Employment screening practices can carry significant legal consequences when testing standards lack clear medical justification. The Union Pacific case brought national attention to how color vision testing policies may create employer liability when they disproportionately exclude qualified individuals.
At the center of the case was whether blanket color vision screening requirements were medically necessary for the roles in question, or whether they resulted in unfair disqualification without sufficient job-related justification.
Background of the Union Pacific Case
Union Pacific Railroad required certain job applicants to pass specific color vision tests as part of its hiring process. In 2016, the U.S. Equal Employment Opportunity Commission (EEOC) filed suit against the company, alleging that its testing policies violated the Americans with Disabilities Act by disqualifying qualified employees based on internal color vision standards. According to the EEOC, experienced conductors and engineers were removed or denied employment despite prior safe performance.
The legal dispute focused on whether the screening methods used were properly aligned with the actual visual demands of the job. If testing standards exceed functional job requirements, they may introduce compliance risk under federal employment laws.
This case raised broader concerns about how occupational health policies are developed and whether screening protocols are evidence-based and defensible.
The Legal Question of Liability
The central legal issue was whether Union Pacific’s color vision testing requirements violated federal disability protections. Employers must demonstrate that screening standards are job-related and consistent with business necessity. When they cannot, exposure to liability increases significantly.
Courts closely examine whether testing policies are narrowly tailored to actual workplace risks. If a screening tool over-identifies impairment or fails to differentiate severity, it may unfairly exclude capable individuals. Such practices may not withstand legal scrutiny.
The case underscores an important reality: occupational screening decisions must balance safety, fairness, and compliance obligations.
Under the Americans with Disabilities Act, employers must demonstrate that screening standards are job-related and consistent with business necessity. Courts evaluate whether testing policies are narrowly tailored to actual workplace risks.
The Role of Color Vision Testing Standards
Not all color vision tests provide the same level of diagnostic precision. Some screening methods operate as simple pass-fail tools without grading severity or distinguishing between congenital and acquired deficiencies.
When employment decisions depend on visual capability, the accuracy and structure of the testing protocol matter. Overly broad screening standards may exclude individuals who can safely perform essential job functions, while insufficient testing may fail to identify genuine safety risks.
The Union Pacific case illustrates how reliance on generalized screening tools, without clear validation against actual job demands, can increase employer liability. Courts evaluate whether testing methods are evidence-based and appropriately aligned with occupational requirements.
Broader Implications for Employers
The outcome of the case carries broader implications beyond the railroad industry. Employers across transportation, utilities, manufacturing, and safety-sensitive sectors use color vision screening as part of hiring or placement decisions.
This case reinforces the importance of:
- Aligning screening standards with documented job functions
- Using validated and defensible testing protocols
- Ensuring policies are consistent with federal disability law
- Regularly reviewing occupational health procedures
When screening standards are not clearly tied to job performance, organizations risk legal exposure, financial consequences, and reputational damage.
A Turning Point in Occupational Screening Policy
The Union Pacific case serves as a reminder that occupational health policies must evolve alongside legal and medical standards. Color vision testing cannot be treated as a procedural formality. It must be scientifically justified and proportionate to the demands of the role.
Employers who rely on outdated or overly rigid screening criteria may unintentionally increase liability. Those who adopt carefully structured, job-aligned testing frameworks reduce compliance risk while promoting fairness and safety.
Ultimately, the case highlights a broader principle: when employment decisions intersect with medical testing, accuracy, proportionality, and defensibility are not optional—they are essential.
