Job Descriptions

The fundamental purpose of a job analysis is to review present positions to determine all primary tasks and subtasks and to document specific job responsibilities into a formal written job description.

Job Analysis for Compliance

Although the ADA does not statutorily require employers to have job descriptions, it is clear that they serve as a vehicle for employers to document essential job functions and state the physical/mental, organizational and environmental factors inherent in all positions to provide a defensible basis for personnel decisions. The written job description is considered evidence of the essential functions of a job. The application of non-essential job criteria which has the effect of screening out persons with disabilities (i.e. lifting, hearing, seeing, etc.) may result in liability. Therefore, clearly defined written job descriptions must be developed since the courts and other administrative agencies (EEOC) will use job descriptions to decide what functions are essential and not essential. It is important that the essential job related functions be well defined since reasonable accommodation under the ADA must be provided in connection with those essential job related functions.

Job analysis is critical in implementing the Americans with Disabilities Act (ADA), particularly the need to describe the essential and non-essential functions of a job. The best methodology to accomplish job documentation and the specification of duties and responsibilities is through job analysis.

The ADA requires employers to consider reasonable accommodation when an individual’s disability provides a barrier to employment opportunities. Reasonable accommodation may include job restructuring, which by definition means that a job is structured (i.e., delineated by duties and responsibilities as in a job description). Sections 1630.9 and 1630.2.2,o,2,ii.

Defining Essential Job Functions

The ADA focuses on eradicating barriers, but does not relieve the employee or applicant from performing the essential functions of the job. Essential functions of a job means the fundamental job duties (which are the essence of a job description). Section 1630.2,n.1.

The evidence of whether a particular function is essential includes the employer’s judgment, written job descriptions, the amount of time spent on particular functions (normally stated in the job description) and work experience of other past incumbents and those performing similar work (documented in job descriptions). Section 1630.2,n,3,i-vii.