I participated in a Social Security disability hearing in which the vocational expert identified the occupation of
Investigator, Dealer Accounts, 241.367-038 . According to the DOT, the occupation occurs in the financial industry; requires light exertion; requires reasoning level 4, math level 3, and language level 4 -- but it is unskilled.
Reasoning level 4 is a problem for unskilled work. There are two unskilled occupations that require reasoning level 4. Most semi-skilled work doesn't get to that level of reasoning. According to
Appendix C of the DOT:
04 LEVEL REASONING DEVELOPMENT
Apply principles of rational systems to solve practical problems and deal with a variety of concrete variables in situations where only limited standardization exists. Interpret a variety of instructions furnished in written, oral, diagrammatic, or schedule form. (Examples of rational systems include: bookkeeping, internal combustion engines, electric wiring systems, house building, farm management, and navigation.)
The hypothetical question to the witness assumed a limitation to simple work. This ain't simple.
The
Selected Characteristics describe the occupation as having occasional manipulative requirements; frequent talking and hearing; as well as visual functions and the exposure to weather. The hypothetical assumed occasional contact with others as well as occasional use of the hands. Unless the investigator spends a lot of time talking to himself, this work does not involve occasional contact with others. The hypothetical did later assume no exposure to bright sunlight. This work requires that function with the exposure to weather -- sunshine being part of weather. See SCO Appendix D, para. 1.
This occupation doesn't fit the limitation on three grounds: simplicity; interaction with others; and exposure to sunlight. The witness caved on the last requirement. No need to beat the witness down with the first two.
At the administrative hearing, we stop there. No need to go down the rabbit-hole of cross-examination at this point. But just for fun, let's explore the occupation.
Investigator, Dealer Accounts, 241.367-038, belongs to
Information and Record Clerks, all other.
SOC group 43-4199 is another trashcan of work:
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.
The group belongs to the classification of
Information Clerks in the Occupational Outlook Handbook. That group contains
10 SOC groups. The work requires at least a
high school education and requires short-term training.
The OOH provides a link to the
employment projections. Information and record clerks have total employment of 188,500 jobs. The finance and insurance sector (52) employs 9,900 information and record clerks.
| 520000 |
Finance and insurance |
9.9 |
If we got this far, we would be able to ask the witness to explain numbers in excess of 25,000 jobs when the industry designated by the DOT does not employ even 10,000 clerks. That figure assumes that every information and record clerk in the industry sector works in this solitary DOT code.
Having fun, so why stop now? Cross-checking with Job Browser Pro lends verification to the suspicions. JBP restates the DOT narrative, trailer, SCO, and other data -- just like West Publishing does for the DOT. There it is, a temperament for dealing with People.
TEMPERAMENTS - (Personal Adaptability)
(Situations to which the worker must adapt)
T - Situations requiring the precise attainment of set limits, tolerances, or standards.
P - Dealing with people beyond giving and receiving instructions.
Not appropriate for a person limited to occasional contact with others to have a core function of dealing with people.
JBP reports three industries for this occupation. All of them are in sector 52. JBP reports no other information and record clerks in the intersection of the SOC and NAICS codes. JBP estimates 7,922 jobs as of 2017.
This occupation illustrates use of the DOT, SCO, unselected characteristics reported by JBP and West (for example), the OOH, employment projections, and JBP to lend credence to the observations about job numbers. More importantly, this blog shows that having all those tools on the belt does not mean that the representative needs to use all of them. Yesterday, we stopped at the SCO requirements to avoid sunlight. The representative needs to know when to drop the mic.
