Apologies to those who have seen my color vision treatise before…

This is my own personal Occ Health Whack-A-Mole. It keeps popping up, and I whack it down whenever possible.

A couple of things to bear in mind:

· Color vision testing in a clinical setting is a medical test under the ADA.

· Competency demonstration in the workplace is not a medical test.

Chew on that a minute. Now a few more background things to note:

· Color vision deficiency can occur in different spectra – red-green, blue-yellow are the main types. Ishihara and most commercially available color vision screening tests are focused on red-green which is most common congenital deficiency. Point of care tests often use the yellow-blue spectrum more.

· Even if the colors you test do match those the person uses in their job (and the ADA expects you not to be doing a medical test unless it relates directly to the job function) that does not mean that they can correctly perform and interpret the test. For patient safety you still have to do a competency test.

· People with color vision deficiency can often compensate. If the test includes a key or legend, they may still be able to accurately match the key, even if what they are seeing looks olive to them instead of pink. Therefore someone who fails a color vision test still needs a competency test to determine if they can do this job function safely.

· While some color vision deficiencies are genetic, others are acquired, most often through a chronic disease process like diabetes. So if you are going to rely on color perception testing, you would need to do it periodically, not just at hire.

· Lighting is a huge factor in color vision perception. Someone with a partial deficit could perform well in a well-lit exam room where you are going screening, but be completely unable to discriminate those same colors in a poorly lit area.

In short, for color vision screening to make sense and be ADA compliant, you’d need to perform the testing in a setting that mimics their work environment, using the same colors that they would be using in the tests they perform and not just what is in the Ishihara plates, and you’d need to repeat testing periodically. And they would still need to do competency testing periodically to demonstrate that they can accurately perform and interpret the test.

I’d urge you to resist the temptation to do standard color vision screening test, and to consider doing good competency testing annually. That’s another rock to look under – what exactly the competency test entails. There should be positive and negative controls, and everyone should have adequate lighting to do the task, both in the competency test area and in the clinical area where the test is performed, which are ideally the same place.

Just my two cents, but I urge you to consider this carefully with your organization’s leadership and legal counsel. I have met with attorneys over this issue and laid out the information above, and always find that once they are fully informed, they recommend the organization not implement color vision testing.

Melanie

Melanie Swift, MD, MPH
Medical Director, Mayo Clinic Physician Health Center

Senior Associate Consultant

Assistant Professor of Medicine

Division of Preventive, Occupational, and Aerospace Medicine

Phone 507.284.2560

_______________________________
Mayo Clinic
200 First Street SW
Rochester, MN 55905
www.mayoclinic.org

From: MCOH-EH [mailto:mcoh-eh-bounces@mylist.net] On Behalf Of Tim Crump
Sent: Tuesday, August 06, 2019 5:17 PM
To: MCOH-EH
Subject: [EXTERNAL] [MCOH-EH] Color Vision testing

Hello all,

1)            How do you approach color vision testing of employees and who administers the tests?

2)            What kind of Quality Assurance is required on results?

3)            How do you handle reporting of failed tests to supervisors, both procedurally, and with respect to the implications on employees’ personal health information being shared with supervisors?

4)            Are these employees given accommodation if necessary?

5)            Care to share your policy?

Thank you for your time and any input you provide.

Tim Crump, MSN, FNP

Tim Crump, MSN, FNP

Family Nurse Practitioner

Multnomah Pavilion 1 SE, Suite 1110

Occupational Health

Healthcare Human Resources

Oregon Health & Science University

3181 SW Sam Jackson Park Rd

Mail code: UHN 89

Portland, OR 97239-3098

Department Phone: 503-494-5271

Office Phone: 503-346-1152

Fax: 503-494-4457

Email: crumpt@ohsu.edu

Mon-Fri, 7:30-4:00

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