysis to meet the provisions of the ADA (1990). Second, survey results gathered from individuals with varying disabilities are presented to suggest some ways job analysis could be used to identify essential functions and potential reasonable accommodations. Third, suggestions are offered for performing an ADA-appropriate job analysis. Finally, we assess the adequacy of several specific job analysis methods to identify essential functions and reasonable accommodations.

ADA TERMINOLOGY RELEVANT TO JOB ANALYSIS

To discuss the ADA and job analysis, some key terms discussed in Title I of the ADA must be defined. Relevant terms include: (a) disability, (b) qualified individual with a disability, (c) reasonable accommodation, and most importantly for job analysis, (d) essential functions.

The ADA (1990) states that a disability means: (a) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; fb) a record of such an impai~ent; or, (cf being regarded as having such an impairment. The term “qualified individual with a disability” means an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the job that such an individu-

ADA-APPROPRIATE JOB ANALYSIS 7

al holds or desires (ADA 1990). However, such an individual may be “otherwise quali~ed~-that is, qualified except that there may be some impediments hin- dering job performance under current conditions or in the typical fashion.

If it can be determined that an individual is “otherwise qualified,” the employer must then determine whether or not the individual can perform the essential functions of the job with or without “reasonable accommodation.” “Reasonable accommodation” refers to the employer’s obligation to make changes to existing facilities, job tools, schedules, work assi~ments, and so forth to enable job performance by individuals with disabilities (ADA 19901. Thus, reasonable accommodation may include: (a) providing individuals with equipment or devices (e.g., voice responsive computers), (b) switching tasks (individuals’ with disabilities switching marginal tasks with other employees), and/or fc) modifying work schedules to accommodate individuals’ with disabilities (ADA 1990). Such accommodations are “reasonable” in that they must be provided to individuals with disabilities unless the accommodation causes “un- due hardship” on an organization because it is significantly difficult or expen- sive for an organization to implement (ADA 1990).

Essential Functions

Probably the most important term for job analysis, however, is the term “essential function.” As mentioned previously, the essential functions of a job are typically not explicitly identified by standard job analysis methods. This is true because essential functions are not necessarily the same as critical tasks. Essential functions are broader than tasks in that they are outcome-, not method-, oriented. That is, essential functions specify the desired end result of an action, not how the essential functions must be performed. Therefore, in job analysis terminology, essential functions are more like “duties” than tasks. In fact, the EEOC (1991a) defines essential functions as “fundamental job duties.” For example, a task may be to type letters on a personal computer. The essential function required of the individual, however, may be to compose letters to clients. Thus, functions do not specify how the individual will compose the letter.

A blind individual may dictate letters to a tape recorder and ask another individual to type the letter. The task, typing the letter, differs from the essential function, corresponding with clients. Consequently, the process or method by which someone performs an essential function of a job may differ from individual to individual, even within the same job title. The distinction between tasks and essential functions recognizes that individuals with disabilities may achieve the same work related outcomes by very different processes than individuals without disabilities.

Essential ~u~~tio~ lde~t~~catjo~. The ADA provides guidelines for determining essential functions. A function is considered essential if: (a) the position exists to perform the function, (b) there are a limited number of other employees available to perform the function, or among whom the function can be

8 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7, NUMBER 1,1997

distributed, and (c) a function is highly specialized, and the person is hired for special expertise or ability to perform it (EEOC 1992, pp. 13-18).

Furthermore, the EEOC (1992) lists several sources of evidence which may be used to determine if a function is essential or only marginal to the job. These sources of evidence are as follows: (a) The employer’s judgment, (b) a written job description prepared before advertising or interviewing applicants for a job, (c) amount of time spent performing the function, (d) consequences of not perfo~ing the function, (e) work experience of people who have performed the job in the past and work experience of people who are currently performing the job, (f) terms of a collective bargaining agreement, and (g) other relevant factors such as the nature of work operation and the employer’s organizational structure (EEOC 1992, pp. 13-18).

The ADA does not require a job analysis to be conducted to determine essential functions. However, a job analysis that identifies the previously mentioned factors would clearly be useful to defend function essentiality (Brannick, Bran- nick, & Levine 1992). A brief review of past court cases pertaining to the Rehabilitation Act of 1973 and the ADA (1990) indicates that the sources of evidence for function essentiality listed in the ADA (1990) may be used separately or in combination to indicate which functions are essential. For example, in Chiari v. City of League City (1991) essential functions were identified by affidavits from the plaintiffs and a written job description. In Carlson v. Inac- om Corporation (1995), the plaintiff argued that she was an “otherwise qualified individual with a disability” even though she occasionally had to miss work due to her disability. The court ruled in her favor because she only averaged seven unscheduled absences per year, and the defendant company had not formulated or published a policy relating to unscheduled absences. Therefore, while regular and predictable attendance is essential to most jobs, the lack of unscheduled absences was not deemed to be essential. In Galloway v. The Superior Court of D. C. (1993), however, essential functions were identified by work experience of people who have previously performed the job. In this case, a blind individual wanted to be a juror, but was denied the right to be a juror due to his blindness. The rationale for this denial was that an essential function of jurors is that they must be able to see physical evidence presented in the case, as well as interpret the nonverbal communications of witnesses. However, the Superior Court of the D.C. failed to examine any studies or review any literature on the ability of blind individuals to serve on juries or the ability of these individuals to assess the credibility of witnesses. Furthermore, blind individuals in other courts have routinely been allowed to serve as jurors if the court concluded that the juror was qualified for a particular trial. For example, blind jurors have served during trials where little physical evidence is presented or if the evidence can be easily explained verbally. Moreover, “audio describers” are available as a reasonable accommodation for blind jurors. Audio describers are trained individuals who describe the physical move- ments of others and physical settings for the blind. Thus, unlike Chiari v. City of League City (19911, Galloway v. The Superior Court of D. C. 0993) used the


performance of incumbents as the primary way to identify function essentiality.

The previous studies illustrate that there is no “magic bullet” when identifying essential functions. Various pieces of information may be used alone or in combination as evidence of function essentiality. With this in mind, it seems logical to gather as much evidence as possible. Additionally, a review of the court cases based on the ADA (1990) reveals that how essential functions are identified is not contested as often as whether or not individuals with disabilities can perform particular essential functions. However, although essential function identification is generally not the primary source of controversy, it does not mean that organizations should not take a proactive stance and ensure that multiple pieces of quantitative evidence are collected to support function essentiality,

The amount of time spent performing a function may also be used as evidence of function essentiality. For example, an existing job description for a receptionist may state that filing is an essential function. However, if the receptionists in a particular organization seldom spend any time filing documents, then filing should not be considered an essential function of this job. Thus, generic descriptions such as those provided in the Dictionary of Occupa- tional Titles may not identify essential functions for specific jobs within different organizations. However, one caveat deserves mention. The amount of time spent performing a function is not always related to function essentiality. For example, a nurse may seldom administer Cardio Pulmonary Resuscitation (CPR), but having the physical ability to administer CPR if necessary may be an essential function of this position.

Overall, the most general method of assessing whether or not a function is essential or marginal is to ask the question “Will the primary purpose of the job be compromised if incumbents are not required to perform this function?” Stated differently, one has to consider the consequences of an incumbent not performing a function as evidence of function essentiality. In the context of the previous nurse example, an essential function of a nurse is to have the ability to administer life saving support such as CPR in certain situations. A nurse who does not have the physical ability to perform CPR compromises the primary mission of a nurse’s job. Therefore, all of the previously mentioned compo- nents can be used to identify essential functions. The goal is to use a job analysis method (or methods) which takes these factors into account.

SURVEY OF INDIVIDUALS WITH DISABILITIES

In an effort to better understand how organizations are currently handling issues related to the ADA, we conducted a survey of 74 working individuals with disabilities. The sample was comprised of 41 females and 33 males whose average age was 38 years old. The average tenure of these individuals was 4.8 years, and most of the sample worked in non-management positions (61%).

10 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7, NUMBER 1, 1997

Nineteen different disabilities were represented, but the three primary disabilities were: visual impairment/blindness (15%), mental illness (lo%), cerebral palsy (10%). We do not claim that the results of this survey generalize to all disabilities, or even that all potential disabilities are represented here. What the results do offer is some evidence which suggests the types of reasonable accommodations which are currently being used, how individuals with disabilities may perform their jobs differently while achieving the same outcomes, and what pieces of information are important for a job analysis to capture.

Results

One of the primary questions we posed to the individuals in our sample measured whether they believed how they performed their job differed from other “nondisabled” employees, and if so, in what ways. Fifty-four percent indicated that they felt their disability did influence how they performed their jobs. The primary differences in how this subset of individuals performed their jobs included: (a) using different computer software (14%), (b) using different equipment or devices (e.g., phone amplifiers) (16%), (c) switching marginal tasks with others to accommodate their disability (16%), and (d) taking short work breaks during the day (5%).

Forty-three percent of the sample indicated that their employers had provided reasonable accommodations. These reasonable accommodations included: (a) special equipment (e.g., phone amplifier, computers, readers for individuals with visual impairments) (18%), (b) scheduling of extra breaks or flextime (16%), (c) substituting marginal tasks with other employees (ll%), (d) office redesign (lo%), (e) computer software (lo%), and (f) increased access (10%).

One striking result of this survey was that the reasonable accommodations for individuals with disabilities did not appear to require great expense on the part of the organization. For example, individuals often indicated that they would like to be able to come in 15 minutes earlier or later to allow them to take public transportation to and from work due to their inability to drive a car. Individuals who discussed office redesign generally wanted such accommodations as having shelves lowered or their desks raised to facilitate access from a wheelchair. Still other individuals suggested that they already informally switched tasks with other employees to accommodate their disability. For example, one individual with a back injury who worked in landscaping offered to perform a larger share of lighter tasks such as pruning shrubs while other individuals were responsible for transporting heavy equipment. These examples indicate that potential reasonable accommodations could be proactively identified by a job analysis approach which clearly outlined: (a) the essential functions of the job, (b) minimal sensory, motor, and cognitive requirements necessary to perform essential functions, (c) the potential flexibility of work scheduling, (d) what tasks are potentially substitutable without interfering with essential function performance, and (e) the equipment individuals will be expected to use to perform essential functions.


One additional point is worthy of mention concerning the results of this survey. Probably the single most important piece of information gathered during this survey became apparent when we tried to classify disabilities into categories such as “invisible” versus “visible” or “mental” versus “physical.” We quickly discovered that such classification schemes masked important individual differences. It became clear that there are not only differences between the impairments created by different disabilities, but also individual differences within a particular disability. For example, an individual with Multiple Scle- rosis (MS) at a later stage of the disease will suffer far more mobility impairment than an individual with MS at an earlier stage. Thus, at an earlier stage, this disability may be considered “invisible,” whereas at a later stage this disability may be considered “visible.”

Kochar and Armstrong (1988) created a table where different disabilities were cross-referenced with various forms of sensory, motor, or cognitive impairments. For example, MS was said to impact posture, mobility, strength, vision, and mental work capacity. However, as alluded to previously, MS may only influence these factors if it is severe. Individuals in the early stages of MS may not suffer from any or only a few of these deficits. Thus, in theory, a table outlining the impairments sufFered with different disabilities may be useful to outline potential reasonable accommodations. In practice, however, the large variability between and even within disabilities makes such tables a vague starting point for human resource managers. Thus, while job analysis may be used to suggest potential reasonable accommodations for certain types of physical or mental impairments, it is not possible to make global decisions regarding reasonable accommodations for any particular disability. The final determination of reasonable accommodations for specific individuals is best done on a cease by cese basis (EEOC 1991a).

GENERAL REQUIREMENTS FOR AN ADA-APPROPRIATE JOB ANALYSIS

The survey we conducted and the EEOC (1991a) both indicate several dimensions which are important to consider when conducting a job analysis in accor- dance with the ADA. These dimensions pose questions which must be an- swered for any given job analysis approach. These questions are as follows:

1. Does the job analysis approach identify essential functions? 2. How outcome versus process oriented is the job analysis method? In other

words, does the job analysis method allow for the possibility that the same outcomes can be achieved by different means?

3. How useful is the method for identifying potential reasonable accommodations? Does the method allow identification of the degree of job flexibility (i.e., does it determine substitutability of tasks, schedule flexibility, various types of equipment which might be employed)? Also, does the method identify minimal requirements for sensory, motor, and cognitive requirements for the job?

12 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7. NUMBER 1,1997

The first issue, essential function identification, is really the primary job analysis consideration. The job analysis method chosen should provide quantitative criticality and time spent ratings for all job functions. This will help to ensure that both essential and marginal functions will be identified. Quantita- tive job analysis methods are generally more legally defensible (Harvey 19901, and thus will provide more consistent evidence for function essentiality. How- ever, many organizations conduct job analyses using qualitative approaches which produce narrative descriptions of jobs (Harvey 1990). Narrative descriptions may be obtained from public sources (e.g., Dictionary of Occupational Titles), or written by personnel administrators or employees themselves. Qual- itative approaches will not necessarily capture specific pieces of information which support which functions are essential because these descriptions vary widely in the amount of information presented and the type of information obtained.

A job analysis conducted by Brannick et al. (1992) supports the use of quantitative versus qualitative job analyses. These authors used a task analysis in an effort to identify the essential functions of pharmacy assistants. They gathered information on whether the assistants: (a) performed certain tasks, (b) how much time they spent performing the tasks, and (c> the consequences of error when performing the tasks. Additionally, Brannick et al. (1992) asked the supervisors of the pharmacy assistants: (a) how essential the task was to getting the work done, and (b) how many people were available to substitute for the individual responsible for performing the tasks if that individual failed to perform the task. They subsequently identified a list of essential tasks. A task was deemed essential if the task met one of the following four criteria: (a) the supervisors’ judgments indicated that the tasks were essential, (b) serious consequences would result if errors were made when performing the tasks, (c) no one else was available to cover the task, and (d) over 70 percent of the incumbents reported performing the task and spent an above average amount of time performing it (Brannick et al. 1992). Although Brannick et al. (1992) made no claims that their job analysis would be endorsed by the EEOC, their approach provides quantitative evidence bearing on function essentiality.

The issue of essential function identi~cation is closely tied with the second point, which is outcome versus process orientation. When an essential function is identified, the purpose of the function and the result to be accomplished should be outlined. Again, it is crucial to remember that although a function may be identi~ed as essential, often it is not essential that the function be performed in a particular way (EEOC 1991a). Thus, a job analysis method should be chosen which focuses on the outcome desired, not merely the process generally used to achieve a particular outcome.

In addition, the job analysis method should be able to proactively identify potential reasonable accommodations for various sensory, motor, or cognitive impairments. The physical abilities necessary for job performance may be identified in terms of categories such as visual, auditory, agility, strength, and endurance requirements of the job. Cognitive capacity could be identified in


terms of concentration, memory, comprehension, problem-solving, and creativity. This idea is clearly not new. Threshold Traits Analysis developed by Lopez, Kesselman, and Lopez (1981) assesses the need for just such physical and cognitive abilities. The unique aspect of the recommendation in this article, however, is that not only are minimal acceptable levels of these traits identified, but that potential reasonable accommodations for deficits in any of these abilities are also suggested. For example, the ability of a pilot to see with reasonable acuity (20/20 vision) is an ability which cannot be accommodated for an individual who is blind. However, c;;her jobs may not require such high levels of sensory acuity. A receptionist who has a hearing impairment may easily accommodate this disability by using a voice amplifier when using the telephone. Thus, a minimal level of hearing acuity may be identified in ad- vance to determine the minimal level of hearing acuity necessary to perform the essential functions of the job.

Additionally, potential reasonable accommodations for certain deficits may be identified. The list of potential reasonable accommodations need not be exhaustive, but should probably include reasonable accommodations used previously within the organization and/or reasonable accommodations used suc- cessfully in outside organizations. This analysis could also illustrate which deficits can be easily accommodated, and which deficits cannot safely be accommodated without jeopardizing the safety of the individual with a disability or other employees.

Brannick et al. (1992) discussed the feasibility of creating a table which identified the sensory and motor requirements for essential functions as they are typically done. However, they argued that this approach ignores the possibility that individuals with disabilities may achieve the same results in different ways. We agree. While obtaining such information may be important for outlining the characteristics necessary for performance of essential functions, it overlooks the possibility of equifinality. However, such a table may be useful if minimal levels of motor, sensory, and cognitive capacities are identified for each essential function. Such a table would outline which deficits could be accommodated, and which could not. Kochar and Armstrong (1988) give an example of how such a table would operate in practice. These researchers discussed an example of a paraplegic individual performing the job of a hospital messenger. The primary essential function was to transport blood samples and other specimens to laboratories throughout the hospital. Additionally, Kochar and Armstrong (1988) identified three minimal strength, mobility, and reach requirements necessary to perform the essential functions of this job. The paraplegic individual met the strength and mobility requirements, but failed to meet the minimal reach requirement necessary to push the emergen- cy call button on the elevator. However, this deficit was easily accommodated by providing the individual a stick to reach the call button. Thus, when minimal sensory, motor, and cognitive requirement for a position are outlined, an employer can assess: (1) whether the individual can perform the essential functions of the job with or without reasonable accommodation, and (2) which deficits may be accommodated and which deficits cannot.


EVALUATION OF CURRENT JOB ANALYSIS METHODS

The ADA (1990) does not state that a certain form of job analysis must be performed to identify essential functions of the job. As suggested in the previous section, different job analysis methods differ in the degree to which they identify ADA-relevant information. Specifically, these methods differ on: (a) their ability to identify essential functions, (b) the degree of outcome versus process orientation, and (c) their ability to outline potential reasonable accommodations. Therefore, each job analysis method to be examined has its strengths and weaknesses with regard to these criteria. Our goal is not to champion one method over all others, but to provide some insight into how these methods can be used alone, or in combination, to ensure ADA-relevant job analysis information is collected.

For this article, we examined five job analytic approaches on the previously mentioned criteria. However, this comparison is not exhaustive in that more job analysis approaches might have been considered. However, the five approaches we chose are representative of a wide range of available techniques. Specifically, we examined Functional Job Analysis (FJA) (Fine 19881, task analysis (e.g., CODAP, standard task analyses), Threshold Traits Analysis (TTA) (Lopez et al. 19811, Position Analysis Questionnaire (PAQ) (McCormick, Jeanneret, & Mecham 19721, and the Critical Incident Technique (CIT) (Flanagan 1954). Table 1 presents the summarized form of the comparison of these approaches in reference to the specified criteria.

Functional Job Analysis

Functional Job Analysis (FJA; Fine 1988) was developed within the U.S. Department of Labor as a way to obtain useful information on thousands of federal jobs. Although used most often within the U.S. government, FJA repre- sents a very thorough, systematic approach to job analysis.

FJA has at its root the belief that there are a number of functions which show up in various jobs. These functions can be categorized into three general categories: Data, People, and Things. Examples of functions include compar- ing, analyzing, synthesizing (Data); exchanging information, supervising, mentoring (People); handling, manipulating, precision working (Things). This emphasis on functions suggests that FJA may be particularly ADA-appropriate, a possibility we consider below.

Outcome Ofie~faf~o~. FJA explicitly outlines the outcome of a given action or what gets done as well as why the action was performed. Specifically, a function, or outcome, level description of tasks is encouraged. For example, FJA results in statements like the following which describes the job of a firefighter: “Examines walls and ceilings in order to ex~i~~~s~ seco~dury fire sources using a pike pole, charged hose line, and an axe.” FJA also stipulates how the job is performed by answering the questions: (a) “Using what tools, equipment or work aids?” and (b) “Upon what instructions?” However, the primary focus of FJA pertains to the outcome of action.

Tab

le 1

C

ompa

rison

of

Fiv

e Jo

b A

naly

sis

App

roac

hes

on A

DA

-rel

evan

t D

imen

sion

s

Out

com

e O

rient

atio

n

Ess

entia

l F

unct

ion

Evi

denc

e

Rea

sona

ble

Acc

omm

odat

ion -

_--

Sub

stitu

tabM

y S

ched

ulin

g E

quip

men

t

Fun

ctio

nal

Job

Em

phas

is i

s pl

aced

on

Ana

lysi

s w

hat

gets

don

e ra

th-

er t

han

just

on

how

on

e do

es i

t. S

peci

fi-

cally

, a

func

tion,

or

ou

tcom

e,

leve

l de

- sc

riptio

n of

tas

ks i

s en

cour

aged

. F

or e

x-

ampl

e, F

JA r

esul

t in

st

atem

ents

lik

e: “

Ex-

am

ines

wal

ls a

nd

ceili

ngs

in o

rder

to

extin

guis

h se

cond

ary

fire

sour

ces

usin

g pi

ke p

ole,

cha

rged

ho

se l

ine,

axe

” (f

unc-

tio

n ou

tcom

e ita

l- ic

ized

).

Tas

k A

naly

sis

Tas

ks m

ay o

r m

ay n

ot

be w

ritte

n to

ref

lect

ou

tcom

es.

Gen

eral

ly,

task

ana

lyse

s ar

e cr

eate

d w

ithou

t ex

- pl

icit

conc

ern

for

outc

omes

.

Iden

tifie

s th

ree

hier

- ar

chie

s of

tas

k fu

nc-

tion:

D

ata,

Peo

pfe,

T

hing

s.

Iden

tifie

s fu

nctio

n fr

eque

ncy

on a

bsol

ute

scal

e,

cons

eque

nces

of

er-

ro

r, a

nd d

iffic

ulty

. W

hile

FJA

doe

s no

t ex

plic

itly

mea

sure

fu

nctio

n es

sent

ialit

y,

it pr

ovid

es m

uch

supp

ortin

g ev

iden

ce.

FJA

job

anal

y-

sis

wor

k-

shee

t al

low

s fo

r su

bsti-

tu

tabi

lity

of

pers

onne

l by

lis

ting

rela

- tio

n to

oth

ers

in p

ositi

on

and

equi

va-

lent

pos

i- tio

ns.

Pro

visi

on

of

subs

ti-

tuta

bilit

y of

pe

rson

nel

coul

d fa

cili-

ta

te

re-

sche

dulin

g fo

r re

ason

- ab

le a

ccom

- m

odat

ion.

Spe

cifie

s to

ols,

m

a-

chin

ery

and

unus

ual

wor

king

co

nditi

ons

requ

ired

for

norm

al

job

perf

orm

ance

. A

d-

ditio

nal

info

rmat

ion

rega

rdin

g po

tent

ial

reas

onab

le

acco

m-

mod

atio

n co

uld

eas-

ily

be

colle

cted

at

tim

e of

job

anal

ysis

.

If ta

sks

are

writ

ten

at

Cro

ss-jo

b su

b-

func

tiona

l le

vel,

then

st

ituta

bilit

y st

anda

rd t

ask

anal

y-

only

po

ssib

le

sis

may

pro

vide

a l

ist

if cr

oss-

job

of c

ritic

al

or i

mpo

r-

sim

ilar

task

ta

nt f

unct

ions

. T

his

scal

es

used

. ca

n be

sup

port

ing

The

new

ev

iden

ce f

or f

unct

ion

Com

mon

es

sent

ialit

y.

One

is-

M

etric

Que

s-

sue

is h

ow c

ritic

ality

tio

nnai

re

is

May

obt

ain

time-

spen

t or

fr

eque

ncy

ratin

gs,

but

it is

not

lik

ely

that

th

ese

will

as

sist

re-

sc

hedu

ling.

Equ

ipm

ent

is u

sual

ly

spec

ified

in

tas

k an

- al

yses

, bu

t no

t al

- w

ays

in a

det

aile

d or

sy

stem

atic

m

anne

r. I

f cl

early

spe

cifie

d,

rea-

so

nabl

e ac

com

- m

odat

ion

sugg

estio

ns

coul

d al

so b

e ob

tain

ed.

cont

inue

d

Tab

le 1

co

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Essential Function Evidence. Additionally, as was stated previously, FJA asks the question of any a task is performed. This forces the job analyst to consider the desired result of action. This method of job analysis could be easily supple- mented to directly identify essential functions of job performance by identify ing which of the reasons listed under why actually represented essential, versus only marginal, functions of the job. Cascio (1991) gives the example of a firefighter who performs the action of carrying smoldering mattresses and fu~iture from buildings in order to reduce fire and smoke dosage to buildings and their contents. At this point of the analysis, it may be possible to rate the reasons for action that are identified in terms of their essentiality/nonessen- tiality. And, while FJA does not directly provide evidence of function essentiality, it does provide much supporting evidence with ratings of function fie- quency on a cross-job relative scale, consequences of error, and difIiculty.

Reasonable A~co~~odatio~ Evidence. FJA worksheets allow for substitutability of personnel by relation to others in the target position and equivalent positions. The provision of information pertaining to the substitutability of personnel could facilitate rescheduling for reasonable accommodation. FJA specifies tools, machinery, and unusual working conditions required for nor- mal job pe~ormance. Additional information regarding potential reasonable accommodation could be easily collected at the time of job analysis.

Task Analysis

A typical task analysis, or task inventory (Harvey 19901, is conducted in the following way. First, inte~iews with a sample of job incumbents (and, usually, supervisors of incumbents) are conducted to obtain a list of tasks in the job. This list is reviewed several times by different parties for completeness and accuracy. Second, a survey is conducted on a much larger sample of job incumbents, in which the tasks are rated on a number of dimensions (e.g., task frequency, importance, or difficulty). Analyses of survey results yield a list of tasks, sorted by criticality. Task analyses are non-transportable job analyses which focus primarily on how a job is performed by outlining the tasks involved in job performance.

Outcome Orientation. Such task analyses are usually performed without ex- plicit concern for outcomes of task performance. Thus, if the task analysis focuses only on what work is completed and not why it is completed, then the task analysis will not allow flexibility when determining how a job can be performed in different ways while achieving the same outcome. For example, the task “Lifts packages of up to 20 pounds off truck, placing them on conveyor belt” would be behaviorally specific rather than outcome oriented. If the same task could be rewritten as “Transports packages, either by manual lifting or with machine assistance, from truck to conveyor belt,” this would be more function or outcome-oriented in nature.

Essential Function Evidence. Similarly, if tasks are written at a high level of specifity (and Harvey 1991, includes task analyses under “high specificity”


approaches) then standard task analyses cannot provide a list of critical or important functions, but only critical or important tasks. On the other hand, if written at a more functional level, a task analysis could provide supporting evidence for function essentiality.

One issue is how criticality is judged. CODAP (Christal 19741, for example, determines importance largely in terms of relative time spent in tasks. How- ever, direct estimates of criticality or importance should be obtained to provide clear evidence that a function is essential.

Reasonable Accommodation Evidence. A task analysis allows for cross-job comparison if a cross-job relative task rating scale is used. Additionally, task analyses often provide time spent or frequency ratings for task performance. More frequent tasks might be more or less substitutable, depending on job incumbent capabilities. If ratings could be obtained on task schedules (e.g., morning versus afternoon) such ratings might assist in allowing flexibility in determining when an individual with a disability could take work breaks throughout the day.

Equipment is usually specified in task analyses, but not always in a detailed or systematic manner. If clearly specified, reasonable accommodations suggestions could also be obtained.

Threshold Traits Analysis

Threshold Traits Analysis (TTA; Lopez et al. 1981) is a method which suggests what human characteristics are important for a job. Subject matter experts rate jobs in terms of the traits necessary to perform the job such as physical abilities (e.g., strength), mental abilities (e.g., memory), learned skills (e.g., craft knowledge), motivational factors (e.g., initiative), and social factors (e.g., influence).

Outcome Orientation. TTA only generally eludes to outcomes. This approach is better for job specifications than job descriptions.

Essential Function Evidence. TTA specifically discusses job functions. How- ever, these are not necessarily work outcome related-e.g., physical exertion or bodily activity. Traits are then identified for various functions. So, the “function” Sensory Inputs requires the “traits” of vision and hearing. In any case, deriving essential functions from a typical TTA does not appear to be straight- forward.

Reasonable Accommodation Evidence. As stated previously, TTA identifies the particular physical and cognitive abilities which are required for performance of the job. Physical requirements include strength, stamina, agility, vision, and hearing. Mental requirements identified include perception, concentration, memory, comprehension, problem-solving and creativity. If nini- mum acceptable levels of each of these requirements are identified below which individuals would be considered unable to perform the essential functions of their job, then this information could be very useful when an employer

20 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7. NUMBER 1. 1997

must determine whether or not an individual with a disability can perform the essential functions required. Cascio (1991) suggests that some individuals with disabilities may be excluded from certain jobs because the job specifications for the job are “inflexible, artificially high, or invalid” (pp. 195-196). Thus, we agree with Cascio (1991) that job specifications should outline minimun levels of acceptable standards for selection. This would help to ensure that individuals’ with disabilities are not being artificially restricted from being selected for a job for which they are capable. Additionally, this information may indicate which deficits can and cannot be safely and easily accommodated.

Position Analysis Questionnaire

The Position Analysis Questionnaire is a “worker-oriented” job analysis method. Worker-oriented methods examine general job demands and characteristics rather than tasks per se. Therefore, these methods generally focus less on outcomes and essential functions than ‘tjob-oriented” methods such as FJA. One big advantage of worker-oriented methods is that vastly different jobs can be compared on degree of demand in various areas of human function- ing. So, for example, an air traffic controller and a stock analyst might have similar jobs in that both are require quick processing of large volumes of information.

Outcome Orientation and Essential function Evidence. Items in worker-oriented approaches such as the Position Analysis Questionnaire (PAQ) are not written to be outcome oriented. For example, PAQ items under “Information Input” include “written materials, ” “quantitative materials,” and “mechanical devices.” These are rated for “extent of use” ranging from nominal to very substantial. Suppose for a particular job the extent of use of written materials is “substantial.” Such a specification does not indicate the desired outcome of working with written materials, it only captures how the job is currently performed. Again, the key point to remember with an ADA-appropriate job analysis is that how a job is currently performed in not necessarily how the job must be performed.

Essential Function Evidence. Using the previously stated example, a job analysis which indicates that the use of written material is “substantial” also fails to indicate the essential function of the job-possible functions requiring substantial use of written materials might include managing correspondence or proofreading. However, the PAQ does request that incumbents rate “importance to the job, ” “amount of time spent,” or “applicability,” of several scales (Information Input, Mental Processes, Work Output, Relationships, Job Con- text). Results from such analyses could be used to identify essential functions if the functions were specified separately and linked to relevant PAQ scales. However, the PAQ does not provide evidence for essential functions as directly as other job analysis approaches such as FJA.

Reasonable Accommodation. Worker-oriented methods do collect information concerning general equipment demands. However, this information would


need to be particularly specified, after which reasonable accommodation rec- ommendations could be made.

Critical Incident Technique

The Critical Incident Technique (CIT) (Flanagan 1954) requires subject matter experts to generate job behaviors or events which exemplify outstand- ing or substandard performance. These job behaviors are grouped into categories, and the categories are named. So, for each job category (e.g., Inspection), good and bad performance examples are available.

Although useful for some purposes, such as developing training or performance appraisal instruments, CIT is clearly a descriptively interesting but potentially incomplete technique-the job may or may not be completely represented by the critical incidents elicited (Harvey 1991).

Outcome Orientation. Flanagan (1954) states that a critical incident should have a “purpose or intent . . . that seems fairly clear to the observer and where its consequences are sufficiently definite to leave little doubt concerning its effects.” For example, a general aim of an activity might be “sustained high quality and quantity of production.”

Essential Function Evidence. The job description resulting from CIT may be important evidence of essentiality, particularly in terms of consequences of error or non-performance. A CIT adapted for ADA purposes, however, would need to assure that functions are focused on. Typically, CIT will only yield particularly behaviors which occur in a particular setting with a particular good or bad consequences.

Reasonable Accommocfation. Equipment normally used will be specified in critical incidents, which may allow for the suggestion of potential reasonable accommodations. Interestingly, Harvey (1990) states that a drawback to CIT is that it may yield results that are “contaminated” by job behaviors unique to a particular job incumbent. That is, the same function might be characterized by different approaches, which could be useful in suggesting substitutability of personnel or alternate methods of job performance which could be performed by individuals with disabilities.

DESIRED OUTCOME OF AN ADA-APPROPRIATE JOB ANALYSIS

As stated previously, the goal of this article is not to champion one particular job analysis method over all others. Undoubtedly, an ADA-appropriate job analysis can be carried out in many ways. Most job analysis methods could be adapted to produce useful, ADA-appropriate job analyses. Table 2 presents part of a hypothetical job description which might result from such a job analysis. The “What” column contains the tasks that are typically produced in a task analytic approach. However, in the “Why” column the essential functions are identified. In the “How” column typical ways of function accomplishment are

Tab

le

2 P

ossi

ble

Con

stru

ctio

n of

AD

A-A

ppro

pria

te

Job

Des

crip

tion

Why

(E

ssen

tial

How

vyp

ical

W

ho

Wha

t (T

ask)

F

unct

ions

) M

etho

d)

Com

men

t

Job

Incu

mbe

nt

Ana

lyze

s D

ata

To

Det

erm

ine

Tre

nds

Usi

ng

Com

pute

r C

ompu

ter

Use

R

e-

Pac

kage

qu

ired.

S

ome

visu

al,

Mot

or

Acc

omod

atio

n C

urre

ntly

in

Pla

ce,

Oth

ers

Pos

sibl

e.

Writ

es

Rep

ort

To

Doc

umen

t R

e-

In S

tand

ard

For

mat

, S

ee

abov

e.

Fun

ctio

n su

lts

Usi

ng

Wor

d-

Can

B

e P

erfo

rmed

P

roce

ssor

. by

Oth

ers.

P

rese

nts

Res

ults

to

T

o P

rovi

de

Info

rma-

T

hrou

gh

Ora

l P

re-

Acc

omm

odat

ion

for

and

Con

sults

w

ith

tion

for

and

Ass

ist

sent

atio

n.

Spe

ech

Dis

abili

ties

Man

agem

ent

Dec

isio

n-m

akin

g P

ossi

ble


listed. Finally, the “Comment” column records the analysts observations about ADA-relevant issues. In order to fill this column, structured questions should be asked of all incumbents. These questions should directly address issues of substitutability, scheduling, and reasonable accommodations. Reasonable accommodations need not be in place, nor need they be exhaustively identified. However, gathering information on what accommodations are currently in place for a given job should not be difficult. Suggesting what accommodations might be reasonable in the future, should the need arise, would simply require the job analyst to use his or her own informed judgment, or to gather such judgment from subject matter experts. It is always open to revision, as might be necessary should an incumbent develop an unanticipated disability. Such a job description as outlined in Table 2, therefore, should clearly be viewed as an updatable, “living” document.

It should be noted that the job description in Table 2 is almost what one gets now from FJA. So, although almost any job analysis method could be used to obtain ADA-appropriate results, FJA seems to be the closest among those we considered. The comment by Howell and Dipboye (1986) about FJA seems prescient:

We know that it is possible with other methods to provide plenty of detail without capturing the essence of what people do-thus missing the forest for the trees. Maybe FJA gives us a glimpse of the forest (pg. 205).

CONCUJSION

We have described how current job analysis methods can be used to incorporate the mandates of the ADA (1990). This article indicated that a job analysis method chosen must focus on three criteria:

1. Identification of essential functions. 2. The job analysis must be outcome-, not method-, oriented. In other words,

the job analysis method should allow for the possibility that the same outcomes can be achieved by different means.

3. The job analysis method should be useful for identifying potential reasonable accommodations. The method should allow identification of the degree of job flexibility (Le., does it determine substitutability of tasks, schedule ~exibility, various types of equipment which might be employed). Also, the method should allow the identification of minimal requirements for sensory, motor, and cognitive requirements for the job.

When specific job analysis methods were reviewed such as the PAQ and task analysis, FJA by Fine (1988) seemed to provide the strongest evidence for identifying essential functions and potential reasonable accommodations. However, we did not review a comprehensive list of all of the available job analysis methods. Therefore, while FJA appears to be a good job analysis method to identify essential functions, other methods may be tailored to meet

24 HUMAN RESOURCE MANAGEMENT REVIEW VOLUME 7, NUMBER 1, 1997

the mandates of the ADA. It is the responsibility of the job analyst to ensure that the particular job analysis method chosen meets the previously mentioned criteria.

Past court cases do not definitively outline which pieces of evidence are most important when identifying essential functions, or how job analysis can be used to proactively identify potential reasonable accommodations. This is not to say, however, that human resource managers should take a reactive stance and wait until court cases shape how job analyses should be conducted. While it can be argued that the ADA (1990) is vague in its prescriptions for how essential functions may be defined, the ADA does suggest multiple pieces of evidence for function essentiality that can easily be collected through job analysis.

In summary, one of the primary goals of this article was to demonstrate to practitioners that a proactive position can be taken to ensure that the mandates of the ADA (1990) are met. Overall, the ADA may benefit human resource managers in ways that may not have been anticipated. First, the nature of work and how work is described is changing. Technological developments, downsizing, and rapid organizational change have all had a major impact on how we understand work (Howard 1995). Indeed, some have suggested that the very concept of “job” is outdated (Church 1996). The ADA (1990) is an event which raises questions about how job analysis is best applied to the description of work. These questions force human resource managers to develop job analysis strategies which are flexible enough to accommodate the changing nature of work.

The second way the ADA will shape human resource management is related to the first point. As has been reiterated repeatedly in the literature over the last several years, the nature of the workforce is changing. Minorities and women are going to comprise a much larger portion of the workforce (Offerman & Gowing 1990), and human resource managers are going to have to respond to these changes. The ADA may provide the impetus for human resource managers to begin to view job analysis as a potential vehicle to be used to incorporate diversity into the workplace. Thus, the ADA can be viewed as a catalyst for “modernizing” job analysis in preparation for both the rapidly changing nature of work, as well as the changing nature of the workforce performing that work.

Brannick et al. (1992) state that a company they worked with worried that falsely identifying functions as essential presented more of a legal problem than not identif~ng essential functions at all. This approach suggests that burying the organization’s head in the sand is a more effective legal technique than proactively trying to comply with the ADA. It is unfortunate that a law designed to encourage diversity in the workplace is now feared rather than embraced as an opportunity to diversify the workplace.

Future Research

This article suggested several avenues for future research. First, future research should assess how Fortune 100 companies are currently conducting


job analyses to meet the mandates of the ADA. It would be interesting to assess how many companies take a proactive view of the ADA and strive to identify essential functions and potential reasonable accommodations through job analysis methods. Additionally, it would be interesting to assess what pieces of evidence these companies use to determine function essentiality.

Second, future research should identify a specific way that information may be combined to ensure that essential functions are identified. Brannick et al. (1992) suggested using a policy capturing approach which makes a quantitative estimate of how much various pieces of evidence contribute to the judgment of function essentiality. Clearly, research is needed in this area.

In addition, the survey results indicated that individuals with disabilities may perform their jobs differently while achieving the same results. However, future research could assess how individuals with various disabilities perform their jobs, and the types of reasonable accommodations requested and imple- mented most frequently. In fact, organizations such as the Job Accommodation Network (JAN) have collected data on the types of reasonable accommodations provided for different disabilities. It would be helpful if organizations such as JAN could work together with human resource managers to publish a menu of reasonable accommodations used by other companies for varying levels of sensory, motor, and cognitive deficits. This list of potential reasonable accommodations could be matched with a list of the minimal requirements for particular jobs identified by a job analysis. Thus, while each particular reasonable accommodation may ultimately be handled on a case by case basis, this does not mean that human resource practitioners cannot benefit from the learning of other human resource managers.

ACKNOWLEDGMENT

The authors wish to thank Micheal T. Brannick, Qian Yang, and Dianna Stone for their help with this article.

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Alliger, G. M. 1991. Job Descriptions and Subjectivity: Toward a More Idiographic Job Analysis. Paper presented at the Ninth International Congress on Personal Con- struct Psychology, Albany, NY.

Americans with Disabilities Act. 1990. 1990. Federal Register 56: 35726-35756. Brannick, M. T., J. P. Brannick, and E. L. Levine. 1992. “Job Analysis, Personnel Selec-

tion, and the ADA.” Human Resources Management Review 2(3): 171-182. Cascio, W. F. 1991. Applied Psychology in Personnel Management (4th ed.). Englewood

Cliffs, NJ: Prentice Hall. Chiari u. City of League City. 1991. U.S. court of appeals for the fifth circuit, No. 89-

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Christal, R. E. January, 1974. The United States Air Force Occupational Research Project, (AFHRL-TR-73-75) Lackland Air Force Base, Texas: Occupational Re- search Division.

Equal Employment Opportunity Commission. 1991a. “Equal Employment Opportunity for Individuals with Disabilities 1991a.” Federal Register 56: (144).

-. 1991b. The Americans with Disabilities Act: Your responsibilities as an employer. Washington, DC: Government document.

-. 1992. A Technical Assistance Manual on the Employment Provisions (Title I) of the Americans with Disabilities Act. Washington, DC: Government document.

Fine, S. A. 1988. “Functional Job Analysis.” Pp. 1019-1035 in The Job Analysis Hand- book for Business, Industry, and Government (Vol. 2), edited by S. Gael. New York: John Wiley and Sons.

Flanagan, J. C. 1954. “The Critical Incidents Technique.” Psychological BuEZetin 51: 327-358.

Harvey, R. J. 1990. “Job Analysis.” In Handbook of Industrial and Organizational Psychology (2nd. ed. Vol. 2), edited by M. D. Dunnette and L. M. Hough. Palo Alto, CA: Consulting Psychologists Press.

Howard, A. 1995. The Changing Nature of Work. San Fransisco: Jossey-Bass. Howell, W. C. and R. L. Dipboye. 1986. Essentials of Industrial and Organizational

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Lopez, F. M., G. A. Kesselman, and F. E. Lopez. 1981. “An Empirical Test of a Trait- Oriented Job Analysis Technique.” Personnel Psychology 34: 479-502.

McCormick, E. J., R. C. Mecham and P. R. Jeanneret. 1972. “A Study of Job Characteris- tics and Job Dimensions as Based on the Position Analysis Questionnaire (PAQ).” Journal of Applied Psychology 56: 347-368.

Offerman, L. R., M. K. and Gowing. 1990.” Organizations of the Future: Changes and Challenges.” American Psychologist 45(2): 95-108.

Toward an ADA-appropriate job analysis

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