Vision Testing for the Safety Professional Part 2

A simple discussion with an ophthalmologist or optometrist about the job duties will give you a set of standards to be included.

Since the publication of our first article ("Vision Testing: A Blind Spot in Occupational Safety," February 2009, page 47), we have been asked many questions, and most people wanted references to the research data. Unfortunately, there is very little. It is conspicuous by its absence. This leaves us with anecdotal evidence or stories. These can be instructive and, in a conversational way, this is how we will proceed.

This article is intended to be a discussion of some things to consider that point the way to a "common sense" vision testing standard for your company.

A trip to any motor vehicle office will reveal a simple machine used to test vision. The machines are operated by motor vehicle department personnel with no specialized training. The machines can test near and far acuity, color correct sight, muscle balance, and contrast sensitivity and can test stereo depth perception and peripheral vision. These machines usually are not found in the offices of occupational physicians doing pre-placement (pre-employment) screenings. If an occupational eye examination is performed, it is only the Snellen chart that we are all familiar with that is used. "E, F, P, T, O, Z, etc."

Employers will screen an employee's hearing to obtain a baseline audiogram because it is required by OSHA (29 CFR 1910.95) for those employees who will be exposed to high levels of noise. Another pre-placement screening that should be included is vision testing.

Getting Started

Most employees had their vision screened when they first acquired their driver's license. That may have been three, 15, or 25 years ago. They have changed. They may now need corrective lenses to drive. However, because the initial driver's license does not require it, most employers will not require it. Instead, they rely upon the driver's license.

The first thing to consider is, can a driver see? Cautionary tale number 1: A large New Jersey employer was sent an out-of-state employee for training whose duties required nighttime work occasionally. When these duties were explained, the employee took out his Okalahoma driver's license, which said "Daylight Driving Only." According to Okalahoma regulations, he could not drive at night or even early mornings or evenings in the winter months. What can a company do? The company sent him for a New Jersey examination and driver's license. Lo and behold, the employee passed his test, and New Jersey issued him a license with full driving privileges. The employer, however, was now on notice that the employee was at risk while driving in the winter months to and from work. Moral: Do not rely on the driver's license as your vision screening. New Jersey has a very poor record.

In fact, in New Jersey there are more than 450 drivers driving with binoculars glued to their glasses. So the second thing is to find out is, what are your state's vision requirements to drive a motor vehicle?

All states have vision requirements; some are better than others. West Virginia recently passed a law mandating that all license renewals beginning in January 2009 would include a vision screening requiring better than 20/40 vision in the better eye.

New York state is similar, with a 20/40 requirement and a minimum acceptable horizontal, binocular field of vision of 140 degrees. New York also allows drivers to wear telescopic lens. What does your state allow?

How Many Eyes?

Does your applicant have two eyes or just one? Drivers with monocular vision have higher rates of collisions and traffic violations. With only one eye, depth perception may be impaired or even impossible. If the job duties require driving or operating any type of equipment, then you should have a standard vision screening included in the pre-placement physical. The test should include visual acuity, color correct sight, depth perception, contrast sensitivity, and peripheral vision.

A simple discussion with an ophthalmologist or optometrist about the job duties will give you a set of standards to be included. The tougher part is existing employees and adding a vision-testing component.

American employers often rush employees out for drug or alcohol testing after an accident. Add a vision testing requirement after any accident, and you may find that employees who have passed drug and alcohol tests need a referral after a standard eye exam.

What Caused the Accident?

More anecdotal evidence: A large electric utility routinely had a few drivers, randomly selected as they drove out of the gate each morning, run their vehicles through a short course of traffic cones. One longtime employee of the company failed this driving test. In addition to the drug and alcohol test, this time, for the first time, the company sent the employee for a vision test.

The employee had suffered a stroke, was blind in one eye, and was partially paralyzed on one side. He had hidden the condition from the employer. The employee passed the drug and alcohol test. A simple $100 exam saved that company from a probable high-dollar collision suit.

This incident raises the question, do you have an affirmative requirement that employees inform you of any medical condition, including visual deterioration if it would adversely affect safe operation or performance? Many employers hand out a policy that requires that the employee report the use of medications; how about adding a vision requirement to this same document? The employee must report any adverse medical conditions, including a change in vision that may prevent safe operation or practice.

Another commonly abused area is contact lenses. Do you know which employees wear contact lenses? If vision is critical to safe operation or practice, do you have an affirmative requirement that employees who wear contact lenses must have glasses available at all times in the event of the loss of a contact lens?

Another anecdote: We have found employees who self-limit their own personal driving by coming to work with a co-worker driving. Yet that same employee drives a forklift and attempts to make it through the day with macular degeneration! Employees hide vision problems, even from loved ones. (While preparing this article, I learned a close personal friend was driving all over the state with cataracts that he was afraid to have addressed. He said, "I learned to see around them.")

A major pet food company held a vision screening as part of a health fair. Among the employees who were tested, about 25 percent were told to get eye examinations due to a problem with their vision, and a large percentage of that group was quality control employees. What critical jobs do you have at your facility, and can your quality control personnel read their gages and dials correctly?

Electricians

Falls, especially among electrical contractors, may be related to vision. Robert Sagendorf, safety director of Eii, Inc., a large New Jersey-based electrical contractor, has an electrician with bifocals installed at the top of his glasses. Why? When working on a ladder, he finds the close wiring tasks are easier to see without craning his neck backward to see the connections.

How many falls from ladders have been as a result of receiving a shock? How many electrocutions have resulted from individuals reaching right past the work area and striking a primary electrical source? Color correct sight and depth perception are critical to an electrician. In low-light situations, wiring colors can be very problematic. Talk to your electrician about how difficult it is to see close work from the top of a ladder.

Do you have visual traps in your workplace? Take the employee who drives a forklift off the dock. We may say it was inattention, driver speed, or blocked vision. However, if we have a slate-gray sky, a gray parking lot, and a gray industrial paint on the dock floor, is it possible we created a situation that was bound to create a problem. Ask your employees who have added little magnifiers to the bottom of their safety glasses if this has ever a problem: walking down stairs or on the last step of a stepladder. We wonder how an employee could have fallen off a leading edge or missed a rung while climbing a tower, but we rarely, if ever, question an employee's vision.

Will electricians without the ability to see red or green have a problem with a complicated wiring project? Will chemical operators without this same ability be able to titrate a solution and understand if it is within specifications? Will a doctor with contrast sensitivity issues misread an X-ray? Will your inspector who reviews the required X-ray of a weld miss a flaw because he has contrast sensitivity issues? If our process requires visual inspections, we should have a discussion with our occupational physician about the visual requirements of the job of the inspector, the operator, and the electrician.

As your human resources staff completes the required physical requirements of a job description, it also should consider how much visual work is required. Ask these questions:

Does the employee need two eyesto properly do the work?
Is color correct sightrequired?
How much "useful field of view" (seeing side to side and up and down) is critical?

This is the important information that should be gathered before the employee is hired.

On Feb. 9, 1996, two New Jersey Transit commuter trains suffered a nearly head-on collision and derailment. Deteriorating color correct vision was cited by the NTSB. Federal railroad rules require that each railroad test the vision of locomotive engineers. They must test initially when they receive their certification and at periodic intervals no longer than every three years. (49 CFR 240.121 and 240.207)

Next Step Forward

Require a vision test for all new hires. Require vision testing of current employees on a periodical or random basis and after any accident. If the employee needs a license to operate equipment such as a forklift or an over-the-road vehicle, ensure that as part of their training they have a vision test, then periodically thereafter. Always test vision after any collision, crash, or accident.

Start with inspectors. It is implied in their very title that they have the requite vision to detect the defects for which they are inspecting. If you never tested their vision, however, how do you know they can properly test your products?

Add drivers next, including salespeople, then new hires, and so on. Turn a negative into a positive: Let prospective clients know that you test vision as well as health, and you just may gain a slight competitive advantage. Unions all over the country learned this same lesson with drug testing and OSHA safety courses. When employers hire a union worker from a hall, they can be assured he or she is in a random drug testing pool and has received at least 10 hours of OSHA awareness training. Vision testing is no different. Those who have been tested and have the necessary corrections are safer than those who are hiding cataracts, macular degeneration, strokes, diabetic retinopathy, or injuries.

Finally, if you cannot agree on a standard for your company to use, the federal motor carrier regulations has a pretty good standard:

A person is physically qualified to drive a Commercial Motor Vehicle if that person has distant visual acuity of at least 20/40 (Snellen) in each eye without corrective lenses or visual acuity separately corrected to 20/40 (Snellen) or better with corrective lenses, distant binocular acuity of at least 20/40 (Snellen) in both eyes with or without corrective lenses, field of vision of at least 70º in the horizontal meridian in each eye, and the ability to recognize the colors of traffic signals and devices showing standard red, green, and amber (49 CFR 391.41(b)(10)).

Here you see two good eyes with an angle of view and color correct sight. What is needed in your organization? It's about time the safety profession learns how to see.

Homework Assignment

Read the situation and send your comments to RegulatoryMavin@yahoo.com. We'll post the best of them in a future issue.

You are the president of an emergency squad, and one of your ambulances drivers suffers an enuclation (removal of the eyeball) of his right eye. After his return to work, he still wants to be a volunteer and insists he can still drive the ambulance. What do you do? Do you let a one-eyed driver drive an ambulance at high speed, in bad weather, at night? What policy should you have in your by-laws to address this situation?

This article originally appeared in the June 2009 issue of Occupational Health & Safety.

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