Job Demand Titles: That’s Not My Job
At the FMI Asset Protection Conference on March 10, 2015, I attended a session on the subject of categorizing jobs appropriately. The presenters were:
Jamie Wright, Corporate Safety Manager, Safeway Inc.
Mike Raub, Director of Business Development, BTE
The initial step in categorizing your jobs is a Physical Demands Analysis. The main elements in this are:
- Onsite data analysis
- Categorize data in accordance with US DOL Handbook for Analyzing Jobs
- Link essential functions and demands of jobs
Other considerations include where the data from the jobs analysis is stored. Is this on a web site or something as simple as a three-ring binder. This needs to be accessable in the future as needed by HR and legal. In addition, this information needs to be reviewed and revised periodically.
One big reason to have good job descriptions with a Physical Demands Analysis is to ensure compliance with the American’s with Disabilities Act (ADA). If you have not taken the time to clearly define your jobs in advance, you risk running into legal difficulties in the future. Clear, current and detailed job descriptions are a vital component when working with individuals who have a disability as defined under ADA.
In addition, if you are a federal contractor and have over 15 employees you are required to have an affirmative action program and to show you have been scheduling periodic reviews of all physical and mental job qualification standards. The rules do not define how frequently a “periodic” review is.
The Physical Demands Analysis (PDAs) are useful in multiple departments:
- Hire the right employee for the job.
- Set benchmarks for disability ratings as needed.
- Ensure POET (Post Offer Employment Testing) / return to work decisions are supported.
- Develop the right job description for the physical demands of the job.
- Set criteria for fit for duty testing
- Is it a scientific and defensible position for hiring and termination decision
- Is it accurate and sustainable so that it supports the normal business operations
The decision on choosing a PDA vendor partner encompasses several areas. You need to consider the size and scope of your operation and choose a partner that is capable of handling your size. You also need to consider their ability to update your PDAs in the future as needed. The partner also needs to do a thorough on-site assessment to ensure the PDA is being done correctly. Sometimes you need a partner who can assist with your data review and storage needs. Finally, your partner needs to have sufficient subject matter experts to provide the backup and support you need. This includes their ability to stand behind you in the event of future litigation.