Storage-facility rental clerk is often identified by vocational witnesses in Social Security disability hearings. It is reasoning level 3, mathematics level 3, and language level 3. It requires frequent reaching, handling, and fingering. Job Browser Pro ver. 1.7.4 estimates 68,736 jobs, almost all of them in the real estate industry subsector (531000). The question turns on reliability.
Real estate fits with the general idea of a storage-facility rental clerk. The Occupational Employment and Wage Statistics breaks down counter and rental clerk employment in the real estate and rental and leasing sector (NAICS 530000) into two subsectors: real estate (NAICS 531000) and rental and leasing services (NAICS 532000). (This is a free report in www.occucollect.com, just register, no subscription needed). Rental and leasing services are the industries that employ furniture-rental consultants and automobile rental clerks. Real estate still fits but seems broad, so we drill down.
County Business Patterns reports employment for the real estate subsector at 1.7 million jobs in all occupations. I run the CBP report for 3 or 4 digit NAICS code, starting with NAICS 531 in www.occucollect.com. (This report is subscription required. CBP is a bear to work through in its native environment, last time I checked). I get the results for the subsector:
NAICS Description Jobs|
531 |
Real
estate |
1,720,076 |
|
5311 |
Lessors
of real estate |
607,988 |
|
53111 |
Lessors
of residential buildings and dwellings |
345,797 |
|
531110 |
Lessors
of residential buildings and dwellings |
345,797 |
|
53112 |
Lessors
of nonresidential buildings (except miniwarehouses) |
180,803 |
|
531120 |
Lessors
of nonresidential buildings (except miniwarehouses) |
180,803 |
|
53113 |
Lessors
of miniwarehouses and self-storage units |
47,386 |
|
531130 |
Lessors
of miniwarehouses and self-storage units |
47,386 |
|
53119 |
Lessors
of other real estate property |
34,002 |
|
531190 |
Lessors
of other real estate property |
34,002 |
|
5312 |
Offices
of real estate agents and brokers |
362,207 |
|
53121 |
Offices
of real estate agents and brokers |
362,207 |
|
531210 |
Offices
of real estate agents and brokers |
362,207 |
|
5313 |
Activities
related to real estate |
749,881 |
|
53131 |
Real
estate property managers |
648,424 |
|
531311 |
Residential
property managers |
486,758 |
|
531312 |
Nonresidential
property managers |
161,666 |
|
53132 |
Offices
of real estate appraisers |
34,143 |
|
531320 |
Offices
of real estate appraisers |
34,143 |
|
53139 |
Other
activities related to real estate |
67,314 |
|
531390 |
Other
activities related to real estate |
67,314 |
The industry group for lessors of real estate contains specific industries for buildings and dwelling as well as nonresidential buildings except miniwarehouses. Storage-facility rental clerk works in the minwarehouses and self-storage units business. We check back with the DOT to be sure:
295.367-026 STORAGE-FACILITY RENTAL CLERK (business ser.; retail trade) Leases storage space to customers of rental storage facility: Informs customers of space availability, rental regulations, and rates. Assists customers in selection of storage unit size according to articles or material to be stored. Records terms of rental on rental agreement form and assists customer in completing form. Photographs completed form and customer to establish identification record, using security camera. Computes rental fee and collects payment. Maintains rental status record and waiting list for storage units. Notifies customers when rental term is about to expire or rent is overdue. Inspects storage area periodically to ensure storage units are locked. Observes individuals entering storage area to prevent access to or tampering with storage units by unauthorized persons. Loads film into security and surveillance cameras, records dates of film changes, and monitors camera operations to ensure performance as required. Cleans facility and maintains premises in orderly condition.
GOE: 09.04.02 STRENGTH: L GED: R3 M3 L3 SVP: 2 DLU: 86
The lead statement "summarizes the entire occupation. It offers essential information." DICOT, introduction. The storage-facility rental clerk works in storage facility businesses. NAICS 531000 is too broad. Storage-facility rental clerk has an apparent conflict with every industry in this list except lessors of miniwarehouses and self-storage units (NAICS 531130). This specific industry accounts for 47,386 jobs in all occupations, not just the counter and rental clerks.
This observation means that 68,736 jobs in the industry subsector has a conflict with the DOT once the claimants asks for administrative notice of CBP. Opening up the Occupational Outlook Handbook for counter and rental clerks in www.occucollect.com (another free report), I follow the hyperlink to the Employment Projections for SOC 41-2021. Within the real estate subsector, counter and rental clerks make up 30.4% of the jobs. Instead of 68,000 jobs, the gross number of full- and part-time jobs is about 16,000 jobs. Only full-time work counts. SSR 96-8p. The O*NET OnLine reports that 60% of counter and rental clerks work 40+ hours per week. We now have the number of counter and rental clerks to less than 10,000. That is less than a significant number of jobs in the Ninth Circuit, your circuit may vary.
To address the 68,000 jobs reported by JBP, we used County Business Patterns and the Employment Projections nested inside of the Occupational Outlook Handbook. CBP and OOH are listed sources as examples of administrative notice. We answered the full-time question using the O*NET but could have used the answer provided by JBP.
The answer of why JBP counts the subsector instead of the industry group or the specific industry rests on the structure used. JBP relies on the OEWS to estimate the occupation-industry intersection. Where the OEWS does not report 4 or 5-digit NAICS codes, JBP does not use them. But our hands are not tied and we can "drill down." We must "drill down." Our client's future depends on it.
___________________________
Suggested Citation:
Lawrence Rohlfing, Storage-Facility Rental Clerk -- Using County Business Patterns to Crush the JBP Job Numbers Estimate, California Social Security Attorney (May 19, 2022) https://californiasocialsecurityattorney.blogspot.com
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