Medium Requires More than Six Hours of Standing and Walking

The recurring refrain of an ability to perform medium work as permitting the person to stand/walk for six of eight hours has strong historical roots in the decision-making of the Social Security Administration.  SSR 83-10 says so:

The regulations define medium work as lifting no more than 50 pounds at a time with frequent lifting or carrying of objects weighing up to 25 pounds. A full range of medium work requires standing or walking, off and on, for a total of approximately 6 hours in an 8-hour workday in order to meet the requirements of frequent lifting or carrying objects weighing up to 25 pounds. As in light work, sitting may occur intermittently during the remaining time. Use of the arms and hands is necessary to grasp, hold, and turn objects, as opposed to the finer activities in much sedentary work, which require precision use of the fingers as well as use of the hands and arms.

That statement regarding standing and walking for approximately six hours in an eight-hour day has no corollary in the Dictionary of Occupational Titles, Appendix C.   While the ruling binds the agency as a matter of published administrative notice, that notice permits the party to rebut that presumption.

I use OccuCollect to drag out data about occupations.  Today we examine Hospital Cleaner:

DOT Code: 323.687-010
SOC Code: 37-2012.00
O*NET URL: https://www.onetonline.org/link/summary/37-2012.00DOT-O*NET Crosswalk: https://www.onetonline.org/crosswalk/DOT?s=323.687-010 &g=GODOT Name: Cleaner, hospital (medical services)
DOT Narrative: 323.687-010 CLEANER, HOSPITAL (medical ser.) alternate titles: housekeeper, hospital Cleans hospital patient rooms, baths, laboratories, offices, halls, and other areas: Washes beds and mattresses, and remakes beds after dismissal of patients. Keeps utility and storage rooms in clean and orderly condition. Distributes laundered articles and linens. Replaces soiled drapes and cubicle curtains. Performs other duties as described under CLEANER (any industry) I Master Title. May disinfect and sterilize equipment and supplies, using germicides and sterilizing equipment.  GOE: 05.12.18 STRENGTH: M GED: R2 M1 L2 SVP: 2 DLU: 87

Strength: M
M-Medium Work- Exerting 20 to 50 pounds of force occasionally, and/or 10 to 25 pounds of force frequently, and/or greater than negligible up to 10 pounds of force constantly to move objects. Physical Demand requirements are in excess of those for Light Work.
Dictionary of Occupational Titles, Appendix C (Dept. of Labor 1991)

Medium work but does it permit sitting for about two hours in a workday?  The O*NET work context report tickled out of OccuCollect provides the data about sitting, standing, and walking:

Exertional	%	Response
Spend Time Sitting — How much does this job require sitting?	0	Continually or almost continually
	0	More than half the time
	0	About half the time
	9	Less than half the time
	91	Never
Exertional	%	Response
Spend Time Standing — How much does this job require standing?	80	Continually or almost continually
	17	More than half the time
	2	About half the time
	1	Less than half the time
	0	Never
Exertional	%	Response
Spend Time Using Your Hands to Handle, Control, or Feel Objects, Tools, or Controls — How much does this job require using your hands to handle, control, or feel objects, tools or controls?	61	Continually or almost continually
	2	More than half the time
	30	About half the time
	3	Less than half the time
	3	Never
Exertional	%	Response
Spend Time Walking and Running — How much does this job require walking and running?	70	Continually or almost continually
	14	More than half the time
	2	About half the time
	0	Less than half the time
	15	Never

The ORS reports standing/walking as a composite activity.  Using OccuCollect to extract that data:

Series ID: ORUP1000062300000126Not seasonally adjustedSeries Title: maids and housekeeping cleaners; hours of standing/walking (10th percentile)Requirement: Physical DemandsOccupation: maids and housekeeping cleanersEstimate: hours of standing/walking (10th percentile)

Year	Period	Estimate
2017	Annual	4

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000062300000126
Series ID: ORUP1000062300000127Not seasonally adjustedSeries Title: maids and housekeeping cleaners; hours of standing/walking (25th percentile)Requirement: Physical DemandsOccupation: maids and housekeeping cleanersEstimate: hours of standing/walking (25th percentile)

Year	Period	Estimate
2017	Annual	5.5

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000062300000127

This data would suggest that 25% of the maids and housekeeping cleaners stand/walk less than six hours, but that is not the question.  Does the person get to sit for two hours in a full-time day?  

Series ID: ORUP1000062300000137Not seasonally adjustedSeries Title: maids and housekeeping cleaners; hours of sitting (90th percentile)Requirement: Physical DemandsOccupation: maids and housekeeping cleanersEstimate: hours of sitting (90th percentile)

Year	Period	Estimate
2017	Annual	1

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000062300000137

We have to climb to the 90th percentile to find any significant sitting.  Read the ORS data for percentiles by adding "or less" to the expression.  Maids and housekeeping cleaners sit for one hour or less in a workday.  That is the most useful and functional reading of the reports.  

We can confirm our reading with a percent of the day data report:

Series ID: ORUP1000062300001004Not seasonally adjustedSeries Title: maids and housekeeping cleaners; % of day standing/walking is required (10th percentile)Requirement: Physical DemandsOccupation: maids and housekeeping cleanersEstimate: % of day standing/walking is required (10th percentile)

Year	Period	Estimate
2017	Annual	86.7

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000062300001004

At the 10th percentile, maids and housekeeping cleaners sit 86.7% of the day.  Six hours cuts off at 75% of the day.  The last piece of data reported by ORS and regurgitated by OccuCollect states:

Series ID: ORUP1000062300001001Not seasonally adjustedSeries Title: maids and housekeeping cleaners; % of day sitting is required (75th percentile)Requirement: Physical DemandsOccupation: maids and housekeeping cleanersEstimate: % of day sitting is required (75th percentile)

Year	Period	Estimate
2017	Annual	6.3

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000062300001001

That is not 6.3 hours per day; that is 6.3% of the day.  The ORS does not provide the 90th percentile for this occupation in this category.  Final note:  most maids and housekeeping cleaners work part-time:

Structural Job Characteristics	%	Response
Duration of Typical Work Week — Number of hours typically worked in one week.	4	More than 40 hours
	35	40 hours
	60	Less than 40 hours

Maids and housekeeping cleaners sit very little during the day, including the cleaner, housekeeping in the medical services industry.  This method applies to many medium exertion occupations.