Employees with 

Epilepsy or Seizure Disorders 

Accommodation and Compliance Series
Preface 

The Job Accommodation Network (JAN) is a service of the Office of Disability 

Employment Policy of the U.S. Department of Labor. JAN makes documents available 

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Updated 03/22/10. 
Practical Solutions • Workplace Success 

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JAN’S ACCOMMODATION AND COMPLIANCE SERIES

Introduction

JAN’s Accommodation and Compliance Series is designed to help employers determine 

effective accommodations and comply with Title I of the Americans with Disabilities Act (ADA). 

Each publication in the series addresses a specific medical condition and provides information 

about the condition, ADA information, accommodation ideas, and resources for additional 

information. 

The Accommodation and Compliance Series is a starting point in the accommodation 

process and may not address every situation. Accommodations should be made on a 

case by case basis, considering each employee’s individual limitations and 

accommodation needs. Employers are encouraged to contact JAN to discuss specific 

situations in more detail. 

For information on assistive technology and other accommodation ideas, visit JAN's 

Searchable Online Accommodation Resource (SOAR) at http://askjan.org/soar. 

Information about Epilepsy 

What is Epilepsy? 

Epilepsy is a brain disorder that affects brain pattern activity. When brain pattern activity 

becomes disrupted, a person can experience seizures, which are strange sensations, 

emotions, behavior, convulsions, muscle spasms, or loss of consciousness (National 

Institute of Neurological Disorders and Stroke, 2008). Epilepsy is a general term that 

refers to a tendency to have recurrent seizures. There are various types of seizures. 

The term "epilepsy" can be used interchangeably with "seizure disorder" (CDC, 2008). 

Between 1.4 million and 2.7 million people in the United States have epilepsy, depending 

upon diagnostic criteria to identify people with epilepsy (CDC, 2008). Having a seizure 

does not necessarily mean that a person has epilepsy. Only when a person has 

experienced two or more seizures is s/he considered to have epilepsy (National Institute of 

Neurological Disorders and Stroke, 2008). 

What causes epilepsy? 

Epilepsy is a disorder with many possible causes such as illness, brain damage, or 

abnormal brain development (National Institute of Neurological Disorders and Stroke, 

2008). Other conditions causing seizures include stroke, complications during childbirth, 

infections (such as meningitis or encephalitis), and genetic disorders. Also, alcohol 

withdrawal and/or long-term alcohol abuse can cause seizures. When a definite cause 
Practical Solutions • Workplace Success 

4 

cannot be identified, the cause may be labeled "idiopathic" or "cryptogenic" (CDC, 

2008). 

How is epilepsy treated? 

For about 80 percent of people with epilepsy, seizures can be controlled with medicine 

such as Tegretol, Depakote, Zarontin, Topamax, or Keppra (CDC, 2008). Surgical 

device implantations, such as the Vagus Nerve Stimulator (VNS), can prevent some 

seizure activity by sending electrical signals to the brain at regular intervals (Schachter, 

2002). Other treatment includes a strict diet - called the ketogenic diet - rich in fats and 

low in carbohydrates (National Institute of Neurological Disorders and Stroke, 2008). 

A person with epilepsy can help control seizures by taking the prescribed medication 

regularly, maintaining regular sleep cycles, avoiding unusual stress, and working closely 

with the physician. Regular medical evaluation and follow-up visits are also important 

(Epilepsy Foundation, 2008). 

Epilepsy and the American with Disabilities Act 

Is epilepsy a disability under the ADA? 

The ADA does not contain a list of medical conditions that constitute disabilities. 

Instead, the ADA has a general definition of disability that each person must meet 

(EEOC, 1992). Therefore, some people with epilepsy will have a disability under the 

ADA and some will not. 

A person has a disability if he/she has a physical or mental impairment that substantially 

limits one or more major life activities, a record of such an impairment, or is regarded as 

having such an impairment (EEOC, 1992). To be a disability covered by the ADA, the 

impairment must substantially limit one or more major life activities. These are activities 

that an average person can perform with little or no difficulty. Examples are: walking, 

seeing, speaking, hearing, breathing, learning, performing manual tasks, caring for 

oneself, and working. Other activities such as sitting, standing, lifting, or reading are 

also major life activities (EEOC, 1992). 

Epilepsy may be a disability because of limitations that occur as the result of seizures or 

because of side effects or complications that can result from medications used to 

"control" the condition (EEOC, 2004). For example, a court concluded that an individual 

who had brain surgery to control seizures, but still continued to experience two or three 

seizures per month, was an individual with a disability because she was substantially 

limited in several major life activities, such as walking, seeing, hearing, speaking, and 

working, while having a seizure and often was limited in caring for herself (sometimes 

for more than a day) following particularly severe seizures (EEOC, 2004). 

Also, some individuals take drugs that control their seizures but experience drowsiness, 

inability to concentrate, or sleep disruption. An individual who is substantially limited in 

major life activities such as sleeping, thinking, concentrating, or caring for himself as a 

result of these side effects would have a disability under the ADA (EEOC, 2004). 
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Accommodating Employees with Epilepsy 

Note: People with epilepsy may experience some limitations discussed in this 

publication, but seldom experience all of the limitations. Also, the degree of limitation 

will vary among individuals. Not all people with epilepsy will need accommodations to 

perform their jobs and many others may only need a few accommodations. This 

publication is a sample of possible job accommodations available. Numerous other 

accommodation solutions may exist. 

Questions to Consider: 

1. What limitations does the employee with epilepsy experience? 

2. How do these limitations affect the employee’s job performance? 

3. What specific job tasks are problematic as a result of these limitations? 

4. What accommodations are available to reduce or eliminate these problems? Are all 

possible resources being used to determine accommodations? 

5. Can the employee provide information on possible accommodation solutions? 

6. Once accommodations are in place, can meetings take place to evaluate the 

effectiveness of the accommodations? Can meetings take place to determine 

whether additional accommodations are needed? 

7. Would human resources or personnel departments, supervisors, or coworkers benefit 

from education, training, or disability awareness regarding epilepsy? Can it be 

provided? 

Accommodation Ideas for Cognitive Impairments Associated with Epilepsy

Memory: People with epilepsy may experience memory deficits, which can affect their 

ability to complete tasks, remember job duties, or recall daily actions or activities. This 

could be caused by a side-effect to medications or from recent seizure activity. 

 Provide written or pictorial instructions, or prompt with verbal cues 

 Offer training refreshers 

 Use chart to describe steps to complicated tasks 

 Maintain, safely and securely, paper lists of crucial information such as 

passwords 

 Use voice recordings of verbal instructions 

 Provide employee directory with pictures 
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 Use nametags and door/cubicle name markers 

 Provide building directory or employee directory by name, floor, unit, etc. 

 Label items at desk (in-box, this week’s videos, etc.) 

 Use auto-dial phone features to connect quickly to used numbers 

Time Management: People with epilepsy may have difficulty managing time, which 

can affect their ability to complete tasks within a specified timeframe. It may also be 

difficult to prepare for, or to begin, some work activities. 

 Divide large assignments into several small tasks 

 Set a timer to make an alarm 

 Provide a checklist of assignments 

 Supply an electronic or handheld organizer, and train on how to use effectively 

 Use wall calendar to emphasize due dates 

Stress management: People with epilepsy may have seizures when stress is not 

properly managed. Situations that create stress can vary from person to person, but 

could likely involve heavy workload, unrealistic timeframes, shortened deadlines, or 

conflict among coworkers. 

 Provide praise and positive reinforcement 

 Refer to employee assistance programs 

 Allow employee to make telephone calls to doctors (and others) for support 

 Provide sensitivity training 

 Modify work schedule 

Accommodation Ideas for Motor Impairments Associated with Seizures 

Driving: People with epilepsy may have driving restrictions. For specific information 

about a state’s regulations involving driving with epilepsy, see: 

http://www.epilepsyfoundation.org/living/wellness/transportation/drivinglaws.cfm 

 Pair employee with co-worker who can drive to meetings or events 

 Allow tele-work or work from home 

 Transfer employee to position whereby driving is not an essential job function 

 Adjust schedule so employee can access public transportation 

 Help facilitate a carpool with co-workers for transportation to/from work 

Balancing/Climbing: People with epilepsy may have difficulty balancing or climbing. 

 Cushion a fall by using rubber matting on floor, and by adding padded edging to 

corners and edges 

 Install machine guarding 

 Use rolling safety ladders with handrails and locking casters 

 Provide head protection 
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 Provide eye protection 

 Use fall protection 

Fatigue: People with epilepsy may experience fatigue, due to a side-effect of 

medications or to recent seizure activity. 

 Use anti-fatigue matting on the floor 

 Provide flexible start or ending times 

 Adjust workweek 

 Provide private or secure rest area during breaks 

Ensuring Safety in the Workplace: Take some universal precautions to ensure safety 

in the workplace. 

 Designate a person to respond to emergencies 

 Keep aisles clear of clutter 

 Provide a quick, unobstructed exit 

 Post clearly marked directions for exits, fire doors, etc. 

 Know when to (or not to) call 9-1-1 

 Assist employee in discontinuing activity such as carrying, climbing, or driving 

 Consult employee’s plan of action to determine how to respond/react when 

employee has a seizure on the job (see "Plan of Action" section for additional 

information) 

Accommodation Ideas for Sensory Impairments Associated with Seizures 

Photosensitivity: People with epilepsy may have seizures or headaches due to light 

sensitivity, which can be exacerbated by light sources such as computer screens or 

fluorescent lights. 

 Use flicker-free monitor (LCD display, flat screen) 

 Use monitor glare guard 

 Allow frequent breaks from tasks involving computer

 Provide alternative light sources:

 Replace fluorescent lights with full spectrum lighting 

 Use natural lighting source (window) instead of electric light 

Seeing/Hearing/Communicating: During or after seizures, an employee may 

temporarily have limited ability to see, hear, or speak. 

 Allow employee time to recuperate from seizure 

 Identify hand signals or other universal signals that employee might use to 

communicate with another person 

 Use PECS (picture exchange communication system) to communicate 
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 Use paging systems to communicate with coworkers 

 Provide 2-way radios with texting options 

 Use alert systems to send message 

Other Accommodations 

Attendance/Absenteeism: Seizure activity can affect a person’s attendance at work. 

 If possible, allow employee to remain on the job after a seizure 

 Provide flexible schedule 

 Count all absences due to seizure activity as one occurrence 

 Provide leave while the employee is adjusting to medications 

 Work straight shift instead of rotating shift 

Personal Care: During or after a seizure, people with epilepsy may exhibit behaviors 

such as crying, drooling, spitting, or urinating. As a result, the person may need time 

following a seizure to engage in activities of daily living such as grooming and 

changing clothes. 

 Allow employee to keep change of clothes at the workplace 

 Provide a private space to regain composure and perform self-care tasks 

 Provide sensitivity training/disability awareness to coworkers

Situations and Solutions: 

An engineer with epilepsy had difficulty managing multiple tasks. JAN suggested colorcoding on-going projects, using wall charts to track progress, and prioritizing tasks for the 

employee. 

A laborer with epilepsy wanted to make her work area safe in the event of a seizure. 

JAN suggested installing machine guarding. 

An educational consultant with epilepsy had driving restrictions. JAN suggested 

allowing another team member to drive to site-visit locations, and tele-work whereby 

she could communicate via email and submit paperwork electronically. 

A welder with epilepsy wanted to make his work area safe when he had a seizure. 

JAN suggested a welder's helmet with additional padding and using a safety switch on 

his welding machines. 

An administrator with epilepsy needed an emergency communication system to 

inform someone that she had a seizure. JAN suggested using a two-way radio. 

A student with epilepsy used hedge-cutters and other landscaping tools in a training 

program. For safety, JAN suggested steel shoes, shin guards, and hand protection. 
Practical Solutions • Workplace Success 

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A telemarketer with epilepsy had difficulty learning new tasks. JAN suggested 

retraining, allowing use of procedural manuals, and assigning one person to 

consistently help the employee. 

A retail sales employee with epilepsy had difficulty adjusting to new medications. 

JAN suggested providing leave during the doctor-recommended three week adjustment 

period. 

A clerical employee with epilepsy was falling from his chair during seizure activity. 

For safety, JAN suggested using a chair without casters/wheels. JAN also suggested 

padded edging for the desk and a rubber mat on the floor. 

Plan of Action: 

In the event that a seizure does occur in the workplace, it is wise to be prepared. 

Preparation begins with a plan of action. 

Can you remember back to elementary school? Think back to practice for a fire drill. 

Everyone in the entire school knew the plan and was prepared for the fire drill. 

Everyone knew who was in charge, what responsibilities each person had, how quickly 

to respond to an alarm, and how to exit the building. That type of preparedness made 

the fire drill work efficiently. 

A plan of action is very similar to an elementary school fire drill. 

A plan of action is an emergency preparedness tool. It can be used to prepare for, or 

respond to, emergency situations that arise when a person has a seizure on the job. 

A plan of action can be created with the employee and employer and can include 

information such as: 

 emergency contact information 

 visual or audible warning signs 

 how/when to provide on-site medical assistance 

 how/when to call 9-1-1 

 how to provide environmental support 

 who to designate as emergency responders 

 who to go to for help 

 how to educate co-workers about epilepsy 

A properly implemented plan of action may reduce the confusion, panic, or fear that 

co-workers or customers experience if they see an employee having a seizure on the 

job. When the plan of action is “in action,” one designated person calls a spouse or 

emergency contact. One designated person watches over the employee. No one 

provides incorrect or unnecessary medical assistance (CPR, for example). No one 
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overreacts to the emergency because everyone is prepared for it, can identify it, and 

respond appropriately to it. 

A sample plan of action is provided. Please use it as guidance on how to write a plan 

of action. Employers are not required by the ADA to use the following form, nor 

are employees with epilepsy required by the ADA to use the form.

 

Sample Plan of Action 

Disability and/or Limitation(s): Epilepsy (simple partial seizures) 

 

Warning Signs for Oncoming Seizure: 

a. John will experience nausea. 

b. John’s face or shoulder/arm will jerk involuntarily. 

c. Warning signs give John 3-4 minute before seizure activity begins. 

d. John will signal designated co-worker using 2-way radio (with texting) to inform of 

oncoming seizure. 

Action Plan: 

a. Using his hand or arm, gently lead John to designated safe area. 

b. If necessary, help John into a seated or laying position. 

c. If necessary, loosen any restrictive clothing (such as a tie or scarf). 

d. During seizure (which lasts from 2 - 5 minutes), John will not need medical attention. 

e. When seizure subsides, offer John a cool cloth for his face or a cool drink. 

f. If John is disoriented, identify yourself and identify his location/surroundings. 

Additional Comments: 

a. Two designated co-workers will carry radios to hear John’s emergency signal. 

b. Supervisor will call John’s emergency contact person. 

c. Based upon John’s documentation provided by his neurologist, ambulance/medical 

attention is not required unless John falls or hits his head. 

 
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This form may NOT be kept in an employee’s personnel file. It must be kept in the 

employee’s confidential medical file.
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Resources 

Job Accommodation Network 

West Virginia University 

PO Box 6080 

Morgantown, WV 26506-6080 

Toll Free: (800)526-7234 

TTY: (877)781-9403 

Fax: (304)293-5407 

jan@askjan.org 

http://askjan.org 

The Job Accommodation Network (JAN) is a free consulting service that provides 

information about job accommodations, the Americans with Disabilities Act (ADA), and 

the employability of people with disabilities. 

Office of Disability Employment Policy 

200 Constitution Avenue, NW, Room S-1303 

Washington, DC 20210 

Direct: (202)693-7880 

TTY: (877)889-5627 

Fax: (202)693-7888 

infoODEP@dol.gov 

http://www.dol.gov/odep/ 

The Office of Disability Employment Policy (ODEP) is an agency within the U. S. 

Department of Labor. ODEP provides national leadership to increase employment 

opportunities for adults and youth with disabilities while striving to eliminate barriers to 

employment. 

American Epilepsy Society 

342 North Main Street 

West Hartford, CT 06117-2507 

Direct: (860)586-7505 

Fax: (860)586-7550 

Info@aesnet.org 

http://www.aesnet.org 

The AES promotes research and education for professionals dedicated to the prevention, 

treatment, and cure of Epilepsy. 
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Epilepsy Foundation of America 

8301 Professional Place 

Landover, MD 20785 

Toll Free: (800)332-1000 

Direct: (301)459-3700 

Fax: (301)577-2684 

http://www.epilepsyfoundation.org 

The nation's leading source of information about seizure disorders. The Foundation offers a tollfree information and referral service, legal advocacy, a national epilepsy library, and a catalog of 

epilepsy-related materials including books, videos, and pamphlets. 

Epilepsy Institute (EI) 

257 Park Ave. South, Suite 302 

New York, NY 10010 

Direct: (212)677-8550 

Phone: (212)677-5825 

http://www.epilepsyinstitute.org 

The EI, a non-profit social service organization, is dedicated to improving the quality of life of 

people with epilepsy and their families who are residents of New York City and Westchester 

County. Some programs have admissions criteria. 

Epilepsy Therapy Project 

P.O. Box 742 

Middleburg, VA 20118 

Direct: (540)687-8077 

http:///www.epilepsy.com/101/101_epilepsy 

Epilepsy Therapy Project seeks to improve incentives and encourage commercial investment in 

new therapies. The Epilepsy Therapy Project brings together financial resources, scientific 

insights and business expertise from leading academic and commercial industry participants.
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References 

Center for Disease Control and Prevention (2008). Frequently Asked Questions about 

Epilepsy. Retrieved June 23, 2008, from http://www.cdc.gov/epilepsy/faqs.htm 

Epilepsy Foundation (2008). What is Epilepsy? Retrieved June 23, 2008, from 

http://www.epilepsyfoundation.org/about/faq/ 

Equal Employment Opportunity Commission. (1992). A technical assistance manual on 

the employment provisions (title I) of the Americans with Disabilities Act. 

Retrieved June 27, 2005, from http://askjan.org/links/ADAtam1.html 

Equal Employment Opportunity Commission. (1994). Questions and Answers about 

Epilepsy and the ADA. Retrieved June 23, 2008, from 

http://eeoc.gov/facts/epilepsy.html 

Fram, D.K. (2007). Resolving ADA Workplace Questions: How Courts and Agencies are 

Dealing with Employment Issues. National Employment Law Institute, 22nd 

edition. 

National Institute of Mental Health. (2008). NINDS Epilepsy Information Page. Retrieved 

June 23, 2008, from http://www.ninds.nih.gov/disorders/epilepsy/epilepsy.htm 

Schachter, S.C. (2002). Vagus nerve stimulation therapy summary: Five years after 

FDA approval. Neurology, 59(6, Suppl 4): S15–S20. 
15 

This document was developed by the Job Accommodation Network, funded by a 

contract agreement from the U.S. Department of Labor, Office of Disability Employment 

Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the 

position or policy of the U.S. Department of Labor. Nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. Department of 

Labor.