OPINION OF THE COURT
Chаrles Donahue appeals from an order granting summary judgment to his former employer, Conrail, in a suit arising under § 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794. We affirm.
I.
Charles Donahue worked for many years on Conrail freight trains, primarily as a train conductor and engineer. In February 1993, Donahue had a heart attack at home. In May 1993, he returned to work. A few months later, in September 1993, Donahue passed out at work. His cardiologist, James Elson, concluded that Donahue’s heart attack and blackout were caused by ventricular tachycardia, a heart сondition that can suddenly cause the heart to beat extremely quickly. To help control this condition, Donahue had a defibrillator surgically installed. This device does not prevent the onset of tachycardia. Rather, it is designed to activate during tachycardic episodes and to shock the heart back into its normal rhythm. For the purposes of this appeal, it is undisputed that the device cannot be counted on to prevent loss of consciousness due to tachycardia.
After Donahue had undergone the surgery and sevеral months of convalescence, Dr. Elson wrote a letter clearing him to begin working again. Nevertheless, Dr. Elson specifically warned Donahue that he remained at risk of passing out unexpectedly and that he should not work on or around moving trains. Despite his doctor’s warnings, however, Donahue asked for work on moving trains. In March 1994, three days after beginning work as a train conductor, he experienced a tachy-cardic episode and passed out while walking down a train track. He was found by co-workers and taken to a hosрital.
After recovering, Donahue asked his supervisors if there were any jobs that he could perform at Conrail in spite of his condition. The supervisors suggested several positions. He applied for at least one of these and was turned down because there were no vacancies. When he again asked his supervisors for advice, they suggested that he consider locomotive school but warned him that he would not be permitted to take any job at Conrail unless his doctor cleared him to work. Demoralized, Donahue decided to apply for Railroad Retirement Board disability benefits. He was granted full benefits and was terminated.
At the time Donahue left his job, Conrail had vacancies in the train dispatcher posi *229 tion. 1 The parties agree that a train dispatcher remotely monitors a stretch of railroad track and the trains on it. On hearing of a mishap, a train dispatcher must dispatch emergency crews to the scene and route traffic away. The dispatcher is also responsible for alerting both train crews and emergency crews about congestion or dangerous situations. A train dispatcher does not constantly control signals but must be prepared to do so if the need arises — as, for example, when an emergency call is received. At some times, especially when there is bad weather, there can be a constant stream of calls to a train dispatcher. Because dispatchers must be alert when they are on duty, and because the consequences of train wrecks can be severe, dispatchers are not allowed to work while under the influence of medications that might make them drowsy. Furthermore, train dispatchers are governed by strict federal regulations designed to insure that railroad employees who send train signals are alert. By regulating the hours that a train dispatcher can work, these regulations “promote the safety of employees and travelers on the railroads.” 49 C.F.R. pt. 228, App. A.
In November 1998, Donahue sued Conrail under § 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 704. He alleged that Conrail had violated the Act by failing to provide a reasonable accommodation that wоuld have allowed him to continue working. Specifically, Donahue alleged that Conrail had failed to accommodate him by offering to transfer him to a position he could perform.
Section 504(a) of the Rehabilitation Act, 29 U.S.C. § 794(a), provides in pertinent part as follows:
No otherwise qualified individual with a disability ... shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance
We have sеt out the elements of a claim under this provision as follows:
To make out a prima facie case of discrimination under the Rehabilitation Act, the employee bears the burden of demonstrating (1) that he or she has a disability, (2) that he or she is otherwise qualified to perform the essential functions of the job, with or without reasonable accommodations by the employer; and (3) that he or she was nonetheless terminated or otherwise prevented from performing the job. The plaintiff must make a prima facie showing that reasonable accommodation is possible. If the plaintiff is able to meet these burdens, the defendant then bears the burden of proving, as an affirmative defense, that the accommodations requested by the plaintiff are unreasonable or would cause an undue hardship on the employer.
Shiring v. Runyon,
*230
An employer’s obligation to provide a reasonable accommodation does not require the employer to create a new job.
Mengine v. Runyon,
Donahue sued under the theory that, at the time of his termination, there were - vacant positions at an appropriate level for which he was qualified. The District Court held, however, that a reasonable jury could not find based on the summary judgment record that there were any such positions, and the Court therefore granted summary judgment in favor of Conrail. Donahue appealed.
II.
The principal question that we must decide in this appeal concerns Donаhue’s ability to perform the job of train dispatcher without posing a significant risk to others. Although Donahue argues, that he could have performed the duties of several other positions without presenting any problems, the summary judgment record is insufficient to show that any of those other positions was vacant, funded, and “at an equivalent level or position as [his former job].”
Shiring,
Although both parties and their amici agree that Conrail was not required to make Donahue a train dispatcher if doing so would have created a “significant risk” to the health or safety of others, the two sides disagree about the allocation of the burden of proof on this issue. 4 Conrail and its amicus argue that Donahue, as part of his burden of proving that he was “qualified” for the train dispatcher position, was obligated to show that he would not present such a risk. By contrast, Donahue and the EEOC, relying chiefly on certain provisions of the Americans with Disabilities Act, maintain that Conrail bore the burden of proof on this issue. 5
We find it unnecessary to decide this question. First, the argument that Conrail bore the burden of proof on this issuе was never made to the District Court and was therefore waived. Second, even if we assume for the sake of argument that Conrail bore both the burden of production and the burden of persuasion on the issue of significant risk, we would still affirm the District Court’s decision. As we will explain, no reasonable jury could fail to find that the evidence in the summary judg *231 ment record established that employing Donahue as a train dispatcher would have presented a significant risk to others.
In disability discrimination cases, courts must evaluate the significance of the risk that аn employee would pose by considering four interrelated factors: the nature of the risk, the duration of the risk, the severity of the risk, and the probability that the potential harm will occur.
See, e.g., School Bd. of Nassau County v. Arline,
[I]t is the potential gravity of the harm that imbues certain odds with significance .... [W]e are far more likely to consider walking a tightrope to pose a significant risk if the rope is fifty feet off the ground than if it is one foot off the ' ground. This is so even if the odds of losing our balance are the same however far we have to fall.
Onishea v. Hopper,
At the time when Donahue left Conrail, he had had one heart attack and had twice passed out at work in less than a year. Even after his defibrillator was installed, he passed out suddenly along a stretch of railroad track. The risk of his passing out unexpectedly was sufficiently high that his own cardiologist refused to clear him to work near trains where he might injure himself by passing out unexpectedly. See App. at A-514. The same doctor stated in his deposition that, at the time when Donahue was dismissed, he should not have been permitted to perform tasks that required him to be “conscious and alert” in case of emergencies. See App. at 512a.
A train dispatcher must be conscious and alert. The train dispatcher’s job involves monitoring railroad track to insure that trains move without mishap. The dispatcher must be alert and ready to communicate with trains quickly as soon as an emergency arises — keeping other trains from entering the area and getting emergency crews to the scene.
See
App. at 529. If a train dispatcher passes out on the job, railroad employees and others could be injured or killed. For this reason, the federal government regulates the hours that train dispatchers may work, and Conrail enforсes strict guidelines involving the medications that train dispatchers may use on the job. In upholding federal regulations allowing for the drug testing of railway employees such as train dispatchers, the Supreme Court
*232
wrote: “Employees subject to the tests discharge duties fraught with such risks of injury to others that even a momentary lapse of attention can have disastrous consequences,” among which are “great human loss.”
Skinner v. Railway Labor Executives’ Assoc.,
In spite of all this, Donahue contends that a reasonable person could consider it safe for him to work as a train dispatсher. Donahue argues that it is not important for every dispatcher to be conscious at all times because several dispatchers work together in the same room. According to Donahue, Conrail could have eliminated the danger posed by his losing consciousness by instructing co-workers to watch him and, if necessary, to take over his duties. See App. at 531. We reject this argument.
To begin, it is not clear that Donahue’s proposal can properly be characterized as an “accommodation.” An employee can succeed under the Rehabilitation Act only if the employee can “demonstrate that a specific, reasonable accommodation would have allowed her to perform the essential functions of her job.”
Taylor,
Furthermore, the record evidence before the District Court demonstrates that this “accommodation” would not have eliminated' the significant risk that Donahue would have posed. Although the record shows that workers occasionally fill in for each other during short breaks, it also shows that there are times, such as periods of bad weather, when emergencies occur with great frequency, and during such times, train dispatchers must work straight through their shifts. See App. at 530, 532. Since Donahue’s fainting spells are entirely unexpected, they might occur when no one is available to “cover” for him. Furthermore, Donahue’s fainting spells are of indeterminate length, and during these times, he is not merely unable to work, but is in need of medical attention and thus may disrupt the work of others. For all these reasons, a short break taken by an employee after notifying co-workers and verifying that they can cover for him or her is not comparable to a sudden and unexpected loss of consciousness.
Donahue also argues that the fact that he has not passed out since 1993 shows that he did not present a “significant risk.” When evaluating Conrail’s refusal to permit Donahue to work as a train dispatcher, however, we must consider the evidence available when Conrail made that decision, not what is known with the benefit of hindsight. When Conrail made its decision, it knew that Donahue had twice passed out at work, and Donahue’s own cardiologist had opined that Donahue was at risk of passing out unexpectedly.
On the evidence in the record, a reasonable factfinder could only conclude that Donahue would have posed a significant risk to others if he had been employed as a train dispatcher — even with reasonable accommodations.
III.
Donahue argues that the decision of the District Court should nevertheless be reversed because Conrail failed to engage in good faith in an “interactive process” designed to find a job to which he could have been transferred. We disagree.
*233 Our seminal case regarding an employer’s obligation to engage in the interactive process is Mengine v. Runyon, supra. There, after concluding that Mengine had not identified “any available permanent jobs which he was capable of performing,” we addressed his argument that summary judgment should not have been granted in favor of his employer, the Postal Service, because the Postal Service had “failed to cooperate with his efforts to investigate job descriptions and job vacancies.” Id. at 419. We noted that, under a recent decision of the Seventh Circuit 6 and a regulation promulgated under the ADA, 7 employers and employees were admonished to seek an “ ‘appropriate reasonable accommodation’ ” through “ ‘a flexible interactive process.’ ” Id. (quoting 29 C.F.R. § 1630.2(o)(3)(1995)). We also expounded on the benefits of this approach:
When the interactive process works well, it furthers the purposes of the Rehabilitation Act and the ADA. The employers -will not always know what kind of work the worker with the disability can do, and conversely, the worker may not be aware of the range of available employment opportunitiеs, especially in a large company. Thus, the interactive process may often lead to the identification of a suitable position. If it turns out there is no job which the worker (with or without accommodation) is capable of performing, then the company cannot be held liable for an ADA or Rehabilitation Act violation.
At the same time, however, we left no doubt that “ ‘it falls to the employee to make at least a facial showing’ that there were vacant, funded positions whose essential functions he was capаble of performing.”
Id.
at 418 (quoting
Shiring,
Mengine’s
treatment of the issue of the interactive process was dictated by the Rehabilitation Act and well established standards regarding summary judgment. The Rehabilitation Act creates a claim on behalf of an “otherwise qualified individual with a disability” who is subjected to discriminatory treatment solely by reason of his or her disability, 29 U.S.C. § 794(a), and an employer’s refusal to
*234
make “reasonable accommodation” constitutes discrimination.
See Shiring
If the defendant in a failure-to-transfer Rehabilitation Act case moves for summary judgment on the ground that the plaintiff has not identifiеd any appropriate vacant position to which the plaintiff could have been transferred, the plaintiff may move for a continuance to permit discovery regarding such positions.
See
Fed. R. Civ. Proc. 56(f). But after a full opportunity for discovery, a motion for summary judgment must be granted if the summary judgment record is insufficient to support a judgment in favor of the non-moving party.
Anderson v. Liberty Lobby, 477
U.S. 242, 255-56,
Other courts of appeals have endorsed this approach.
See, e.g., Jachan v. New York State Dept. of Labor,
Relying on certain statements in our opinion in
Taylor,
[A]s we explained in Mengine, “The ADA, as far as we are aware, is not intended to punish employers for behaving callously if, in fact, no accommodation for the employee’s disability could reasonably have been made.” Mengine,114 F.3d at 420 (quoting Willis v. Conopco, Inc.,108 F.3d 282 , 285 (11th Cir.1997)).
Id.
Donahue relies, however, on the following passage from the next page of the Taylor opinion:
When an employee has evidence that the employer did not act in good faith in the interactive process ... we will not readily decide on summary judgment that accommodation was not possible and the employer’s bad faith could have no effect. To assume that accommodation would fail regardless of the employer’s bad faith would effectively eliminate the requirement that employers must participate in the interactive prоcess.... [Wjhere there is a genuine dispute about whether the employer acted in good faith, summary judgment will typically be precluded.
Id. at 318.
When this passage and the statements quoted earlier are read in context, they are entirely consistent.
Taylor
was a case in which the plaintiff, a secretary suffering from a mental illness, sought accommodations relating to the job that she had held for years.
See
IV.
For these reasons, we affirm the decision of the District Court.
Notes
. Donahue claims that there were also vacant positions in the position of "block operator.” The train dispatcher and block operator pоsitions, however, are very similar (The block operator simply works on a smaller scale.) The District Court held that a person who was not qualified to be a train dispatcher was also not qualified to be a block operator, and neither party has challenged that holding on appeal. Accordingly, we will refer to both positions as "train dispatcher” positions.
. Section 504(d) of the Rehabilitation Act, 29 U.S.C. § 794(d) provides that "the standards used to determine whether this section has been violated in a complaint alleging employment disсrimination under this section shall be the standards applied under Title I of the Americans with Disabilities Act of 1990.”
.Donahue asserts that he could have been transferred to a position as a hump conductor, car retarder operator, switch tender, or clerical worker. He insists that was capable of performing the essential duties associated with these positions. However, Donahue has not pointed to evidence in the summary judgment record that there were vacant, funded spots at an appropriate level in аny of those jobs.
Donahue also argues that he should have been offered a transfer to the position of yardmaster. The District Court held that appointment as a yardmaster would have represented a promotion, and Donahue has not challenged that holding on appeal.
. The Supreme Court used the term "significant risk” in
School Bd. Of Nassau County v. Arline,
. See 42 U.S.C. § 12113(a) and (b).
. Beck v. University of Wisconsin Bd. of Regents, 75 F.3d 1130, 1135 (7th Cir.1996).
. 29 C.F.R. § 1630.2(o)(3)(1995).
. Similarly, sitting en banc in Deane v. Pocono Med. Ctr., we noted:
Although not a ground of our decision, we take this opportunity to observe that this protracted (and very much ongoing) litigation would likely have been unnecessary had the parties taken seriously the precepts announced in our opinion in Mengine v. Runyon.... While it may turn out that reasonable accommodation for Deane is impossible, ... nevertheless, an employer who fails to engage in the interactive process runs a serious risk that it will erroneously overlook an opportunity to accommodate a statutorily disabled employee, and thereby violate the ADA.