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Advances in Social Sciences Research Journal – Vol. 8, No. 3
Publication Date: March 25, 2021
DOI:10.14738/assrj.83.9877. Iyundhu, A, Karooma, C., & Emong, P. (2021). Complying with Reasonable Accommodation Requirements for Persons with Visual
Impairment in Uganda Public Service Employment? Assumptions and Gaps. Advances in Social Sciences Research Journal, 8(3) 632-
651.
Complying with Reasonable Accommodation Requirements for
Persons with Visual Impairment in Uganda Public Service
Employment? Assumptions and Gaps
Iyundhu Andrew
Department of Community & Disability Studies,
Faculty of Special Needs & Rehabilitation of Kyambogo University, Uganda
Karooma Cleophas
Department of Planning and Governance,
Faculty of Interdisciplinary Studies of Mbarara University of Science & Technology, Uganda
Emong Paul
Department of Community & Disability Studies,
Faculty of Special Needs & Rehabilitation of Kyambogo University, Uganda
ABSTRACT
Uganda has got legal and policy frameworks that guarantee the
provision of reasonable accommodation in employment for persons
with disabilities, persons with visual impairment inclusive. The
available literature indicates that persons with visual impairment
remain largely disadvantaged in public service employment despite
the progressive disability legal and policy framework in the
employment. The paper examines the Uganda public service
employment compliance with provisions of reasonable
accommodation for persons with visual impairment. This paper
arises from a study on access to and inclusion of persons with visual
impairment in public service employment in Uganda. The study
adopted a qualitative research approach. Twenty-two [22]
participants were interviewed and included persons with visual
impairment in public service and their direct supervisors from four
districts of Jinja, Kampala, Iganga, and Mbarara, officials from Public
Service Commissions, National Council for Disability, and Uganda
National Association of the Blind. Data was obtained using interviews
and observation and analyzed using thematic analysis. The results
show the gaps and assumptions in the provision of reasonable
accommodation requirements for persons with visual impairment in
employment and have effects in the provision of auxiliary and
support services, modification of working environment & facilities,
making information accessible, modification of job application
procedures, restructuring work systems, provision of housing,
among others.
Keywords: persons with visual impairment; reasonable accommodation;
Uganda public service employment; requirements
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Iyundhu, A, Karooma, C., & Emong, P. (2021). Complying with Reasonable Accommodation Requirements for Persons with Visual Impairment in
Uganda Public Service Employment? Assumptions and Gaps. Advances in Social Sciences Research Journal, 8(3) 632-651.
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URL: http://dx.doi.org/10.14738/assrj.83.9877
INTRODUCTION
Uganda has got progressive legal and policy frameworks guaranteeing a right to employment to
all qualified persons with disabilities without discrimination and is based on equal opportunities.
Uganda has also ratified the CRPD and as such must abide by its human rights standards on
inclusive employment. Both the CRPD in article 2 and the Persons with Disabilities [PwD] Act
[2019] section 9 stresses the provision of a reasonable accommodation to persons with visual
impairment in employment for them to perform their work tasks like any other employee.
Reasonable accommodation means the necessary and appropriate modifications and
adjustments not imposing a disproportionate or undue burden, where needed in a particular
case, to ensure to persons with disabilities the enjoyment or exercise on an equal basis with
others of all human rights and fundamental freedoms [CRPD, 2006, art.2]. In regards to the
inclusion of persons with visual impairment in employment, reasonable accommodation means
the necessary and appropriate modifications or adjustments done to a job or work environment
where needed in a particular case to enable a qualified applicant or worker with a disability to
participate and enjoy all privileges on an equal basis with other ordinary employees without
causing a disproportionate or undue burden to the employer in the entire employment process
[PwD Act, 2019, s. 9].
The phrase 'reasonable' in the provision of accommodation as indicated in both the CRPD and
PwD Act is a reference to its relevance, appropriateness, and effectiveness for the person with
the impairment. Thus the accommodation is reasonable only when it achieves the purpose for
which it is being made, and is tailored to meet the requirements of the person with the
impairment. Also, the phrase ‘disproportionate or undue burden’ means that the request for
reasonable accommodation needs should not cause an excessive or unjustifiable burden on the
employers.
The provision of reasonable accommodation for PwDs in employment amounts to modification
of working environment & facilities, restructuring work systems, assigning different places of
work, modification of the equipment, provision of auxiliary and support services, modification of
job application procedure, making information accessible, among others [United Nations Enable,
2006; CRPD, 2006 art. 9; PwD Act, 2006, s.9; Oire, 2013; Holland et al., 2017].
Globally, 15% [approximately 1.1billion] of the world's population are persons with disabilities
[WHO, 2015]. It is also estimated that 253 million persons have a visual impairment, of which 36
million are blind, and 217 million have moderate visual impairment globally [WHO, 2015; IAPB,
2015]. In Uganda, persons with disabilities constitute 12.4% [approximately 4.5 million] of
Uganda's total population and of which 6.1% [approximately 2.1 million] are persons with visual
impairment [Uganda Bureau of Statistics [UBOS], 2016a].
The available literature indicates that more persons with visual impairment are attaining the
minimum required academic qualifications to be able to seek employment including in public
service in Uganda [Emong, 2014; UBOS, 2015; UBOS, 2016b]. It is also evident that any PwD who
possesses the relevant academic qualification has a right to seek and be employed in the public
service as provided in both the United Nations human rights laws and conventions, and Ugandan
laws on disability. The CRPD [2006] in article 27 obligates States to recognize the rights of PwDs
to work on an equal basis with others. In so doing the CRPD requires States to provide PwDs the
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opportunity to gain a living by work freely chosen or accepted in a labor market and work
environment that is open, inclusive, and accessible. According to Nyombi and Kibandama [2014],
and Griffiths et al. [2018], the implementation of the provisions of reasonable accommodation
guaranteed by the United Nations Conventions, and Ugandan laws has been a challenge in
Uganda. This is justified by the available literature that shows that persons with visual
impairment experience challenges in public service employment processes in Uganda. They
work in the unmodified workplace environment, information on available job opportunities are
in most cases not in an accessible format, and excluded from employment opportunities such as
confirmation and promotion in their employment careers among others [Coffey et al., 2014;
Nyombi & Kibandama, 2016; Bonaccio et al., 2019].
LITERATURE REVIEW
This study is guided by the theoretical understanding that reasonable accommodation is one of
the standards of attaining equality and non-discrimination for persons with disabilities based on
equal opportunities. In the introduction, the concept of reasonable accommodation has already
been explained. It entails the provision of modifications or adjustments to enable persons with
disabilities to enjoy or exercise all human rights and fundamental freedoms on an equal basis.
Equality and Non-discrimination
The concept of equality and non-discrimination are human rights standards based on the idea of
the inherent dignity and inalienable rights of every human being [UDHR 1948, Preamble & art.1].
It is guaranteed in human rights law internationally, the Charter of the United Nations, UDHR
[1948, arts. 1 & 2], ICESCR [1966, art. 2], ICCPR [1966, art. 2], and CRPD [2006, art. 2]. In
particular, article 1 of the UDHR [1948] states that all human beings are born free and equal in
dignity and rights.
The Concept of Equality
According to commentaries, the concept of equality is understood in three ways, i.e., formal
equality, equality of results, and equality of opportunity [Coleman, 1973; Degner & Quinn, 2002;
Lawson, 2011; Segall, 2013; Fredman, 2016]. The three conceptions of equality provide
perspectives on how persons with visual impairment experience employment. These are
explained below.
Formal Equality
Formal equality entails equal treatment in a similar environment [Hardie, 1980; Fredman, 2002].
This understanding of equality prohibits direct discrimination based on someone's
characteristics. In that way, it protects persons with a visual impairment from being
discriminated against based on disability. Thus in employment, a qualified person should be
subjected to similar treatment in employment. In the context of disability inclusion and with
specific reference to persons with visual impairment, formal equality requires that persons with
visual impairment are entitled to employment opportunities in the same manner as other
ordinary persons in the country. The limitation of formal equality is that it is merit-based.
Therefore it doesn't emphasize the provision of reasonable accommodation required by persons
with visual impairment to perform work tasks like other employees in the same working
environment.
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Iyundhu, A, Karooma, C., & Emong, P. (2021). Complying with Reasonable Accommodation Requirements for Persons with Visual Impairment in
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Equality of results
Equality of results means treating individuals based on their groups to realize equal outcomes
[Coleman, 1973; Lawson, 2008; Lawson, 2011; Fredman, 2016]. It is concerned with achieving a
fairer distribution of benefits or results and examining discrimination with outcome analysis
[Lawson, 2011; Fredman, 2016]. The equality of results is being implemented through
affirmative action.
In Uganda according to the Constitution of the Republic of Uganda [1995, art. 32], affirmative
action means deliberate action taken in favor of groups marginalized based on gender, age,
disability, or any other reasons created by history, tradition, or custom to address imbalances
that exist against them. In employment, there is affirmative action. The PwD Act [2019] section
14 [1] states that to uphold the fundamental rights and freedoms of persons with disabilities, the
Government shall promote a policy of affirmative action for persons with disabilities including
employment of persons with disabilities in the public service. The Employment Act [2006]
subsection 6[4], states that any distinction, exclusion, or preference in respect of a particular job
based on the inherent requirements of that particular job shall not be deemed to be
discrimination. The Uganda Employment Policy [2011] section 6 [6.7] states that the policy shall
promote affirmative action, adequate safety nets, and social protection for the poor and
vulnerable groups to hedge tasks associated with the operation of the market system.
The limitation of equality of results is that affirmative action policies mainly address
discrimination at the entry point and leave the discrimination intact beyond that point. Thus it
doesn’t address the systemic barriers that exclude persons with visual impairment in
employment. Also, it pays little attention to accommodate human diversity by adapting existing
structures, i.e., distinctions such as sex, religion, birth, disability, among others.
Equality of opportunity
Equality of opportunity is about providing appropriate ways to eliminate all forms of structural
or institutional discrimination, i.e., it rejects all policies that tend to bring about discrimination
by focusing mainly on outcomes in the form of quantitative results [Lawson, 2008; Fredman,
2010; Elford, 2013; Segall, 2013; Emong, 2014]. In the context of disability inclusion, it involves
a holistic approach aimed at promoting PwDs’ rights without excluding them from mainstream
society. Thus it requires the removal of systemic barriers in the employment institutions that
affect persons with visual impairment to carry out work tasks. According to Nyombi and
Kibandama [2014], and Wickenden et al., [2020], PwDs experience discrimination in the
recruitment and selection processes, exploitation, and being employed in the lowest status jobs.
They are denied workplace opportunities related to assignments, job counseling, and job training
opportunities [Sundar et al., 2018; Graham et al., 2019]. Persons with visual impairment
experience difficulties in accessing environment and buildings which are inaccessible because
they have problematic design and do not have facilities such as elevators, ramps, lifts and where
the lifts exist, some have technological constraints for instance not having talking devices to
enable a blind person access information or clear direction in Uganda [Clayton et al., 2012;
Barclay et al., 2012; NUDIPU, 2014; Narayanan, 2018]. To Wahidin et al. [2018], employees with
visual impairment experience a challenge of accessing information shared by employers and
colleagues as it is always put in inaccessible formats of print, among other systemic barriers.
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Therefore, the challenge with equality of opportunity is that it doesn't prepare persons with
visual impairment to get proper treatment in employment. Also, it takes a long period to address
systemic barriers that exist within the employment institutions.
The Concept of Non-discrimination
According to article 2 of the CRPD [2006] discrimination based on disability means any
distinction, exclusion, or restriction based on disability that has the purpose or effect of impairing
or nullifying the recognition, enjoyment, or exercise on an equal basis with others of all human
rights and fundamental freedoms. This understanding captures all discriminatory factors against
persons with visual impairment in employment, such as intentional discrimination, disability
unfriendly practices, criterion, policy-related among others.
In Uganda, discrimination is understood as giving different treatment to different persons
attributable only to their respective description by sex, race, color, ethnic origin, birth, creed or
religion, social, culture, geographical, economic standing, political opinion or disability, or any
combination of the above [Constitution of the Republic of Uganda, 1995, art. 21; PwD Act, 2019,
s. 9; Employment Act, 2006, s. 6].
In regards to the employment of persons with disabilities, the PwD Act [2019] s.9, the acts of
discrimination include based on the disability the employer refusing to accept an application
made by the PwD who qualified for the job, the conditions for applying for the job or the selection
criteria exclude applications by PwDs, the assessment of the performance of an employee with a
disability is conducted in a manner that does not correctly gauge the performance of that
employee, the remuneration or benefits that given to an employee with a disability is less than
that given to the other employees who perform similar tasks. It also includes an employee with
a disability not considered for promotion, on the job training, scholarships, or any other benefits
that are accorded to the other employees; based on the disability, an employee with a disability
is transferred from a job or task which he or she is capable of performing to another job or task
which he or she is unable to perform due to his or her disability; the employer does not provide
reasonable accommodation required by the employee with a disability to perform his or her job
tasks among others [PwD Act, 2019, s. 9].
To promote non-discrimination, article 5 of the CRPD [2006] obligates state parties to recognize
that all persons are equal before and under the law and are entitled without any discrimination
to the equal protection and equal benefit of the law. It also obligates state parties to prohibit all
discrimination based on disability and guarantee to PwDs equal and effective legal protection
against discrimination on all grounds. In Uganda, and with regards to non-discrimination in
employment, the PwD Act [2019] Section 9 states that an employer shall not discriminate against
a person with a disability, based on the disability of that person. Section 9 of the PwD Act also
states that an employer shall in any advertisement for a job, where appropriate, encourage
persons with disabilities to apply for the job, provide an applicant with a disability who applies
for a job reasonable accommodation necessary to undertake the job interview and provide an
employee with a disability reasonable accommodation in the performance of the job or tasks.
The understanding of the concept of non-discrimination as provided in the CRPD and PwD Act as
explained above covers both direct and indirect discrimination. In the context of direct
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Sampling & Sampling Technique
This article is derived from the Ph.D. thesis which employed twenty-two participants. The
numbers of participants selected per category are as follows: Persons with visual impairment
were fifteen and of which ten were employed by public service, while five were seeking
employment. The officials from organs constituting public service were three and of which one
official was selected from the Public Service Commission, and two from District Service
Commissions. The study involved two direct supervisors of persons with visual impairment in
their employment. Besides, one participant was selected from the Uganda National Association
of the Blind, and one official from the National Council for Disability.
The qualitative research approach was used and the purposive sampling technique was
employed to select all participants of the study. The technique was appropriate for this study
because the participants selected were those knowledgeable enough to providing information
regarding the problem under study. Also, the snowball sampling technique was used to select
persons with visual impairment employed by public service and it was appropriate given the fact
that their details were not known.
Data Collection
The unstructured interview guides with open-ended questions were used to collect data and
were preferred because they allowed flexibility in data collection and to obtain in-depth
responses elicited through seeking clarification and probing on the responses that were given
[Mason, 2018; Creswell, 2013]. The instrument also allowed the researcher to record the
participants' responses using a voice recorder that helped to make comparisons with the data
that was collected through note-taking while interviews went on. The non-participant
observation method was also used and it involved designing an observation checklist that guided
the observation, consisting of aspects to be observed such as; adaptations made in the workplace
environment, accessibilities like ramps, walk-ways, stairways with rails, leveled environment
with no dangerous objects, and auxiliary services. The method enabled observing the
preparedness of the employment agencies to accommodate employees with visual impairment.
Data Analysis and Presentation
The thematic analysis strategy was employed to analyze data. It involved transcribing the
information from the field, reading through several times the findings, listening to audio
interviews for further evidence, and overall understanding. The sub-themes from the transcripts
were generated to ease data analysis. The next step was to write reflective explanations on each
of the sub-themes identified in the transcripts. The process involved thorough reading through
the transcripts several times while reflecting on the subthemes that relate to the research
question. The process was so helpful in that the information that was not objectively considered
in the process of transcribing was identified and revised. The findings of this study are presented
in form of an analytic narrative with quotations from the participants' reports for each of the sub- themes identified. This is followed by the interpretation and discussion of the findings.
Ethical Considerations
The study obtained approval from the Research Ethics Committee Board of Faculty of
Interdisciplinary Studies, Research Ethics Committee of Mbarara University of Science &
Technology, and Uganda National Council for Science & Technology. All the participants took part
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in the research voluntarily after having been informed about the details of the research and their
rights, as was stated in the informed consent. The pseudo names were generated and have been
used in this paper to ensure the anonymity of the participants, in addition to their positions being
safeguarded to protect them from being traced for the information given.
RESULTS AND DISCUSSION
The results and discussion is structured in the following ways: provision of auxiliary and support
services, modification of working environment & facilities, making information accessible,
modification of job application procedures, restructuring work systems, provision of housing to
employees with visual impairment, and provision of job training opportunities.
Provision of auxiliary and support services
Participants expressed that the provision of reasonable accommodation is a challenge in public
service and they acknowledged that it is an emerging issue that needs to be considered in public
service employment in order not to disadvantage persons with visual impairment. Participants
also stated that it has not been conceptualized and fully applied in public service employment in
Uganda. A participant [VIE.5] affirmed that:
The public service structure doesn't have a provision of reasonable accommodation, what the
public service does is, appoint you, deploy you, and provide a salary but it doesn't have any other
special considerations. There is nothing special for PwDs but they have other incentives for other
people like science teachers and those who are working in hard-to-reach areas they have some
allowances added to their pay but for persons with special needs, no there is nothing additional.
Another participant [VIE.1] lamented that:
The situation of employment for persons with visual impairment in Uganda is not yet the best
because when you look at our policies, like the PwD Act, it says that the government or employers
shall provide auxiliary aids like readers, software in computers, support assistants like teaching
assistants, but this has not yet been implemented which has made work a little bit hard although
we persons with visual impairment persist on.
The above expressions show that the provision of reasonable accommodation for persons with
visual impairment is not known in public service. To affirm this, participants revealed that there
is no provision in the policy guidelines of public service that calls for the employment of support
assistants such as sighted guides, or Braille transcribers and such positions are not in the
establishment of public service. Participants also revealed that the application forms and in
particular public service form 3 [Revised 2008] does not have a provision for the disability type
to enable the employers to know and prepare in advance for the applicant with a disability to
plan the necessary modification and auxiliary services that may be required by the employee
with visual impairment. One of the employers [DSC.1] acknowledged that:
Unfortunately, the employment of the sighted guide for persons with visual impairment is not
provided for in the policy guidelines of public service. For instance, you are saying if we recruited
a head-teacher who is blind, is there somewhere in the structure where we should employ
another support staff to be in charge to support this head-teacher? I think that has always been
handled administratively, I would like to mention that even in the Local Government Council V.
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We have one of the councilors who is blind. We have already provided her with support staff and
the council is meeting the expenses for the support staff. So while I accept that there are no
provisions in the structure specifically for that kind of arrangement, administratively it has
always been possible.
A participant [VIE.1] expressed that:
First of all, I don't think there is room for provision of reasonable accommodation in the policy
guidelines of public service because I remember when I was still chairperson of the council for
disability in the district, we carried out a study on access to employment by youth with
disabilities and members of the District Service Commission were saying that 'you know for us
we can realize that someone has got a disability on the onset of appearance before the panel but
at the time of applying one cannot know because the application form doesn't have a slot that
requires for one to know that this person is visually impaired so that they could either get
somebody to guide you to and from the panel when you come alone to appear for interviews, this
is secret for you, come along with a person who can help you and after you have faced the panel
you go and maybe when the results are out and you are among the successful person again there
is a way how you are notified'. But, from experience and the number of interviews I have
attended, and the times I have interacted with several people, both in commission and the
interviewees, I don't think there is anything.
The above expressions mean that public service is not proactive in providing reasonable
accommodation for persons with visual impairment. They instead react or prefer providing it
only when they are confronted with the situation of receiving an applicant with visual
impairment or when he or she has reported for work and expresses a need. Participants' opinions
were that because of the limited recognition of the provision of reasonable accommodation in
public service employment, it is disadvantaging and indirectly discriminating against persons
with visual impairment during interviews. Participant [VIE.2] lamented that:
The provision of reasonable accommodation is not in the structure or policy guidelines of public
service and to know that it is not there, at this time if a visually impaired person goes for an
interview you cannot find that the laptop or typewriter is there if you are to write what is to be
written, so indirectly that is a way of eliminating you; two, they always have interviews of two
kinds-oral and written aptitude, now when you reach there for you, you know Braille and the
others like those who are deaf don't know Braille, they don't even have time to wait for you to go
and type this and that, so you are eliminated indirectly because those provisions are not there.
Another participant [VIE.4] lamented that:
You know those members on the District Service Commissions sometimes when they look at you
they see a real burden because when you go there for interviews and you tell them that if am to
get employed, I need this place to be disability friendly, they take that to be costly to them and
thus see it as a burden. Then if you ask for a personal assistant or computers with jaws, they look
at it as a burden and it may be hard for you to go through and obtain the job.
The expressions above mean that provision of reasonable accommodation is a new concept that
needs to be understood and be inculcated into the policy guidelines of public service. Whereas it
is trying to be appreciated, the practice is reactive. The expressions also show that whereas
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public service may be willing to provide support staff such as sighted guides to employees with
visual impairment, the policy guidelines do not provide for it and it appears public service does
not know how much could be done because for one to be employed he or she must have an
academic qualification, which is not clear for those serving as sighted guides. Also when
somebody is appointed he or she is supposed to grow within public service through promotion.
But when it comes to a personal assistant like a sighted guide, how is he or she supposed to grow
within that line. The above finding concurs with Graham et al. [2019] who revealed that persons
with visual impairment lack assistive aids attributed to the systematic delays in accessing and
provision of assistive technology, which limits their effective performance at the workplace. The
finding contravenes article 9 subsection 2[e] of the CRPD [2006] which obligates state parties to
undertake appropriate measures to provide forms of live assistance and intermediaries,
including guides, readers, and professional sign language interpreters, to facilitate accessibility
to buildings and other facilities open to the public. The finding further contravenes with the PwD
Act [2019], in section 9 subsections 2[c] which states that an employer shall provide an employee
with a disability reasonable accommodation in the performance of the job or task. The above
finding and literature show that the lack of provisions of reasonable accommodation for persons
with visual impairment in public service structure is a challenge. Therefore there is a need for
Disabled Persons Organizations [DPOs] and other stakeholders to furnish public service with
relevant information regarding the employment of support staff such as sighted guides including
the required academic qualifications to be considered. Also, it requires a change of the laws and
policy guidelines used by public service to include the provision of reasonable accommodation
for PwDs.
Modification of the working environment and facilities
Participants mentioned that persons with visual impairment require modification of the
workplace environment to enable them to perform their tasks. In the process of data collection,
the situation of unmodified workplace environment was observed in some places, characterized
by potholes, broken pieces of bricks, and lack of demarcations on the compound of workplaces,
making the mobility of workers with visual impairment difficult. Also, some of the buildings were
old, with broken verandas & floors, and having no ramps among others, and thus could not be
accessed by persons with visual impairment easily and safely. One of the direct supervisors
[DS.1] acknowledged that:
The environment here is terrible, in fact when you look at how the classes and the verandas, even
you having sight, the environment is very dangerous. But they keep on moving, at times they fall
off but they have nothing to do since we don't have enough money for renovation.
Another participant [VIE.3] lamented that:
In public service employment, workplace physical accessibility is a problem. You may find there
are stairs that you may not be able to climb, no lifts, even when the lifts are there, they don't talk,
you know we have talking lifts these days that notify of the level or floor you are at. Besides white
canes are not provided so that you can easily navigate through a working premise.
The above expressions show that public service employment is not proactive in the provisions of
a reasonable accommodation to persons with visual impairment and as such modification of the
working environment has not been catered for to enable them to perform their tasks. However,
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whereas employers need to make necessary modifications in the workplace environment and
facilities, this may be limited given that it has financial implications and employers may take it to
be a burden. The finding is in agreement with Clayton et al. [2012] who affirms that PwDs
experience a challenge of the unmodified physical environment at their workplaces in Uganda
and thus face difficulties in accessing the environment and buildings at workplaces which are
inaccessible because they have problematic design and do not have facilities such as ramps, lifts
and where the lifts exist, some have technological constraints for instance not having talking
devices to enable a blind person access information or clear direction. The finding contravenes
with the CRPD [2006] in article 9 subsection 1[a] that obligates state parties to take measures,
which include the identification and elimination of obstacles and barriers to accessibility of
buildings, transportation, and other indoor and outdoor facilities, including schools, housing,
medical facilities, and workplaces. Therefore, employers in public service need to ensure that
they become both proactive and reactive in the provision of reasonable accommodation for their
employees with disabilities in regards to providing necessary modifications to enable them to
perform their duties like others. Given that the provision of reasonable accommodation may
require funds, the Government and other civil society organizations need to provide some
financial support to employment agencies to facilitate the provision of reasonable
accommodation for PwDs.
Making information accessible
Participants expressed that job advertisements are in most cases made general and not
disability-inclusive in that no specification is indicated targeting persons with visual impairment.
It was mentioned that job adverts are made without any statement encouraging PwDs to also
apply and in most cases put in a format that is not accessible such as in printed Newspapers, on
memos and circulars pinned on notice boards which are in print and not in Braille, making
persons with visual impairment to only rely on friends to get information. One of the employers
[DSC.1] expressed how information on available jobs is disseminated:
When it comes to publicity or dissemination of information on the available job vacancies, we
have tried to publish this information as much as we can. We utilize notice boards of head-quotas
and lower local governments, in addition to the national gazette or the national newspapers and
I believe even a person who may not be having sight, even where the Braille is not possible a
friend can be able to give information. So that is how at least we publicize adequately.
Another participant [VIE.10] expressed that:
I can say that the way or the procedure they use to advertise for jobs doesn't favor all of us
because most times they don't use audio advertisements, they put in newspapers of which I can't
read print. If I don't hear people who may be talking or I don't have a connection with people in
the district I may not get the information. It is rare to find job advertisements on radio that this
district is advertising and this number of teachers is encouraged to come and apply, no. Recently
they advertised for head-ship, those who want to become head-teachers and deputy head- teachers but it was mysteriously, I got information when people had been called for interviews
yet if I had papers that mean I would have missed. So the way how they advertise, the procedure
is not all that good because it doesn't favor all people.
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The deployment is handled by the Chief Administrative Officer’s office but they consider the place
that is easy to reach, easy to stay for the PwD. Then here of-course they look at the setting for
example if he or she is an office attendant they look for a convenient building for that person to
work in because we also have storied buildings. Also, at least for people who are blind or
physically disabled they have tried to make access to buildings comfortable, they try to avail them
with comfortable chairs and desks, you know this is Local Government we try to provide at least
the basics.
The above expressions indicate that whereas the public service guidelines have to be observed
and given that they are limited in disability concerns, employers may be flexible and provide it
by discretion. However, this may be dependent upon the willingness of employers and as such
there can be no guarantee that every time concerns of employees with visual impairment shall
be taken care of. The finding is in line with section 6 [1] of the Employment Act [2006] that
obligates all parties including the Minister, labor officers, and the industrial court to seek to
promote equality of opportunity to eliminate any discrimination in employment. The finding also
concurs with article 5[3] of the CRPD [2006] which states that to promote equality and eliminate
discrimination, and to take all appropriate steps to ensure that reasonable accommodation is
provided. Whereas the laws provide for the provision of reasonable accommodation for
employees with visual impairment, this has not been embraced by the public service
employment, given that the policy guidelines used do not have such provisions, and where
employers have considered concerns of employees with visual impairment, it has always been
done by discretion. This may cause a likelihood that other employers may have to follow the
guidelines strictly given that diverting from them may amount to a violation of the law and result
in being implicated for bribery. It is therefore important that public service becomes proactive
in the provision of reasonable accommodation by making the policy guideline disability- inclusive.
Provision of housing to employees with visual impairment
Participants revealed that employees with visual impairment are not given staff houses at their
workplaces and even where they exist they are not disability friendly. Participants were that
because of not having staff houses at their workplaces, they are forced to commute from their
homes to work every day which results in a lot of inconveniences. One of the direct supervisors
[DS.2] acknowledged that:
As a school having teachers who are blind, we have structural challenges. The houses for staff
accommodation are there but they are a bit old and need renovation to be used by our staff
members that are blind. This has compelled them to rent elsewhere on their own, which is
sometimes hard for them.
Another participant [VIE.6] lamented that:
No, not only in my view but I have ever enquired from the officials at the district about the
unbearable working conditions I am in. They said that '...No, there is no special offer in public
service that just because somebody is with Special Needs you construct for him or her a house at
the school or you do this and that. No, it is not there in the structure.' They instead say that, for
us, we have given you the job, find other things on your own and when you go there at the district
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Iyundhu, A, Karooma, C., & Emong, P. (2021). Complying with Reasonable Accommodation Requirements for Persons with Visual Impairment in
Uganda Public Service Employment? Assumptions and Gaps. Advances in Social Sciences Research Journal, 8(3) 632-651.
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URL: http://dx.doi.org/10.14738/assrj.83.9877
to complain that you have been given a school which has nowhere to sleep, they say, 'Now, what
can we do, should we put there another person who will be able to fight the situation?'
The above expressions show that public service is neither proactive nor reactive in the provision
of a reasonable accommodation to employees with visual impairment, given that they are not
given conducive staff houses at their workplaces. The above statements also mean that generally
public service employment is faced by inadequate staff quotas for workers, and as such
employees with visual impairment are affected worst due to such precedent. The above finding
is in agreement with the findings from a study done by Mazaki [2017] which indicated that many
districts in Uganda are constrained with a lack of teachers' housing, in that there are hardly any
school staff houses and so teachers have to find their accommodation. The finding also concurs
with Wickenden et al. [2020], and Bekoreire et al. [2012] who pointed out that transport to and
from the workplace is often challenging for PwDs due to high cost and lack of accessibility. The
above expressions and literature indicate that given the mobility challenges experienced by
employees with visual impairment, public service needs to have staff quotas built at the
workplace to accommodate employees with visual impairment. It may also require providing
them with housing and transport allowances to enable them to either rent houses near the
workplace or to commute every day from their homes to the workplace.
Provision of job training opportunities
Participants mentioned that some employers provide opportunities to their employees with
visual impairment to go back to school and pursue academic qualifications. One of the employers
[DSC.1] expressed that:
I see a very bright future for persons with visual impairment, given the fact that they have been
allowed to go for more training while on the job. This is a very good indicator that persons with
disabilities have a future in this local government because we have allowed many of our staff to
upgrade and also to specialize in Special Needs. The future is also demand-driven, we have got
partners who have come on board and established these units especially for Special Needs,
definitely the more we have the more the need for more specialized staff, although this is a
general view.
The above expression shows that provision of reasonable accommodation in regards to training
opportunities is given to employees with visual impairment operating or working in specific
settings or units for the blind. This implies that those who may be working in inclusive settings
may be denied the opportunities of going for further studies, resulting from public service
employment not having provision for reasonable accommodation for employees with visual
impairment.
Besides, participants who were employed by public service had a differing opinion in regards to
being given the opportunity of going for further training. They expressed that sometimes when
they ask for study leave from their employers, they are not given. Some participants also revealed
that sometimes employees with visual impairment are denied opportunities to attend training
workshops either within or outside the work premises. As one of the employees with visual
impairment [VIE.2] lamented that:
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For me I have ever complained, I requested to go to study but they have not done that. I am being
denied the opportunities to go for upgrading and yet they give other colleagues who are able- bodied. In-fact I will even retire without being given the chance to go back to school to study.
The above expression means that because of the lack of provision of reasonable accommodation
in public service employment, employees with visual impairment are denied opportunities to go
for studies while at work. This means that such employees are indirectly denied the opportunity
for promotion given the fact that it is dependent upon having more academic qualifications, and
extra skills to perform. The finding is in line with Sundar et al. [2018], and Graham et al. [2019]
who stated that PwDs are denied opportunities related to assignments, job training, job
counseling, and get less pay than others in a similar job. It, therefore, requires that public service
consider being proactive and reactive in providing reasonable accommodation in regards to job
training opportunities for employees with impairment, given the fact that job training enables
employees to obtain the required academic qualifications and relevant skills to improve on their
work performance and may result in their work promotion.
CONCLUSION
The provision of a reasonable accommodation to persons with visual impairment in Uganda's
public service employment has not been made a reality. This is largely due to fact that the Public
Service Commission is the overall body responsible for the appointment of workers into public
service and because its policy guidelines do not have a provision for reasonable accommodation
for PwDs, it has resulted in District Service Commissions of District Local Governments to
provide the requirements for persons with visual impairment to work by discretion. Therefore,
the policy provisions of reasonable accommodation as provided in United Nations Conventions,
and Ugandan laws need to be effectively implemented. For example ensuring equality and non- discrimination in all employment processes to enable persons with visual impairment to obtain
employment and provision of requirements such auxiliary aids such as Perkins Braille machines,
Braille slates & stylus, computers with jaws, dolphin pens, and many others and supportive
services such as sighted guides, Braille transcriber, among others to work effectively like other
employees.
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