This is a question that we have heard over the years from companies that require a Commercial Drivers License (CDL) for employees in certain job titles – whether they are bus/transport vehicle drivers or public works employees. For many positions that involve driving certain classes of vehicles, the state or federal government require a driver to have a CDL. One component of obtaining and maintaining a CDL is undergoing a DOT medical examination with a DOT certified provider.
The main purpose of a DOT medical examination as part of obtaining/maintaining a CDL is to ensure that a driver is medically safe to operate the vehicles within the classification of their license. Priority areas of a DOT medical exam include assessments of vision, hearing, blood pressure, cardiovascular health history, metabolic health history (ex. diabetes), and an overall physical assessment. An assessment of the upper and lower extremities checks for muscle weakness or loss of limbs. While range of motion is addressed in a DOT medical examination, it is to determine whether the examinee has any potential range of motion issues that the DOT examiner may feel are detrimental to their ability to operate trucks and passenger buses. While an employer may be sending a driver for an exam, the examiner is not evaluating based on specific job demands.
The DOT medical examination does not address specific range of motion issues related to ingress/egress for specific types of vehicles (how high is the first step and the grab handles), the range of motion required to operate controls on specific vehicles, or the strength and range of motion related requirements to perform employer specific tasks (loading/unloading products/materials, securing items, operating controls, moving hoses, pulling down ladders, etc.). A job specific post-offer physical pre-employment evaluation (or depending upon the situation, Return To Work FCE or Fit For Duty FCE) can address the examinee’s ability to perform the essential minimum postural and physical demands of the position. Employers should have a customized job description that includes objective measurements of the essential minimum physical and postural demands of the job title. These measurements should be collected using the vehicles, equipment, and other items that are used by the employer and employees when performing their job.
Obtaining a DOT medical certification does not necessarily mean that a driver can meet the essential postural and physical demands of a customized job description. Conversely, meeting the essential postural and physical demands of a customized job description does not mean that a driver will be able to successfully pass a DOT medical examination (a variety of medical conditions are automatic exclusions in DOT medical examinations or require physician approved waivers).
NJ Ergonomics can assist with the documentation of objective measurement of physical and postural demands of job tasks as well as generation of Post-Offer Pre-Employment physical abilities testing protocols that are based on the essential demands of a job title.
All too often, job titles in the DOT get lumped into a closest possible job title instead of a singular, job specific title. In many ways, this dictionary is like a thesaurus when it comes to finding a specific job entry to use as a reference. Due to the fact that a wide range of applicable job titles may all fall under one specific entry, the information is not always as applicable as we would like it to be. Sometimes, it gets the main theme of the job but the demands may be off – or in other cases, the listed physical demand is more of an average of the possible demands.
Not too long ago, I went to a Cowtown Rodeo in southern New Jersey and was wondering how the Dictionary of Occupational Titles would define the demands for a rodeo clown. Rodeo clowns fill a unique role within the world of rodeo. At first glance, they seem to be for entertainment and they do fill that role. However, one type of rodeo clown – the barrelmen – provides the comic relief while the other type of rodeo clown – the bullfighters – help to keep the riders safe when they have fallen off of a bull or a bronco. From observation, it appears that rodeo clowns have to be fast, be agile, have good balance, and an ability to climb fences at times to get out of the way of a bull or bronco. They don’t appear to have the heavy lifting demands of rodeo performers involved in calf roping which requires the ability to pick up a calf and put them back on the ground.
“Demonstrates daring and skill by bronco riding, calf roping, bull riding, steer wrestling, or similar feats in rodeo competition to entertain spectators and compete for prize money.”
It really only covers the rodeo clown in the entertaining spectators portion as the rodeo clowns don’t perform the other tasks listed. And the entry for clown in the DOT does not really seem to cover what a rodeo clown does, other than:
“Dresses in comical costume and makeup and performs original or stock comedy routines to entertain audience.”
There is a huge variation in the physical demands between the two entries. The clown entry places the physical demand as light (20 pounds occasional, 10 pounds frequent, negligible constant) while the rodeo performer entry places the demand at heavy (100 pounds occasional, 50 pounds frequent, 20 pounds constant).
Once could argue that the rodeo clown fits closer to the rodeo performer description at heavy as they may have to help an injured rider up from the ground but DOT entries don’t do a good job of explaining the balance required or describing the surface that the rodeo clowns perform on (a dirt surface that has been churned up by the hooves of horses and cattle) or the need to be able to move quickly out of a need for safety for themselves and others. However, the entry doesn’t explain to a person that hasn’t seen a rodeo clown in action that they may have to sprint to the edge of the arena and quickly climb the fence that separates the audience from the arena to get to safety. Alternatively, the entry for rodeo performer is a little on the light side for use with rodeo riders that perform calf roping – a calf in a competition can weigh between 220 and 280 pounds per competition rules. Being that the roper is trying to get the calf roped, secure, and immobilized they are more likely than not to exceed 100 pounds of force in pushing, pulling, lifting, and carrying.
Ideally, a job description for a job title when being used for comparison during an FCE will include information about the physical demands (lifting, pushing, pulling, carrying and the heights and manners that these tasks are performed) as well as the postural demands (balance, walking, kneeling, squatting, reaching, etc. and how they are performed/where they are performed). Rodeo clowns definitely walk (and run) on uneven terrain that sometimes may be wet or muddy and is definitely slippery – balance and speed of movement for safety is definitely important. Some rodeo performers need to have enough balance to stand on a horse while going around the arena at speed. Their climbing needs are not the usual climbing needs for your standard party or circus clown. As a matter of fact, most jobs don’t require you to climb a 6 to 8 foot fence to escape from a rampaging bull.
In upcoming posts, we will take a look at other job titles to see how well the Dictionary of Occupational Titles matches up against the actual demands of the job. Posts will look at nursing, skilled trades, and many other jobs including a comparison for the personnel that work in Weights and Measures. Some positions, such as nursing, present many of the same issues outlined in this post. The entry for nurse in the Dictionary of Occupational Titles lumps almost all of the varied roles that nurses perform into one singular entry – however, some occupations such as police and fire have breakdowns of the different internal roles. We will visit each of these and look at the impacts that these entries may have on performance of an FCE.
Quick notes: All images in this post are owned by Quin Bond. Usage is available upon request.
Yesterday, I had pulled a job description that had been provided to us for a Functional Capacity Evaluation to use as a resource during a discussion with a client as they sought to understand the dynamics of a particular job position within the security field. As I reviewed the description, I remembered that despite the description’s length and detail level, the description had some significant issues when it came to the issue of lifting and carrying.
Hidden Information On What May Be Carried
One piece of information that needs to be kept in mind is a small quote embedded in description box located two pages prior to the physical demands. The box that can be easily missed states: “Personal gear per individual carried routinely is about 28 pounds and may need to climb towers as high as 60 feet with about 21 pounds of gear (rifles are normally staged for towers).” A box just below that indicates that this gear includes weapons, binoculars and/or night vision equipment, special purposed detectors, ballistic helmet, ballistic vest, ammunition, flashlight, and other small items.
One of the issues is not the fact that the two tables don’t match due to the “21-24 pounds” in the carry section versus “11-24 pounds” in the lift section. That is a typo that can be easily clarified through a quick call to the employer (note to FCE providers: never be afraid to call the case manager to ask to reach out the employer for clarification of demands – even for typos.)
There are three issues in regards to the carrying and lifting tables within the job description:
Issues With Carrying
The first issue is that the carry demand is not clearly defined. As noted above, there is a small box that denotes “personal gear individually carried routinely is about 28 pounds”. Those items in the list are not carried in the traditional sense of a bimanual or unilateral carry. The items listed in that box are items that are either worn directly on the body (ballistic helmet, ballistic vest, handgun in a holster, etc.) or items that would be carried in pouches or attached to their belt or vest (ammunition, flashlight, radio, etc.).
That knowledge helps to potentially explain the 12 hours per day of carrying 25-34 pounds in the above table but the table does not include an explanation that would indicate that this is the case. It does not help to explain any of the values greater or less than that specific range. Loaded rifles typically weight below 10 pounds (as do radios, binoculars, night vision optics, sensors, and many other items) yet the 10 pounds and under range is marked as “NA” or not applicable.
The 35-50 pound range and the 51-74 pound range have less frequent demands but it is difficult to determine whether those categories are inclusive of the 28 pounds of gear carried on the security officer or those are different items that are to be carried in some manner.
The carrying section should include more descriptive information to inform the reader as to what is being carried as well as the object’s weight and the manner in which it is carried (with two hands, with one hand, or worn/attached to the body).
Issues With Lifting
The lifting section brings its own issues – partially due to the ambiguity of the section defining the carry demands as well as ambiguity within the lifting section.
A quick look at the lifting demands indicates occasional lifting within the 11-24 pound and 25-34 pound ranges with no lifting demands above 34 pounds. There are no lifting demands above 34 pounds yet the carrying section indicates carrying loads up to 74 pounds. Typically, in order to carry an object that object must first be lifted – unless it is being directly loaded onto a person by someone else (such as lifting a backpack for another individual to don).
As with the carrying section, the lifting section does not provide any definitions, beyond weight ranges, of what the security officer actually lifts during the performance of their job role. While the section we discussed at the beginning lists some of the gear for the position, it is difficult to apply those items to the lifting table.
While we can make assumptions that items that are carried are either carried with both hands, carried with one hand, or carried by wearing, it is difficult to make assumptions from this table about how the lifting is performed. In addition, the table does not indicate the height ranges that lifts are performed from (knee height, waist height, shoulder height, overhead). This is an important issue when performing post-offer physical abilities testing or when performing a return to work or fit for duty FCE to determine whether an employee qualifies for return to work at full duty.
The lack of details in both the carrying and lifting sections also make it difficult to determine if accommodations are available for modified duty or not.
What About Pushing And Pulling?
Carrying and lifting are two of the three big strength tasks that should be included in a job description. We haven’t discussed pushing and pulling and the tables above don’t include either. Over the course of the primary five pages of the job description, the words pushing and pulling were not present while some of the simple grasping tasks listed (opening doors, gates, hatches, etc.) have frequency values but not force values listed.
However, the physical abilities battery that all candidates must complete includes a requirement of completing a specified number of push/pull cycles of “41 PSI” and a single 6 inch push that is set at “91 PSI”. There is not any documentation within the job description or the test that can be tied directly to these values.
The Climbing Section Is Good
The section that deals with climbing tasks is much better and denotes the types of climbing that may be performed. One of the positive aspects of this section of the description is that it includes stairs as a form of climbing. I have read too many job descriptions in the past that indicate that the job title does not require the ability to climb yet the employee was injured while ascending or descending a flight of stairs.
The one detail that would be helpful is a better description of ladder types. In the past, we have performed onsite ergonomic assessments for generation of customized job descriptions which included multiple types of ladders for the same site including A-frame ladders, extension ladders up to 40 feet, and fixed ladders – both angled and vertical.
While this job description provides a significant level of detail, it does not include the details that a treating physician, treating physical therapist, or a therapist providing a return to work evaluation would need to successfully prepare an injured employee for return to full duty. These professionals need to know what is being carried, how it is being carried, what is being lifted and where it is being lifted from or to, and how the security officer is outfitted while performing their daily tasks. Pushing and pulling demands need to be better defined – from opening and closing doors, gates, and hatches to other tasks that may require pushing and pulling actions.
Often, when you ask an individual (therapists and physicians included) to describe a security officer, they will respond with a description of a generic security officer that one would meet in a shopping mall or at a concert/sports event. In the case of this job description for security officer, the position is much closer to a paramilitary role and security officers in this role need to treated/rehabbed in that manner.
This job description was heavy on words and tables and would have greatly benefitted from the addition of photographs that help to visually describe and define the actions performed by those in this job title as well as the environments in which the tasks are performed.
Shortly before the holidays, the NTSB offered a blog post that included recommendations for school bus operators as a result of the investigation into a December 2017 school bus accident in Oakland, Iowa. The tragic accident took the lives of a school bus driver and a 16 year old student when the exhaust pipe of the bus was blocked by the side of a drainage ditch. While all of the bus exits – emergency non-emergency – were operational, the report suggests that the student and driver succumbed to smoke inhalation when the student may have been attempting to help get the bus driver off of the bus.
In November 2017, the driver had visited his doctor due to complaints of pain and stated that “he could walk if he used a cane or crutches, that he experienced pain that prevented his sitting for more than 30 minutes (or standing for more than 10 minutes), and that he was sleeping less than 4 hours a night.” The school bus driver had been scheduled for a lower back surgery that would have occurred just 2 days after the fatal bus accident due to complaints of chronic lower back pain with weakness of his right leg.
The NTSB final report notes that the school district was aware of his physical disabilities and his scheduled surgery but did not remove him from service. In addition to his physical complaints, numerous complaints about his driving performance were provided to the school district previous to the event but not documented. However, finding number 9 concludes:
“It is likely that the bus driver’s progressive chronic back disease, which caused severe chronic pain, impaired his ability to evacuate the school bus himself or to assist the passenger to evacuate.”
The report also notes that the school district did not follow the district’s own requirements defining physical abilities of school bus drivers including appropriate fit for duty clearance of a driver that was not able to perform the required safety duties of the position.
Finding number 10 states:
“The use of physical performance tests on both a routine and as-needed basis can help identify physically unfit drivers who have a valid medical certificate but who might not be able to perform required safety duties, especially in an emergency.”
It is important to remember that a valid medical certificate does not necessarily indicate that the holder can perform the essential postural and physical demands of a specific position. The valid medical certificate only indicates that the holder meets the 4 non-discretionary standards (vision, hearing, epilepsy, diabetes mellitus) and 9 discretionary standards (hypertension, cardiovascular disease, respiratory function, loss of limb, limb impairment, neuromusculoskeletal dysfunction, mental disorders, drug use, and alcoholism) as outlined in 49 CFR 391.41. The valid medical certificate indicates that a physician has determined them to meet the 13 standards but does not include a functional abilities test based on the essential minimum postural and physical demands of a position based on validated measurements of the required tasks.
Finding number 10 provides the basis for the following recommendation, which is directed to 44 states including New Jersey, made in the report:
“Revise your school bus driver requirements so that all drivers must pass a physical performance test on hiring and at least annually, and also whenever a driver’s physical condition changes in a manner that could affect his or her ability to physically perform school bus driver duties, including helping passengers evacuate a bus in an emergency.” (Emphasis mine)
School bus drivers perform a variety of tasks, in addition to driving the bus, that have specific postural and physical requirements, including:
Range of motion/strength to enter/exit the bus from the front side entrance, rear exit, or the wheel chair entrance.
Check roof top emergency exits (reaching to 72+ inches and applying vertical pushing and pulling forces) as part of the daily pre-drive inspection.
Maneuvering and securing (bending, kneeling, reaching) of wheelchairs when driving students who utilize wheelchairs.
The ability to bend/kneel to check under seats as well as view underneath bus.
The physical ability to provide assistance in seating/securing (seatbelts) for special needs students in the event that a bus aide is not provided for this task.
The physical ability to help move a physically incapacitated passenger from the bus in the event that the passenger needs to be moved to safety prior to the arrival of trained first responders.
Many states, including New Jersey, suffer from a shortage of school bus drivers. However, the NTSB report states:
“The NTSB is also aware that many medically certified school bus drivers with safe driving records have physical limitations that could prevent them from passing a PPT. However, the consequences of a driver not being able to evacuate a school bus or assist passengers in an emergency cannot be ignored.” (emphasis mine)
Additional recommendations by the NTSB include:
Appropriate fire suppression systems in the engine compartment
Usage of 911 emergency buttons as opposed to radioing the transportation supervisor (The driver of the bus contacted the transportation supervisor by phone after the fire started rather than calling 911. The call to 911 was not immediately placed by the transporation staff but by the student’s mother after the family was notified.)
Making sure that students, teachers, and other district employees are trained in evacuating through all of the exits, including manually operated loading doors, in the event that a bus driver becomes incapacitated.
I have had two separate discussions this week involving job titles, job descriptions, and when employees are required to do jobs that are outside of their “specific” job title – but still essential job demands of their overall “job title”. During both discussions, a key detail to the “specific” job title in question was that the specific job title falls under a much broader category.
I try to avoid sports analogies when meeting with clients because they can sometimes be cliché, especially depending upon the setting. However, a recent Phillies game went into extra innings and became a great example of the situation that both clients were questioning. While we refer to most major league baseball players by the position that they play, the overall job title that applies to them is baseball player. During this extra inning game, the Phillies manager had to make some adjustments in the 13th inning (not really different than unplanned overtime) which included moving an outfielder to pitching and having a pitcher play in left field. While not uncommon, moves like this don’t happen in every extra inning game. What made this game memorable is that Vince Velasquez, the pitcher who was placed in left field, made two highlight worthy throws to throw runners out. Each of these players were moved from their “normal” job to a different job, but still under the same title, and were able to fulfill their role – well maybe not for the outfielder who pitched because the Phillies lost the game.
We have several clients that use a system similar to this, in that when a person applies for a position with the company, they will apply for Job Title “A”. For these clients, Job Title “A” will have several sub-titles or location areas that the employee may be directed to work within after company specific training. They may have been hired with experience in other sub-titles or locations but these companies, much like the military, will place these new employees where they have a demand. One of the companies uses a title of Mechanical for the position. Those within the Mechanical position may work in carpentry, plumbing, electrical, rigging, welding, etc. While an employee may be placed in one of these areas dependent upon company needs, they are all trained to be able to perform the tasks of mechanical employees so that when the need arises they can fill that particular need. On the public sector side of this issue, we have seen similar job descriptions that require staff of public works departments or the buildings and grounds department within a school district have to be able to perform multiple roles as needed.
Cross job utilization can allow for companies to identify modified duty accommodations that an employee may be able to fill, help to spread out overtime over a larger group of employees if an individual employee is injured or ill, and allows some employers to reduce the amount of different job titles that they need to perform post-offer pre-employment tests for – if the job demands to be able to perform across multiple roles can be demonstrated to be an essential demand.
Sporting events with storied traditions are not typically the settings for learning new lessons in the world of essential demands for job positions. However, the 2018 US Open is a great lesson for employers in reviewing both their “essential job demands” as well as their post-offer physical abilities testing process.
Each of the four tennis Grand Slam tournaments has their own specific styles – Wimbledon has grass courts and white tennis outfits, the French open is a demanding tournament due to its clay surface, the Australian Open has hard surfaces like the US Open, but the roof can be closed so play can continue during inclement weather, and the US Open is played on a hard court surface. Until this year, the US Open had one unique functional difference from its three peers – ball boys and girls were required to be able to throw the ball overhand across the court, accurately, to their peers when balls were needed. In the other three tournaments, the ball is rolled across the courts, underhand. The US Open is also the only Grand Slam tournament that allowed adults over the age of 18 to apply as a ball boy or girl.
This year, the US Open determined that by changing the essential demand for this exchange of tennis balls on the court from throwing to rolling, it would open the applicant pool to a broader base of applicants. The US Open has not attributed the change to a decrease in the number of applicants with a strong enough throwing arm and adequate throwing accuracy but to a desire to increase the applicant pool to include those who may not have been able to be applicants due to this singular demand but meet all of the other demands. This change marks an end to a several decades long tradition of throwing the tennis balls.
But, was it truly an essential demand to begin with? Not necessarily. As has been mentioned, most tournaments are able to function adequately with the balls being rolled across the courts. It was an entertaining method of performing the task, but changing the method does not reduce the completion of the end result – the ball gets from one side of the court, whether it is rolled or thrown.
What essential job tasks do you have that may have another method or technique for being performed that does not impair (either from a safety or a financial hardship aspect) the end result of the job task? If this task is changed to an alternate method, have you accurately modified your post-offer physical abilities tests or the job demands description that are utilized during treatment and return to work testing?
“You can arrive at your dream a lot of different ways, but you also arrive there as a different version of yourself based on whatever pathway you choose.” – Joanna Gaines
Post-offer physical abilities testing is something that should really be straight forward. Testing based on the minimum essential postural and physical demands for the position that has been offered to the candidate. Seems pretty simple, the candidate either meets or does not meet the minimum essential demands. But, it isn’t always that simple because the process involves people.
When a candidate fails a post-offer physical abilities test, the employer has to choose what path they will take. Some employers may look to see if the candidate’s abilities meet the demands of different position. Other employers may offer the candidate the opportunity to repeat the test at a later date. Some employers may choose to not re-test.
One of the employers that we work closely with allows candidates to work on improving in the areas in which they did not meet the demands and attempt the test again with the next new hire class. This particular employer has a fairly high passing rate (which is due to a phenomenal hiring process by the employer that helps to make sure that the demands of the position are consistently reinforced during every contact with the candidate), so the number of candidates who do not meet the demands is fairly low. Of those that do not meet the demands on the initial test, some come back to test again. It is a good job with solid benefits and is worth the time and effort for these candidates to try again. Nearly everybody who re-tests comes back physically stronger and with improved range of motion and physical abilities and passes the test. Many comment that not meeting the demands on the initial test was a significant wake-up call about their previous level of fitness. They wish they were able to start the jobs with their original classmates but they are also content with the fact that they have not only done what was required to earn the job but have made lifestyle changes that will benefit them for years to come. We don’t mind repeat tests for this employer as we know most candidates return, changed for the better.
Recently, we had a second test for a candidate from a different employer. This candidate’s scenario was much different. It was the first post-offer failure for the employer and it was a result of lack of medical treatment for an auto-immune disorder that attacked the candidate’s upper extremities in a way that did not allow the candidate to meet the minimum essential demands. The employer did not have alternative positions with decreased physical demands to offer. As the candidate had not yet received treatment for their condition, we suggested to the employer (along with the instruction of talking to their lawyers) that if the candidate has a change in physical function due to treatment that they be re-tested.
When this candidate was scheduled for a second test, I was unsure of what to expect. Luckily, the candidate returned with significantly improved function due to appropriate medical treatment and they were able to meet the minimum essential postural and physical demands of the position. The candidate told us that as a result of not meeting the demands for a position, they realized that they needed to become more proactive with their physician in seeking a successful treatment regimen for their condition. For this candidate, not only did they obtain the position they wanted on the second test, they were able to become a successful advocate for their own healthcare status and understand the importance of that in keeping their condition in check.
In each of these success cases, the post-offer candidates arrived at Point B – meeting the demands and obtaining the position – but they also arrived at Point B as improved versions of themselves with better fitness and abilities, and in the second case a better advocate for their own healthcare.