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What Is "Employment?" U.S. Department of Education Out of Step with Reality

by Christopher Gray

When National Industries for the Blind (NIB) hosted a meeting of the World Blind Union (WBU) a few months ago, I had the opportunity to visit the Seattle Lighthouse for the Blind and meet many people who are blind and deaf-blind who work there on federal government contracts as well as commercial subcontracts for companies like Boeing Aircraft. The many blind people I talked with expressed pride in the work that they do: They manufacture products such as easels, aircraft parts, binders and rubber stamps. Visiting and getting to know these energetic "workshop employees" brought back memories of when I worked at the Lighthouse many years ago to help pay my way through college.

I also heard many of the folks I talked with expressing bewilderment over a new federal Rehabilitation Services Administration regulation that went into effect in October 2001.

"They are trying to say that our jobs aren't real jobs," one long-time employee complained. "I make more than $15 per hour in a supervisory position and the RSA is saying that our jobs aren't acceptable 'employment outcomes' anymore, because too many blind people work here."

What an odd criterion on which to base a definition. One wonders: Would an apartment house cease to be a living space if too many blind people lived there?

I saw blind people working at all levels within the company. There are 128 blind employees working on what the Javits-Wagner-O'Day Act (JWOD) defines as "direct labor" positions, and another 25 blind people in other positions throughout the Lighthouse. In addition, there are 22 blind people who have multiple disabilities besides their visual impairments who participate in a "supported work" program. The average wage for the direct labor (production) employees is over $10 per hour. The lighthouse also offers all of its full-time employees health insurance, which includes dental coverage, life insurance and a pension plan.

Under the new rules adopted in October 2001, the Rehabilitation Services Administration calls facilities like those at the Lighthouse "non-integrated settings." The new rule says that if a disabled person chooses a job at the Lighthouse or other places it calls "non-integrated settings," then no vocational rehabilitation funds can be spent to prepare a vocational rehabilitation client for that choice. In other words, you can choose, but not that choice, if you want or need VR services. Typical services such as orientation and mobility training and job coaching are now denied to you by VR if you want to go to work in a "non-integrated" industrial setting. VR is, in all likelihood, now depriving many people who are blind and visually impaired of jobs. In addition, the rehab counselor who allows a person to choose to work in a non- integrated industrial setting at any point in the rehabilitation process is penalized, in that such a placement may not be counted as a closure -- and it is closures on which states and their employees are monitored by the Department of Education, and ultimately judged.

A Seattle Lighthouse employee, who works as a machinist, told me that it seems crazy to him that one federal agency says that manufacturing jobs or customer service jobs at the Lighthouse are not acceptable employment, but three other federal agencies consider him to be "employed": the Internal Revenue Service; the Department of Labor; and the Social Security Administration.

Furthermore, other rulings which various federal and state agencies have made over the years definitely place the settings which many of us are still calling "workshops" in the category of real employers who pay the salaries of real workers -- where workers can unionize and engage in collective bargaining with management in addition to enjoying paychecks and other benefits of real work. For example, rulings were made by the National Labor Relations Board and in the courts that jobs at NIB-related agencies in Houston and Cincinnati met the appropriate standards for "employment," and pursuant to this ruling, the Teamsters Union came to represent employees in the Cincinnati facilities and both facilities continue to have union representation today.

I'd heard that about 40 deaf-blind people work at the Lighthouse, many having moved from other states in order to find employment and to live in a friendly, nurturing environment. "For us, integration is isolation," said Debbie Sommer, who moved to Seattle from Colorado almost 16 years ago. Born deaf, Debbie now also is totally blind and communicates with the assistance of a sign language interpreter who signs into her hand. "Jobs are almost impossible for deaf-blind people to get," Debbie told me, "and if I did get another job I probably wouldn't have a tactile sign language interpreter or a TTY with braille that lets me use the telephone. And I probably couldn't participate in the company like I do here on employee committees and at meetings."

She added that in addition to the insurance, she also now gets four weeks a year of paid vacation and sick leave as well as the other benefits she values.

Roger Hilling is another long-time employee. He started working at the Lighthouse in 1974, when he was a senior in high school. "I started out as a work-study student," he remembers. "I've worked in the Dynacraft area assembling hoses for big trucks, I've made automobile jacks and hand-trucks, and I've worked in the Boeing Department with drill presses and punch presses. Once they knew my ability, I was in demand all over the place."

Three years ago, Roger was again asked to apply his talents to a new position, this time in the production of rubber stamps. "I can turn out about a hundred stamps a day," he boasts. "I assemble stamps by gluing the rubber stamp into the housing. We make both self-inking and pre-inked stamps. Our largest customer is the U.S. Postal Service. We also make stamps for the Department of Agriculture."

Roger says he makes $9.42 per hour.

Both Debbie and Roger attended college. Debbie said that she went to see what college life was like, but decided that she enjoyed working and making things much more than studying. Roger earned an associate's degree in recreation technology, but only found volunteer jobs, so he went back to the Lighthouse and has been there most of his working life, except for a year or two as a cashier with a vendor in the Business Enterprises Program. Both are active in the Seattle community and love the services -- especially public transportation -- available there. Debbie also enjoys a number of recreational activities, including snow shoeing.

As I reflect on my visit with the blind and the deaf-blind employees at the Seattle Lighthouse, it is obvious that these folks consider themselves to be employed and that each enjoys their work and the economic independence it provides. Both of the workers I have told you about received assistance from vocational rehabilitation agencies in preparation for their employment at the Lighthouse: Debbie with orientation and mobility and braille, and Roger with job coaching.

But today's vocational rehabilitation programs aren't supposed to help prepare blind people for jobs such as these any longer. Due only to a politically motivated, dogmatic agenda, blind people are being made to feel like second-class citizens. The fact that this rule was authored and promulgated primarily by administrators who are themselves blind is the height of irony -- and shame!

These looked like real jobs to me, and they feel like real jobs to the people who do them. These workers and others who aspire to work in a manufacturing setting deserve the support of rehabilitation funding, not to mention the respect of their peers. The American Council of the Blind membership agrees, both through recent resolutions on the subject and in its longstanding support for employees in industrial settings. This employment outcome rule needs to be modified so that it distinguishes between the kind of work activities that used to take place at many old-fashioned sheltered workshops, and today's good jobs available at many NIB-associated agencies across the country. There's more to arriving at a definition of a job than how many other people with disabilities work there.

The leadership of ACB is now actively engaged in several activities related to this problem. First, we are calling upon U.S. Congressional members to launch a full-scale investigation into the rule and various aspects of its application. Second, ACB is actively promoting legislation that will overturn this rule within the Vocational Rehabilitation Act itself.

Charlie Crawford, who drafted a proposed amendment to the Rehabilitation Act in consultation with me, has very aptly described the problem which the amendment seeks to ameliorate as follows: "While it is clear that the majority of blind and otherwise disabled people will choose to work in integrated settings, the Rehabilitation Services Administration at the United States Department of Education has promulgated regulations which adversely impact upon blind and other consumers having made a choice to seek employment at industrial settings with other members of their disability group wherein these individuals would earn at least minimum wage, often with benefits. RSA has not only penalized and devalued these individuals, but has further disenfranchised other individuals with disabling conditions so severe as to render them unable to work up to the level of minimum wage even though they can and do perform work of value to themselves and society. Despite a nearly 2-to-1 negative response to the proposed regulation and calls from Congress to resolve the situation, RSA has continued to impose an ideologically constructed standard rather than supporting either in the first instance the informed choice of consumers desiring to work in non-integrated settings at or above minimum wage, or in the latter instance individuals who have the ability to perform some level of meaningful work in such settings.

"We propose the following solution. The Rehabilitation Act (29 U.S.C. ch16 secs 705(11)(A) and 705 (11) (C) are hereby amended under Title I to read as follows. '(11) Employment outcome

'The term "employment outcome" means, with respect to an individual--

'(A) entering or retaining full-time or, if appropriate, part-time competitive employment in the integrated labor market, or pursuant to the informed choice of such individual, employment in the non-integrated labor market at or above minimum wage; ...

'(C) satisfying any other vocational outcome the Secretary may determine to be appropriate (including work at the sub-minimum wage level in non-integrated settings for individuals who do not qualify under section (A), or satisfying the vocational outcome of self-employment, telecommuting, or business ownership), in a manner consistent with this chapter.'"

Choice is the operative word here, and ACB intends to assure that Americans who are blind or visually impaired, or deaf and blind, or multiply disabled can make choices for themselves, by themselves, about where they want to work and the kinds of jobs that are good jobs for them, and that the vocational rehabilitation system, which has, since its inception, helped people with disabilities to acquire the skills they need to go to work, will continue doing this important work for blind and visually impaired people, no matter where we want to work and no matter how many other people with disabilities choose to work alongside us.