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.
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
| 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 pre-placement 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.
Pre-employment 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 pre-placement 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" pre-placement medical examinations regardless of the job.
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.