5 Steps to Help Determine the Essential Functions of a Job

Lorrie Coffey

December 17, 2022

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As a Talent Management Consultant I work with companies across many industries to help them
understand how the Americans with Disabilities Act (ADA) impacts them. One key component of this is
helping organizations create or revise their job descriptions and understand what the essential functions
of the roles in their organization are. Often I find that employers don’t connect their job descriptions to
their need to comply with ADA and they don’t understand how determining the essential functions of a
position plays into that compliance. The failure to understand how to evaluate the essential functions of
a role and how to determine accommodations under ADA can be costly, so it’s imperative for
organizations to understand ADA, how to evaluate jobs within their organization, and how the two
things tie together when the need to accommodate a candidate or employee arises.

When dealing with ADA accommodations, employers most often find themselves challenged with how
to accommodate the physical job requirements that are necessary to complete those essential functions
of the role. Every job has physical requirements. When we think of physical job requirements, we
commonly think of physical activities such as sitting, standing and lifting. But physical requirements
often go well beyond that. Some jobs have much more strenuous physical requirements and employers
need to be able to ensure that they are hiring individuals physically capable of performing those physical
requirements. In order to do this, employers first need to understand what physical capabilities are
necessary for the completion of that role.

There are a number of ways that an employer can evaluate a role to understand what physical
requirements are needed in order for an employee to be able to perform the functions of that role. A
multi-pronged approach is recommended in order to obtain the most comprehensive data.

1) Start with conducting a job analysis. A job analysis includes interviewing incumbents in the role
to determine the functions of that role. Ask questions regarding what tasks they complete on a
daily and weekly basis and what percentage of their time they spend on each task or category of
tasks.

2) Observe them in their work. Once you have met with the incumbents in the role, observe them
actively engaged in their work. Select a few incumbents and spend time observing them
performing the functions of the role. Ask follow up questions about the tasks you see them
performing.

3) Compare your results to the current job description. Once you have completed the job
interviews and observations, compare your results to the current job description and make
updates as necessary, paying cloe attention to the physical requirements needed to complete
the required duties of the role.

4) Conduct research on the role and similar roles. In addition to conducting a job analysis, there
are resources available to assist organizations in developing well-crafted and compliant job
descriptions, such as the Bureau of Labor Statistics (BLS) job descriptions. By reviewing similar
roles, it can help you calibrate on your own job descriptions and make sure that you didn’t miss
anything in the job analysis phase that you may need to follow up on.

5) Additional considerations. Once you’ve completed the job analysis and your research, there
may be additional considerations needed, such as determining if certain physical fitness
standards are necessary for the position such as weight, height, or lifting requirements. IF a

position requires extreme or repetitive physical exertion, you may consider if a pre-employment
medical exam or physical abilities test (PAT) is appropriate for the position. When considering
the use of a medical exam or PAT, you must be careful to ensure the exam is appropriate to
ensure that the employee physically healthy to perform the essential functions of the role but
that the medical information obtained does not provide you with information that would allow
you to potentially discriminate against the employee in violation of any state or federal laws,
such as the Genetic Information Nondiscrimination Act of 2008 or GINA. PATs can be a great
way for an employer to evaluate a candidate’s ability to perform physical activities that mimic
the physical requirements of the job. Keep in mind not all PATs are an exact demonstration of
the work performed, but may be an assessment designed to evaluate physical attributes that
roles require. An example would be the type of PAT that candidates are often required to
complete for law enforcement roles, where they are required to perform a series of physical
tests such as running a timed mile, push-ups, sit-ups, and other exercises that are timed. It’s
important to remember that when using PATs in the hiring decision, the tests must be valid and
reliable.

Once you have conducted the job analysis, research, and reviewed additional considerations, you must
determine if the functions you noted are essential to that role. Determining what is an essential
functions of a position is not always an easy task. There are a number of factors that must be considered
when determining if a functions is essential to a role. These include, but are not limited to, how much
the position exists to perform the function, how often the function must be performed, how many
employees are available or required to perform the functions, and how specialized the function is. Take
for example the role of a rubber mold operator who is required to be able to lift up to 100 pounds. The
operator is lifting 100 pound sheets of rubber onto a mold press and shifting that sheet around on that
press multiple times a day throughout their shift. This is the sole purpose of this position, the function is
specialized to that position, and therefore the function is essential. Now consider the role of a
firefighter. While firefighters do not run into burning buildings every day and carry individuals out of
buildings every day, the position exists for that very purpose and all firefighters must be able to perform
those tasks. They receive specialized training in order to be able to safely perform the functions of the
job such as entering that burning building, running up and down flights of stairs with heavy gear on, and
carry individuals to safety. These functions are essential even though they are not performed on a
regular basis.

By evaluating the positions within your organization and understanding what the essential functions of
each role are, you are better able to evaluate ADA accommodations when they arise and make
determinations on whether accommodations can be made to allow a qualified individual to perform the
essential functions of their role.

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Lorrie Coffey is a Talent Management Consultant for a small workforce development firm, Horizon Point Consulting, based in Decatur, Alabama.  She has been working in  human resources for almost twenty years, developing a specialty in employment law and compliance.  She completed the MJ-LEL program in 2022.  Lorrie can be reached at lac@horizonpointconsulting.com.

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