Common Medium Unskilled DOT Codes -- Standing and Walking

 Medium work as defined in the DOT has no maximum percentage or amounts of standing and walking during an eight-hour day, other than the length of the workday.  The primary tool for examining the existence of medium work and the amount of standing and walking during the workday is the Occupational Requirements Survey.  Here are the data:

DOT Title	DOT Code	Industry	2020      OOH	OOH     JOBS	OEWS   JOBS	S/W ≤6	STR. MEDIUM
CLEANER, INDUSTRIAL	381.687-018	(any industry)	37-2011	2,217,000	1,990,510	0.0%	75%
KITCHEN HELPER	318.687-010	(hotel & rest.)	35-9021	408,500	396,660	0.0%	49%
LABORER, STORES	922.687-058	(any industry)	51-9198	238,000	239,340	0.0%	76%
MARKER	369.687-026	(laundry & rel.)	51-9061	557,900	549,200	50.0%	30%
PACKAGER, HAND	920.587-018	(any industry)	53-7064	599,700	599,270	0.0%	65%

The only group with possible medium work with standing and walking less than or equal to six hours is inspectors, testers, sorters, samplers, and weighers (SOC 51-9061).  Half the jobs do not require sitting in excess of six hours but less than a third require medium exertion.  The data confirm the suspicion:

Strength Type	Value
Sedentary	10.4%
Light Work	48.6%
Medium Work	30%

The half of the jobs that do not require excess standing and walking, over 10% of those are sedentary.  Sedentary work requires standing and walking not more than occasionally during the workday.  That leaves almost 40% of the jobs with the number of light jobs exceeding in the aggregate the number of medium jobs.  

This calls into question the dependence of standing and walking on the strength require.  Since Labor does not provide the correlation between excess standing and walking, we ask the vocational expert to give an opinion.  Are medium jobs more likely to require standing and walking in excess of six hours a day as compared to light jobs in the same classification of inspectors, testers, sorters, samplers, and weighers (SOC 51-9061)?  The burden rests on the agency to come forward with persuasive evidence that medium jobs exist.  If they do not exist, we use Table 2 of the Medical-Vocational Guidelines.  For a person over 55 with a relevant work history or more than a limited education, that makes a difference.  

Create the conflict.  Ask the witness to give statistical testimony.  When the witness cannot, the Commissioner cannot sustain her burden of proof.  

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Suggested Citation:

Lawrence Rohlfing, Common Medium Unskilled DOT Codes -- Standing and Walking, California Social Security Attorney (December 6, 2021)  https://californiasocialsecurityattorney.blogspot.com