CHRO Issues New Guidance on CT Workplace Accommodations for Pregnancy, Childbirth, and Related Conditions
On April 23, 2019, the Connecticut Commission on Human Rights and Opportunities issued a Best Practices Blue Paper offering guidance to employers on how to deal with accommodation requests related to pregnancy, childbirth, and related conditions. The full text of the guidance is available here.
This guidance explains the obligations imposed on companies with three or more employees under the Connecticut Fair Employment Practices Act (“CFEPA”), largely echoing the 2017 CFEPA amendments. In short, the blue paper reminds employers that workers are entitled to: reasonable accommodations for pregnancy, childbirth, and related conditions; reasonable leaves of absence due to disability resulting from pregnancy or any pregnancy-related condition or symptom; and reasonable accommodations for lactation needs.
Further, the guidance reiterates that employers are required to engage in a good faith interactive process with an employee requesting an accommodation or leave and whenever the employer has a reasonable basis to believe an employee may need an accommodation. The guidance lays out the basic stages of the process—starting the process, engaging in the good faith interactive process, and concluding the process—and lists helpful examples of what the process should look like when put into practice. The CHRO highlights the importance of communicating during the process and documenting the results in writing at the end of the process.