Saturday, January 14, 2017

Understanding Production Workers, All Other -- SOC 51-9199

A favorite of vocational experts all across the country -- occupations within the designation of production workers, all other.  Click on the link for an O*NET list of 1,590 DOT codes that fall within the SOC group with the designation 51-9199. 

That isn't accurate.  Go back to the 2011 Occupational Employment Statistics (OES).  There isn't a 51-9199.  But there is a SOC/OES group designated 51-9399.  The Bureau of Labor Statistics explains for 2011:
* This occupation has the same title, but not necessarily the same content, as the 2010 SOC occupation
This OES occupation is a combination of data collected for the 2010 SOC occupations 51-3099 Food Processing Workers, All Other, 51-9199 Production Workers, All Other and the 2000 SOC occupation 51-9199 Production Workers, All Other. 
 In 2012, BLS reports jobs numbers for 51-9199 and 51-3099.  As of 2011, production workers, all other bore a child, food processing workers, all other.  When O*NET lists 1,590 DOT codes for 51-9199, it hasn't caught up to the split.  We know this because 51-3099 lists no DOT codes.  Our friends at SkillTran use their connections with Labor to ascertain that food processing workers, all other at 51-3099 contains 61 unskilled to skilled light to heavy occupations.  SkillTran's Job Browser Pro leaves 1,526 DOT codes in 51-9199.  I have not ascertained where the other three went -- it is beyond the scope of this piece.  What we do know is that 51-9199 contains fewer than 1,590 occupations because BLS put some of them into 51-3099. 

Back to the task at hand -- what is the nature of 51-9199 and how many jobs exist in any particular DOT code residing in that accumulation?  The O*NET characterizes 51-9199 as:
"All Other" titles represent occupations with a wide range of characteristics which do not fit into one of the detailed O*NET-SOC occupations. O*NET data is not available for this type of title. For more detailed occupations under this title, see below.
This description of the 1,500+ DOT codes is simple -- it is a wastebasket for a group of codes that have little in common with each other and existing in insufficient numbers individually or in discernable groups to warrant a "real" SOC code of their own.  The O*NET makes the same statement about the 51-3099; it repeats the first two sentences quoted above.  By my count, there are 50 SOC groups that have that "all other" designation.

This takes us to the reason why vocational expert designate occupations within 51-9199 with impunity.  Their is no hard data to contradict anything that they say about the physical, mental, and skill requirements of the work.  Other O*NET codes have detailed information about the requirements of the occupational groups, but the 99's.  They are too disparate and dissimilar to have any published data. 

As presently constituted, 51-9199 contains 52 separate sedentary unskilled DOT codes and 390 light unskilled DOT codes.  Sedentary and light semi-skilled and skilled occupations make up another 440 DOT codes.  Over a third of the sedentary unskilled occupational base and almost a quarter of the light unskilled occupational base identified in the Appendix 2 regulations individually don't amount to a significant number of jobs.  If they did, they would be in their own SOC group,  Let's prove it. 

From the employment projections that form the foundation of the Occupational Outlook Handbook.  For 51-9199 EP, BLS reports

Industry 2014
Sort Order Code Title Employment Percent of industry Percent of occupation
1 TE1000 Total employment 236.2 0.2 100.0
27 31-330 Manufacturing 105.0 0.9 44.5

If the vocational expert identifies a manufacturing occupation, the number cannot exceed 105,000 jobs and then only if there are no other occupations with different skill or exertion levels. 

63 326000 Plastics and rubber products manufacturing 5.7 0.8 2.4
64 326100 Plastics product manufacturing 4.3 0.8 1.8
65 326200 Rubber product manufacturing 1.3 1.0 0.6

The DOT reports three light unskilled and 10 other DOT codes in the plastic products industry that fall into 51-9199.  The DOT reports eight unskilled light and 43 other codes in the rubber products industry that fall into 51-9199. 

There are 20 DOT codes in the optical goods industry.  NAICS.com reports that industry designation 339115 covers ophthalmic goods manufacturing.  The closest we get to in the EP reports:

123 339100 Medical equipment and supplies manufacturing 3.5 1.1 1.5

County Business Patterns reports industry employment:

339115 Ophthalmic Goods Manufacturing 24,910

Using the EP 1.1% of the industry represents 51-9199 jobs, we get 274 jobs ... in 20 different DOT codes.  That tells us that there are NOT thousands of lens inserters or final assemblers of optical goods.  The only other possibility is:

333314 Optical Instrument and Lens Manufacturing 15,003

And the EP says:

93 333300 Commercial and service industry machinery manufacturing 0.6 0.7 0.3

600 jobs.  But don't be fooled -- none of the businesses in 333314 fit final assembler or lens inserters. 

There are 52 sedentary codes and 390 codes to walk through.  The EP and the CBP inform the process.  The EP are part and parcel of the OOH.  The CBP are separately noticed.  20 CFR 404.1566(d); 416.966(d). 

The proof starts with cross-examination.  Good luck. 

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