Preschool Teacher -- An Illustration of the Outdated DOT

Preschool teacher (DOT 092.227-018) is a fairly common occupation representing 523,600 jobs in the national economy.  OOH (2018) 25-2011 -- Preschool teachers, except special education.  Preschool teacher is the only DOT code in the group.  The DOT classifies preschool teacher as a light skilled occupation, SVP 7.

The O*NET Resource Center states that preschool teachers require one month of training or less in 30.43% of jobs.  Preschool teachers require related work experience of 30 days or less in 19% of jobs.   Preschool teachers require a high school diploma or equivalent in 28.75% of jobs.  From these three data points, 19% of preschool teachers could represent unskilled work.  A small minority of jobs require either on-the-job training or related work experience in excess of two years.  Less than 38% require more than an associate's degree.  O*NET OnLine Resource Center (2019) 25-2011.00 -- Preschool teachers, except special education.  The SVP of Preschool teachers appears overstated.

The Occupational Requirements Survey estimates that preschool teachers represent SVP 7 work in 37.5% of jobs and SVP 6 work in 26.3% of jobs.  The ORS does not describe the remaining 36% of jobs in terms of skill level.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  Those undescribed jobs could require SVP 2-5 or 8-10, as well as represent a percentage of responses that were not clear enough for reporting purposes.

The Occupational Requirements Survey estimates that preschool teachers require light exertion in 24.3% of jobs and medium exertion in 54.3% of jobs.  The ORS does not describe the remaining 25% of jobs in terms of exertion.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  Those undescribed jobs could require sedentary or heavy exertion, as well as represent a percentage of responses that were not clear enough for reporting purposes.

The SCO describes preschool teacher as requiring frequent reaching and handling with occasional fingering.  DOT 092.227-018.  The aptitudes, as part of the DOT dataset not in the SCO or DOT, describes preschool teacher as requiring below average motor coordination and finger dexterity but requiring average manual dexterity.

The O*NET OnLine states that preschool teachers use their hands to handle, control, or feel objects continually or almost continually in 17% of jobs, more than half the time in 37% of jobs, about half the time in 5 percent of jobs, less than half the time in 8% of jobs ,and never in 33% of jobs.  O*NET OnLine (2019) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey states that preschool teachers require fine manipulation in all jobs.  Preschool teachers engage in fine manipulation occasionally in 75.8% of jobs and frequently in 19.2% of jobs.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.  In addition to fine manipulation, preschool teacher must keyboard in 67.7% of jobs occasionally in 33.1% of jobs.  Id.

The Occupational Requirements Survey states that preschool teachers require gross manipulation in all jobs.  Preschool teachers engage in gross manipulation occasionally in 52.8% of jobs and frequently in 36.3% of jobs. Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey states that preschool teachers reach at or below shoulder level in 88.8% of jobs.  Preschool teachers reach at or below shoulder level occasionally in 45.7% of jobs. Preschool teachers reach overhead in 40.6% of jobs, using both hands in 36% of jobs.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The Occupational Requirements Survey describes preschool teachers as standing/walking 75% of day at the mean, half the day at the 25% percentile, and 90% of the day at the 90th percentile.  Occupational Requirements Survey (2018) 25-2011.00 -- Preschool teachers, except special education.

The O*NET OnLine reports that preschool teachers work less than 40 hours per week in 52.1% of jobs.  Preschool teachers work full-time or more in 47.8% of jobs.  O*NET OnLine (2019) 25-2011.00 -- Preschool teachers, except special education.

For a step four analysis of ability to perform past relevant work, it is important to first classify the nature of the work as actually performed.  Did the work require SVP 7 skill level while engage in light work?  Did the claimant work full-time or part-time?  What were the standing/walking requirements of the job as actually performed.

Once the claimant establishes an inability to perform preschool teacher as actually performed, the attention must turn to the occupation as generally performed.  If the claimant worked part-time as past relevant work, then the existence of part-time work counts as generally performed.  Careful attention must be given to the question of as generally performed in terms of staying at or below the claimant's skill level, excluding jobs that require too much exertion, or have requirements that the claimant does not or no longer possesses.

The as generally performed analysis begs the question:  what does generally mean?  If generally means typical, then preschool teacher typically requires medium exertion.  If generally performed means something other than typically performed, then the claimant has a much more difficult burden to establish the inability to perform past relevant work as generally performed.  Because the DOT presents occupations as typically found in the national economy (DICOT App. D), typicality represents the best approximation of as generally performed.  Whether that range falls around the median, a plurality, or an average will turn to a case-dependent fact.

What is clear is that DOT as to preschool teacher no longer describes work that exists in the national economy.  The DOT does not describe typical skill, exertion, or manipulative requirements.

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SUGGESTED CITATION:

Lawrence Rohlfing, Preschool Teacher -- An Illustration of the Outdated DOT, California Social Security Attorney (May 14, 2020)
https://californiasocialsecurityattorney.blogspot.com/2020/05/preschool-teacher-illustration-of.html

Preschool Teacher -- Not Light Work -- Rebut the DOT

I am getting ready for a hearing but you really need to know this.  You can rebut the DOT.  My case is for a preschool teacher of advanced age and capable of light work.  I expect the vocational expert to tell the ALJ that the job is light per the DOT and thus as generally performed.

092.227-018 TEACHER, PRESCHOOL (education)

    Instructs children in activities designed to promote social, physical, and intellectual growth needed for primary school in preschool, day care center, or other child development facility. Plans individual and group activities to stimulate growth in language, social, and motor skills, such as learning to listen to instructions, playing with others, and using play equipment. May be required to have certification from state. May be designated Teacher, Child Development Center (education); Teacher, Day Care Center (education); Teacher, Early Childhood Development (education); Teacher, Nursery School (education).
GOE: 10.02.03 STRENGTH: L GED: R4 M2 L3 SVP: 7 DLU: 81

There it is light.  But is it.  I checked the Occupational Requirements Survey published by the Bureau of Labor Statistics.  

Latest Observation:Annual 201730.00

Annual 2017 - Annual 2017Minimum Value: Annual 201730.00
Maximum Value: Annual 201730.00
Data Availability:2017 - 2017

Data extracted on: Dec 14, 2017 (11:24:47 AM)

Occupational Requirements Survey

Series Title	:	Civilian workers; preschool teachers, except special education; pounds maximum weight lifted/carried (25th percentile)
Series ID	:	ORUP1000037400000235
Seasonality	:	Not Seasonally Adjusted
Survey Name	:	Occupational Requirements Survey
Measure Data Type	:	Pounds
Industry	:	All workers
Occupation	:	Preschool Teachers, Except Special Education
Class of Worker	:	All workers
Requirements	:	Physical demands
Type of cases	:	Maximum weight lifted/carried

That is the 25th percentile and 30 pounds is well beyond light.  

Latest Observation:Annual 201740.00

Annual 2017 - Annual 2017Minimum Value: Annual 201740.00
Maximum Value: Annual 201740.00
Data Availability:2017 - 2017

Data extracted on: Dec 14, 2017 (11:26:14 AM)

Occupational Requirements Survey

Series Title	:	Civilian workers; preschool teachers, except special education; pounds maximum weight lifted/carried (50th percentile - median)
Series ID	:	ORUP1000037400000236
Seasonality	:	Not Seasonally Adjusted
Survey Name	:	Occupational Requirements Survey
Measure Data Type	:	Pounds
Industry	:	All workers
Occupation	:	Preschool Teachers, Except Special Education
Class of Worker	:	All workers
Requirements	:	Physical demands
Type of cases	:	Maximum weight lifted/carried

That is the 50th percentile.  As generally performed, the work is not light.  

Latest Observation:Annual 201780.8

Annual 2017 - Annual 2017Minimum Value: Annual 201780.8
Maximum Value: Annual 201780.8
Data Availability:2017 - 2017

Data extracted on: Dec 14, 2017 (11:27:22 AM)

Occupational Requirements Survey

Series Title	:	Civilian workers; % of preschool teachers, except special education; strength is medium work
Series ID	:	ORUP1000037400000663
Seasonality	:	Not Seasonally Adjusted
Survey Name	:	Occupational Requirements Survey
Measure Data Type	:	Percentage
Industry	:	All workers
Occupation	:	Preschool Teachers, Except Special Education
Class of Worker	:	All workers
Requirements	:	Physical demands
Type of cases	:	Strength

Now that is definitive.  Preschool teachers require medium exertion.  The DOT is rebutted by governmental data.  

Latest Observation:Annual 201715.8

Annual 2017 - Annual 2017Minimum Value: Annual 201715.8
Maximum Value: Annual 201715.8
Data Availability:2017 - 2017

Data extracted on: Dec 14, 2017 (11:28:28 AM)

Occupational Requirements Survey

Series Title	:	Civilian workers; % of preschool teachers, except special education; strength is light work
Series ID	:	ORUP1000037400000662
Seasonality	:	Not Seasonally Adjusted
Survey Name	:	Occupational Requirements Survey
Measure Data Type	:	Percentage
Industry	:	All workers
Occupation	:	Preschool Teachers, Except Special Education
Class of Worker	:	All workers
Requirements	:	Physical demands
Type of cases	:	Strength

Makes sense, some preschool teachers engage in light exertion.  We get past step four and straight into step five.  Transferability is present but it is one occupation.  That does not qualify as a range of work.