Monday, May 18, 2020

Laundry Worker and Literacy

In Sutherland v. Saul, the Ninth Circuit affirmed on the basis that the vocational testimony about laundry worker did not have an apparent conflict with the DOT in an unpublished opinion.  The court did not address the finding of the ALJ that Sutherland could perform past work or other occupations beside laundry worker.  Nor does the court tell us the boundaries of the medical-vocational profile.  The vocational testimony asserted that some laundry worker jobs required literacy, but not all.  The court reasoned:
The Dictionary thus describes "maximum requirements" of jobs as "generally performed," and not what every job within that occupational field requires. [Gutierrez v. Colvin, 844 F.3d 804, 807 (9th Cir. 2016)] (quoting SSR 00-4P, 2000 WL 1898704, at *2-3). Here, the vocational expert testified that some, but not all, jobs that fall within the relevant occupational category of "laundry worker" require literacy. That is not an "obvious or apparent" conflict with the Dictionary's requirements for the relevant laundry worker occupation, which says almost nothing about literacy. Id. at 808; see also DICOT 361.685-018, 1991 WL 672987
It bears repeating, the DOT does not describe the maximum requirements of occupations as they are generally found.  The DOT describes the typical requirements of occupations as they are generally found.  DICOT Appendix D.  Gutierrez implicitly defers to a ruling that is not entitled to deference.

But that is not the question here.  The question is whether laundry workers require literacy.  The Occupational Outlook Handbook (available on for free www.occucollect.com) states that laundry and dry-cleaning workers (SOC 51-6011) represents 218,600 jobs.  Laundry and dry-cleaning workers contains 23 DOT codes and 168 alternate occupational titles.  Laundry and dry-cleaning workers require a high school or equivalent education in 20.6% of jobs.  Laundry and dry-cleaning workers do not have a minimum educational requirement in 79.4% of jobs.  Laundry and dry-cleaning workers do not require literacy in 18.5% of jobs.  Occupational Requirements Survey (2018).

The number of jobs that do not require literacy is approximately 40,400 jobs.  The data supports the testimony of the vocational witness as to the existence of a significant number of jobs that do not require literacy.  Whether other limitations (whether eroding exertion or other cognitive requirements of work) would erode that number is not discernible based on the face of the court's unpublished opinion.

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Laundry Worker and Literacy, California Social Security Attorney (May 18, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/05/laundry-worker-and-literacy.html

Thursday, May 14, 2020

Preschool Teacher -- An Illustration of the Outdated DOT

Preschool teacher (DOT 092.227-018) is a fairly common occupation representing 523,600 jobs in the national economy.  OOH (2018) 25-2011 -- Preschool teachers, except special education.  Preschool teacher is the only DOT code in the group.  The DOT classifies preschool teacher as a light skilled occupation, SVP 7.

The O*NET Resource Center states that preschool teachers require one month of training or less in 30.43% of jobs.  Preschool teachers require related work experience of 30 days or less in 19% of jobs.   Preschool teachers require a high school diploma or equivalent in 28.75% of jobs.  From these three data points, 19% of preschool teachers could represent unskilled work.  A small minority of jobs require either on-the-job training or related work experience in excess of two years.  Less than 38% require more than an associate's degree.  O*NET OnLine Resource Center (2019) 25-2011.00 -- Preschool teachers, except special education.  The SVP of Preschool teachers appears overstated.

The Occupational Requirements Survey estimates that preschool teachers represent SVP 7 work in 37.5% of jobs and SVP 6 work in 26.3% of jobs.  The ORS does not describe the remaining 36% of jobs in terms of skill level.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  Those undescribed jobs could require SVP 2-5 or 8-10, as well as represent a percentage of responses that were not clear enough for reporting purposes.

The Occupational Requirements Survey estimates that preschool teachers require light exertion in 24.3% of jobs and medium exertion in 54.3% of jobs.  The ORS does not describe the remaining 25% of jobs in terms of exertion.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  Those undescribed jobs could require sedentary or heavy exertion, as well as represent a percentage of responses that were not clear enough for reporting purposes.

The SCO describes preschool teacher as requiring frequent reaching and handling with occasional fingering.  DOT 092.227-018.  The aptitudes, as part of the DOT dataset not in the SCO or DOT, describes preschool teacher as requiring below average motor coordination and finger dexterity but requiring average manual dexterity.

The O*NET OnLine states that preschool teachers use their hands to handle, control, or feel objects continually or almost continually in 17% of jobs, more than half the time in 37% of jobs, about half the time in 5 percent of jobs, less than half the time in 8% of jobs ,and never in 33% of jobs.  O*NET OnLine (2019) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey states that preschool teachers require fine manipulation in all jobs.  Preschool teachers engage in fine manipulation occasionally in 75.8% of jobs and frequently in 19.2% of jobs.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  In addition to fine manipulation, preschool teacher must keyboard in 67.7% of jobs occasionally in 33.1% of jobs.  Id.

The Occupational Requirements Survey states that preschool teachers require gross manipulation in all jobs.  Preschool teachers engage in gross manipulation occasionally in 52.8% of jobs and frequently in 36.3% of jobs. Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey states that preschool teachers reach at or below shoulder level in 88.8% of jobs.  Preschool teachers reach at or below shoulder level occasionally in 45.7% of jobs. Preschool teachers reach overhead in 40.6% of jobs, using both hands in 36% of jobs.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey describes preschool teachers as standing/walking 75% of day at the mean, half the day at the 25% percentile, and 90% of the day at the 90th percentile.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The O*NET OnLine reports that preschool teachers work less than 40 hours per week in 52.1% of jobs.  Preschool teachers work full-time or more in 47.8% of jobs.  O*NET OnLine (2019) 25-2011.00 -- Preschool teachers, except special education.

For a step four analysis of ability to perform past relevant work, it is important to first classify the nature of the work as actually performed.  Did the work require SVP 7 skill level while engage in light work?  Did the claimant work full-time or part-time?  What were the standing/walking requirements of the job as actually performed.

Once the claimant establishes an inability to perform preschool teacher as actually performed, the attention must turn to the occupation as generally performed.  If the claimant worked part-time as past relevant work, then the existence of part-time work counts as generally performed.  Careful attention must be given to the question of as generally performed in terms of staying at or below the claimant's skill level, excluding jobs that require too much exertion, or have requirements that the claimant does not or no longer possesses.

The as generally performed analysis begs the question:  what does generally mean?  If generally means typical, then preschool teacher typically requires medium exertion.  If generally performed means something other than typically performed, then the claimant has a much more difficult burden to establish the inability to perform past relevant work as generally performed.  Because the DOT presents occupations as typically found in the national economy (DICOT App. D), typicality represents the best approximation of as generally performed.  Whether that range falls around the median, a plurality, or an average will turn to a case-dependent fact.

What is clear is that DOT as to preschool teacher no longer describes work that exists in the national economy.  The DOT does not describe typical skill, exertion, or manipulative requirements.

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Preschool Teacher -- An Illustration of the Outdated DOT, California Social Security Attorney (May 14, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/05/preschool-teacher-illustration-of.html

Monday, May 11, 2020

Conflating the Stand/Walk Limitation to Eight Hours

A vocational witness responds to a hypothetical question that assumes a capacity for light work and a limitation to standing/walking for six hours in an eight hour day.  The claimant is advanced age, high school education, and past relevant work as a pharmacy technician (DOT 074.382-010, SVP 3, light).

The question did not contain any mental limitations but did have a limitation to occasional postural activities. The absence of a mental limitation, even slight or mild, made the case difficult. The limitation to occasional postural activities is unimportant. The vocational witness states that the person could perform past work as a pharmacy technician.
ATTY: What SOC code does pharmacy tech sort into?
VW: 29-2052 pharmacy technicians.
ATTY: What is your understanding of generally performed?
VW: [silence].
ATTY: Well, does it mean the majority of jobs, the median, the mean, what does generally performed mean to you?
VW: Generally performed as described by the DOT.
ATTY: What if we consider generally performed in the national economy. (that is the standard 20 C.F.R. § 416.960(b)(2)) If someone can only stand/walk six hours in an eight hour day, so that person must sit for two hours, can this individual perform work as a pharmacy tech as generally performed in the national economy?
VW: [mumbles, then silence.]
ATTY: If I presented you with data from the Department of Labor that reports jobs in this occupational group do not sit at the 25th percentile, do not sit at the median, and only sit for 1.1 hours at the mean, would that change your answer as to whether an individual could perform work as a pharmacy tech, as generally performed in the national economy, when that individual cannot stand/walk more than six hours in an eight hour day?
The vocational witness agreed that past work as a pharmacy tech requires more than six hours of standing/walking as actually and generally performed in the national economy.  Skills did not transfer to work that permitted six hours or less of standing/walking in an eight-hour day.  A colloquy ensued between the ALJ and counsel that "about six hours" of standing and/or walking found in the initial and reconsideration medical opinions/findings does not permit eight hours of combined standing/walking.  

In this case, counsel had submitted the Occupational Requirements Survey for Pharmacy Technicians (29-2052.00) from www.OccuCollect.com.  The ORS data and the vocational witness concession put the claimant into grid rule 202.06 once the claimant carried his burden of proof that he could not perform his past work as actually or as generally performed.  

Data wins.  Disabusing the witness of the notion that six hour of standing and/or walking does not mean six hours of each wins. 

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Conflating the Stand/Walk Limitation to Eight Hours, California Social Security Attorney (May 11, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/05/conflating-standwalk-limitation-to.html

Saturday, April 18, 2020

Use of the OOH and O*NET Accepted by the Court

The district court reverse and remanded Cymande S. v. Berryhill, 2019 WL 4148351, at *3 (C.D. Cal. May 16, 2019).  The decision is not available on Google Scholar.  No freebies.

This a straight Occupational Outlook Handbook and O*NET OnLine assault on vocational expert testimony mounted at the Appeals Council.  The district court summarized the issue:
Plaintiff also argues that the ALJ could not have reasonably relied on the testimony of the VE given that the VE's figures for a single job exactly matched the OOH reported figures for a category of jobs containing 18 distinct DOT job codes in one instance and 782 distinct DOT job codes in another instance.
Inspectors, testers, sorters, samplers and weighers (SOC 51-9061) is the occupational group that contains 782 DOT codes.  The OccuCollect.com everything report summary for any of the 782 DOT codes (including nut sorter) states:

There are 782 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report

67 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Sedentary
14 are SVP 2
585 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Light
3 are SVP 1 132 are SVP 2
117 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Medium
17 are SVP 2
13 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Heavy
1 are SVP 1 6 are SVP 2

The unskilled occupations make up 173 DOT codes out of the 782 total codes.  The OOH currently describes the occupational group as typically requiring a high school diploma or equivalent, moderate-term on-the-job training, and representing 574,000 jobs.  The OOH glossary defines moderate-term as more than 30 days and up to one year.  The work is typically semi-skilled or skilled.  Inspectors, testers, sorters, samplers and weighers are not typically unskilled.  A nut sorter (DOT 521.687-086) cannot represent 574,000 jobs.  

This is one of occupations identified in Biestek v. Berryhill.  The proposition that 120,000 jobs as a nut sorter existing in the national economy ever is laughable.  Justice Gorsuch identified that concept in dissent.  

Cashiers (SOC 41-2011) is the occupational group that contains 18 DOT codes.  The OccuCollect.com everything report summary for any of the 18 DOT codes (including toll collector) states:

There are 18 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report

5 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Sedentary
13 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Light
6 are SVP 2

The unskilled occupations make up 6 of the 18 total codes.  The OOH currently describes the occupational group as typically requiring no formal educational credential, short-term on-the-job training, and representing 3,648,500 jobs.  Toll collector cannot represent 3.4 million jobs.  

Cymande S. v. Berryhill represents progress is using the OOH combined with the O*NET crosswalk report to demonstrate the fallacy of job numbers.  Other data not mentioned by the court concerned the standing/walking of inspectors and cashiers, the predominant part-time nature of cashier work, as well as unskilled vs. semi-skilled or skilled work as reported by the O*NET (full-time) and ORS (other job characteristics).  Cymande S. v. Berryhill can be your next win if you present the vocational rebuttal to the ALJ or the Appeals Council (where AC evidence matters). 

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Use of the OOH and O*NET Accepted by the Court, California Social Security Attorney (April 18, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/04/use-of-ooh-and-onet-accepted-by-court.html

Thursday, April 16, 2020

Come on Down! Let's Make a Deal!

Let's Make a Deal is the iconic TV game show that debuted in 1963 and continues to this day.  Whether you remember Monty Hall or the new version with Wayne Brady, Let's Make a Deal is the risk of the bird in the hand or pursue the two in the bush only to find that the two in the bush was a box of rocks.  Administrative Law Judges play that game too.

I will use the experience of yesterday.  I could use similar experiences from 30 years ago.  The conversation goes something like this:
ALJ:  I am willing to find your client disabled as of February 1, 2020, the week before the psychiatrist signed the medical source statement.
ATTY:  The PA that authored that MSS completed two more with congruent findings, the first in 2008.
ALJ:  I know that.  If you don't want to take the February 1, 2020, date, then I will send the claimant out for a consultative psych eval -- who knows how long that will take.  Your choice counsel.
ATTY:  Compromising the claim is never my choice.  I will speak to my client.
ALJ:  I will put the call on hold and the monitor will text me when I can pick up.  
The vocational expert hangs up on my insistence.  I explain the game of Let's Make a Deal.  Not only do I not know who the consultative examiner will be, I have no idea what that person will write.  It isn't even a testifying medical expert where I can choose what exhibits to point out.  The consultative examiner is the worst option.  The client, desperate for security and tired of general relief subsistence, takes the ALJ offer rather than wait until December to get a decision whether the same, better, or worse.

We address this issue based on the Code of Conduct for Unites States Judges.  Canon 3A(4), second paragraph, states:
A judge may encourage and seek to facilitate settlement but should not act in a manner that coerces any party into surrendering the right to have the controversy resolved by the courts.
Is the threat of a consultative examination coercive?  Is the statement that getting the claimant out to a consultative examination when the unending COVID-19 crisis ends coercive?   I submit that the choice of pay now or wait an indeterminate amount of time with an unknown variable is coercive.  We further the analysis with the last clause of the oath of office of every office other than the President and elected or appointed offices:
I will well and faithfully discharge the duties of the office on which I am about to enter.
 The oath of justices and judges is similar:
I will administer justice without respect to persons, and do equal right to the poor and to the rich, and that I will faithfully and impartially discharge and perform all the duties incumbent upon me ...
The authority of an ALJ includes taking appropriate measures necessary to enable him or her to discharge the duties of office.

The clear import of the duty of the ALJ is to pay the claims of people that meet the disability standard on the date that the ALJ believes is proven by the record and to deny benefits to people that have not met the burden of proof.  Pay every dime due and deny every dime not due.

In our case from yesterday, the ALJ was either not persuaded of disability as of February 1, 2020, or was using that date as a coercive lever to preclude resolution of the controversy as to the earlier date.  The February 1, 2020, date is an endorsement date, not a medically based onset date.  It is a coerced result.

That is the bottom line.  The ALJ either put someone on the disability rolls that did not belong there by stripping that person of to right to have the earlier period adjudicated, or the ALJ simply coerced the person into giving up rights to protect the government fisc or some other improper purpose.

When an ALJ suggests an amendment to the onset date or the termination of disability, that suggestion or offer should stand without precondition.
I am prepared to find your client disabled as of February 1, 2020.  You may amend your onset date or I will prepare a partially favorable decision, leaving the exceptions and review rights intact.  What would your client like to do?  
That is the type of statement that complies with the oath of office and the judicial canons, used here by analogy.

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Come on Down!  Let's Make a Deal!, California Social Security Attorney (April 16, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/04/come-on-down-lets-make-deal.html

Thursday, April 2, 2020

O*NET OnLine Will Migrate to the SOC 2018 in November 2020

New O*NET-SOC Taxonomy Transition Tools within O*NET Web Services

With the release of the O*NET 25.1 Database in November 2020, O*NET Web Services will transition to the O*NET-SOC 2019 taxonomy. This taxonomy, based on the 2018 SOC, introduces several changes to the occupations returned by our services. It includes 1,016 occupational titles, 923 of which represent O*NET data-level occupations. For more information on these changes, see the O*NET-SOC Taxonomy page at the O*NET Resource Center.
To help O*NET Web Services users with the upcoming taxonomy transition, Taxonomy Services are now available to enable developers to connect occupational data between existing systems based on the O*NET-SOC 2010 taxonomy, and the future O*NET-SOC 2019 taxonomy-based O*NET Web Services.
That's the announcement from the Department of Labor, Employment Training Administration (ETA). One big change comes in production workers, all other (51-9199).  This probably the most statistically abused group in terms of the number of DOT codes (1,590), the number of unskilled sedentary and light DOT codes (457), and the insidious use of equal distribution.  Part of that will go away in November.  Here is what is happening to SOC 51-9199 and its detailed occupation 51-9199.01 Recycling and Reclamation Workers:
51-9161.00 Computer Numerically Controlled Tool Operators
51-9162.00 Computer Numerically Controlled Tool Programmers
51-9199.00 Production Workers, All Other
53-7062.04 Recycling and Reclamation Workers
Some DOT codes, maybe, and a significant number of jobs will move to other O*NET/SOC codes.  Part of the gross data aggregation will go away.  Production workers, all other will get numerically smaller.  None of the unskilled sedentary and light DOT codes currently resident in production workers, all other fit the three new classifications.

Another statistical mess will get cleaned up.  Stock clerks and order fillers will consolidate four detailed occupations back into the single SOC code:
43-5081.01 Stock Clerks, Sales Floor
43-5081.02 Marking Clerks
43-5081.03 Stock Clerks- Stockroom, Warehouse, or Storage Yard
43-5081.04 Order Fillers, Wholesale and Retail Sales

Those four detailed occupations and the constituent 2 million jobs will all end up in Stockers and Order Fillers with a new numerical designation, but same name:
53-7065.00 Stockers and Order Fillers
We can expect the ORS will track the new changes.  Counting unskilled light stockers and order fillers will get easier because the data will designate light and unskilled jobs.  We will still have to put the numbers together.  My suspicion is that the number of light markers will go down significantly because the range of medium exertion includes constant lifting/carrying of 2 pounds or frequent lifting/carrying of 11 pounds in addition to the recognized occasional lifting/carrying of 21 pounds all to that maximum of seldom lifting/carrying of 50 pounds.

When the data arrives, you can expect to see it incorporated into OccuCollect and its heralded everything report.

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, O*NET OnLine Will Migrate to the SOC 2018 in November 2020, California Social Security Attorney (April 2, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/04/onet-online-will-migrate-to-soc-2018-in.html

Thursday, March 19, 2020

Documented Occupational Erosion Using BLS Data Accepted by the ALJ

I had a telephone hearing with an ALJ. Judge states that he found the pre-hearing brief persuasive and intends to award benefits for a younger individual, high school education in a foreign country, illiterate in English, past work semi-skilled and light. The residual functional capacity is for a limited range of light work: standing two hours; walking two hours. Clearly a mixed bag on the medical-vocational criteria. I attach an everything report from OccuCollect.com for the two occupations cited. The everything report includes the DOT, SCO, OOH, O*NET, and ORS data along with calculations for the common factors encountered. With those reports attached, here is the argument presented, the client's name replaced with CLAIMANT, to protect privacy:

The prior vocational expert testified to assembler of plastic hospital products (DOT 712.687-010) representing 115,000 jobs; assembler, electrical accessories (DOT 729.687-010) representing 20,000 jobs. The testimony is easily contradicted and rendered feeble. It is not substantial evidence. You should find CLAIMANT disabled under the Medical-Vocational Guidelines, Rule 201.17 by analogy.

1. Assembler of Plastic Hospital Products

Assembler of plastic hospital products is a light unskilled occupation. DICOT 712.687-010. Assembler of plastic hospital products belongs to the occupational group of production workers, all other (SOC 51-9199). Production workers, all other represents a large occupational group containing 1,590 DOT codes at all levels of exertion and skill. O*NET OnLine, DOT crosswalk, 51-9199. The Occupational Outlook Handbook describes production workers, all other, as representing 244,700 jobs in the nation with a typical educational requirement of a high school diploma or equivalent and typical on-the-job training of moderate-term — more than 30 days and up to one year. Occupational Outlook Handbook (2018), 51-9199.

Production workers, all other, have no minimum educational requirement in 49.1% of jobs. They require literacy in 31% of the jobs. That leaves 18.1% of the jobs is not requiring literacy. Production workers, all other, engage in unskilled work in 53% of jobs. Production workers, all other, engage in medium work in 63.9% of jobs. Production workers, all other, stand/walk 6.75 hours per day at the 25th percentile; 7.92 hours per day at the 50th percentile; and 8.0 hours per day at the 75th and 90th percentiles. There is no significant range of work in the occupational group of production workers, all other, that permit standing/walking equal to or less than four hours in an eight-hour day. Occupational Requirements Survey (2018), 51-9199.00.

2. Assembler of Electrical Accessories I

Assembler of electrical accessories I is a light unskilled occupation. DICOT 729.687-010. Assembler of electrical accessories I belongs to the occupational group of electrical and electronic equipment assemblers (SOC 51-2022.00). Electrical and electronic equipment assemblers is a large occupational group containing 61 DOT codes at all levels of exertion and skill. O*NET OnLine, DOT crosswalk, 51-2022. The Occupational Outlook Handbook describes electrical and electronic equipment assemblers as representing 218,900 jobs in the nation with a typical educational requirement of a high school diploma or equivalent and typical on-the-job training of moderate-term — more than 30 days and up to one year. Occupational Outlook Handbook (2018), 51-2022.

Electrical and electronic equipment assemblers have no minimum educational requirement in 26.7% of jobs. Literacy is required in all, 26.7% of jobs. Electrical and electronic equipment assemblers engage in unskilled work in 29.2% of jobs. Electrical and electronic equipment assemblers engage in light work and 28.3% of jobs. Electrical and electronic equipment assemblers do not sit at the 10th percentile; sit for hours per day at the 50th percentile; sit 6.4 hours per day at the 75th percentile; and sit 7.2 hours per day at the 90th percentile. Electrical and electronic equipment assemblers stand/walk 1.6 hours per day at the 25th percentile; 4.8 hours per day at the 50th percentile; 7.2 hours per day at the 75th percentile; and 8.0 hours per day at the 90th percentile. Very few electrical and electronic equipment assemblers meet the residual functional capacity assessed, but none of them meet the educational deficiency of illiteracy in English. Occupational Requirements Survey (2018), 51-2022.00.

3. Conclusion

A limitation to four hours of standing/walking in an eight-hour day erases the ability to perform light work. First and foremost, the ability to stand is far more important than the ability to walk for light work. Social Security Ruling 83-10. The primary difference between light and sedentary work is standing/walking. Id. You should apply Grid rule 201.17 and find CLAIMANT disabled.

The ALJ directed the vocational expert to the brief in the E section.  The vocational expert confirmed that the person could not perform any identifiable work.  Hearing concluded. 

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, Documented Occupational Erosion Using BLS Data Accepted by the ALJ, California Social Security Attorney (March 19, 2020)
http://californiasocialsecurityattorney.blogspot.com/2020/03/documented-occupational-erosion-using.html