Can rarely performed tasks still be essential job functions under the ADA?
Issue:

Barbara had successfully worked as a physician’s assistant (PA) for several years at a Utah correctional facility before a physical safety training requirement was added to medical and clinical positions that require inmate contact. Barbara is unable to fulfill this requirement because of numerous physical impairments and seeks to continue in her position without fulfilling the new requirement. She argues that certification in physical safety training is not an essential function of her position because she has performed her job for eight years without having to employ emergency training. Given that Barbara and most other employees at the prison have not had to utilize emergency training, can physical safety training certification constitute an essential job function under the Americans with Disabilities Act (ADA)?
Answer:    

The Tenth Circuit said yes. Job functions that are rarely required may still be essential for purposes of the ADA, so long as the potential consequences of employing a person incapable of performing the function are sufficiently severe. Although the emergency training was rarely performed, it was essential; the PAs had daily contact with inmates, one PA had been attacked, and the training would better equip the PAs to handle “the risks and dangers” of the environment in which they worked. Moreover, the court said, the previous attack underlined the consequences of not requiring the certification. Because the PAs had daily contact with inmates, the training was an essential, if rarely performed, function.

Source: Hennagir v. Utah Dept of Corrections (10thCir 2009) U.S. App. LEXIS 20163.
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