before personal protective equipment or worker training may be considered. A more fully elaborated version of the hierarchy of controls places protective measures in the following order of preference:

  1. engineering controls (e.g., elimination, ventilation, mechanical guarding);

  2. administrative controls (e.g., safe job procedures, job rotation);

  3. personal protective equipment (e.g., respirators, ear plugs);

  4. individual behavior (e.g., safe lifting techniques); and

  5. warnings (e.g., labels, bells).

While these hierarchies vary in their detail, they tend to share at their core the notion that methods of protection that do not rely primarily on individual employee behavior alone are preferred to those that do.

Extending the legal and ethical perspective and the goals of maintaining a safe and healthful work environment, however, leads inevitably to varying interpretation of the extent to which health promotion, treatment, and rehabilitative services—crucial to the general health status of older workers—should be provided at or through the workplace. This is in addition to worker education and training, retraining for changing job tasks, and the many other activities that are offered at or through the workplace. A wide variety of employee interventions to maintain and improve health and safety have been established over many decades, albeit usually not universal in coverage, and new delivery and experimental programs are continually appearing.

The Americans with Disabilities Act (ADA) is one law that anticipates and addresses the hierarchical approach by requiring job interventions and accommodations. The ADA protects workers if they have a disability that substantially limits one or more major life activities but they are able to perform the essential functions of the job with reasonable accommodations. Accommodations under the ADA require that employers make existing facilities readily accessible and usable, and that they restructure jobs or modify work.

While older workers are more likely than younger ones to have disabilities covered by the ADA, the need to accommodate older workers goes well beyond these covered limitations. This chapter considers accommodations in the broadest fashion. For example, Burkhauser, Butler, and Kim (1995), using a proportional hazards analysis with data from the 1978 Survey of Disability and Work, found that provision of an accommodation, defined broadly, slowed worker withdrawal from the workforce and delayed the beginning of SSDI payments. Potential recall bias in these studies might be addressed in a longitudinal study, using data now available from the Health and Retirement Study. No studies have examined whether workplace ac-



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