Post-Offer / Pre-Placement Functional Testing for New Hires – History & Current Practice
With today’s concern about an increasingly aging work population and job applicants who may have significant medical conditions already in existence at the time of hire, approaches to reduce the risk of injuring a new hire have become a nation-wide priority among industries. The cost of loss time and related medical expenses associated with musculoskeletal disorders (MSDs) to American employers is astounding. According to the Bureau of Labor Statistics (BLS), MSDs comprise over one-third of occupational injuries and illnesses and constitute the largest job-related injury and illness problem in the United States. Ergonomic injuries are estimated to cost American employers over 20 billion dollars annually.
Consequently, the field of ergonomics has received much attention nationally over the past few years. The primary concept in ergonomics is to make the job fit the worker. However, if an employer has incorporated all reasonable ergonomic interventions in the work place, has minimized the essential physical demands of the job, and has effectively eliminated ergonomic stressors to make the job as safe as possible, what can an employer do if a person seeking placement in a job has a disability or simply lacks the physical capacities (e.g. strength, endurance, flexibility, etc.) to perform the job safely and/or effectively? The obvious answer is to properly match the functional (physical) capacities of an applicant to job-specific functional demands prior to job placement.
Early pre-employment testing was flawed with inconsistency in testing methodology and the inability to correlate certain tests to the specific physical requirements of the job. Many functional abilities testing programs were designed and implemented with a wide variety of testing procedures and philosophies being developed. In many settings, early functional abilities testing were successful in reducing the incidence of injury. However, many potential workers were discriminated against due to various testing protocols being subjective and not necessarily related to the actual physical demands of the job.
With the advent of the Americans with Disabilities Act (ADA) in 1991, an emphasis was made on testing the abilities of a person to conduct a job safely regardless of real or perceived disability. This foundation established by ADA regulation led to an evolution in medical testing that shifted from speculation based on standard medical exams to job-specific functional testing to assess risk of injury. In order to properly “match” the worker’s physical capabilities to the physical demands of the job, medical testing became dependent on content validity derived from physical demands validations (PDVs) or job analyses.
There are various forms of functional abilities testing currently being used today. To be legally performed, employers should ensure that the testing protocol is fully compliant with the EEOC and ADA by ensuring the absence of disparate discrimination in the functional test design. This is accomplished by conducting a physical demand validation (PDV) of each job to identify the minimum essential functional demands of a job required to perform the job safely and effectively. Data from a PDV can be translated into a functional job description (FJD). Key physical demands criteria derived from the PDV and listed in the FJD can be utilized to construct job-specific functional test. These tests will assess the ability of individuals to perform only the essential functions of a particular job prior to placement in that job.
The ADA prohibits medical or disability inquiries prior to a job offer. Functional capacity testing that includes monitoring of heart rate and blood pressure is a form of a medical test, and as such, cannot be conducted on a person until a conditional offer of hire had been made to the applicant. Therefore, it is technically not accurate to call such a test a “pre-employment test”. The correct terminology is “post-offer, pre-placement functional capacity test”.
Due to the variability in a person’s health and physical fitness condition that can occur over time, it is hypothesized that there is no medical screen that can truly offer long term predictions on capacities to work without injury or illness. Instead, it is proposed that the post-offer, pre-placement functional capacity test is should be considered limited to determining whether or not the test recipient has the physical capacity to perform the essential job functions on the day of the examination. In other words, this type of testing should be used to determine if the person, on the date of the examination, has a medical condition or physical deficit that interferes with the ability to perform the job safely. Thus, the use of content validity in test design properly serves the purpose of designing fit-for-duty testing.
Since functional tests are considered forms of physical stress tests, it is prudent to conduct a detailed physical examination on the conditional new hire before allowing that person to become engaged in physically demanding tests. This is necessary to reduce the risk of injuries during functional testing. Certain medical conditions discovered during the pre-functional physical examination, such as excessive high blood pressure, can pose immediate threat of harm during functional testing. Any such finding warrants a hold on further testing until the person can have the medical condition resolved.
By performing functional testing across the board for all members of a selected job title, an employer can determine if a person has sufficient strength, flexibility, balance, coordination and cardiovascular fitness to perform the minimum essential functions of a job. If such a test accurately uses a battery of functional tests that represents true essential job functions, it can be considered valid and nondiscriminatory.
In essence, the use of a correctly designed post-offer, pre-placement functional test for specific job demands is fully compliant with the Equal Employment Opportunity Commission (EEOC) and the Amended Americans with Disabilities Act (AADA) and has proven to be an effective component in loss control efforts used by industries today. In fact, the Occupational Safety and Health Administration (OSHA) considers proper matching of employees to the job as being instrumental to injury prevention.
Need more information about fit-for-duty testing to lower injuries, contact WorkSaver at 800.414.2174 or e-mail Dr.Bunch@worksaversystems.com.