No Teamwork -- A Look at Helpers - Production Workers

The claimant has a limitation to no teamwork.  The vocational expert rolls out the standard list of unskilled jobs.  Simple question:

Q.  Does the Department of Labor publish data that confirms your testimony.

Turns out that DOL does.  In the occupational group of Helpers - Production Workers, we find 12 of the unskilled sedentary occupations; 157 of the light unskilled occupations; and 172 of the medium unskilled occupations.  There are 111 heavy and very heavy unskilled occupations as well.  This is a big occupational base and balance of the 782 occupations in this huge group requires some level of skill.  

Now that we established the importance of this occupational group in the 2,400 unskilled sedentary to medium occupations, we can focus on the incumbent perception of the incidence and importance of working with a team in 341 sedentary, light, and medium unskilled occupations.  Here is what the O*NET says about this group (from OccuCollect):  

Interpersonal Relationships	%	Response
Work With Work Group or Team — How important is it to work with others in a group or team in this job?	28	Extremely important
	50	Very important
	12	Important
	2	Fairly important
	8	Not important at all

The O*NET suggests that Helpers - Production Workers work with a team and that it is at least fairly important in 92% of jobs.  If the hypothetical question includes no teamwork or includes an occasional contact with co-workers and supervisors, the O*NET provides a basis for cross-examination.  

Q.  Is your experience less than, equal to, or greater than the survey of incumbents conducted in the collection of O*NET data?

We should check some of the other interpersonal relationship data for this occupational group:

Interpersonal Relationships	%	Response
Contact With Others — How much does this job require the worker to be in contact with others (face-to-face, by telephone, or otherwise) in order to perform it?	39	Constant contact with others
	24	Contact with others most of the time
	20	Contact with others about half the time
	17	Occasional contact with others
	0	No contact with others

Coordinate or Lead Others — How important is it to coordinate or lead others in accomplishing work activities in this job?	17	Extremely important
	16	Very important
	39	Important
	8	Fairly important
	21	Not important at all

Deal With External Customers — How important is it to work with external customers or the public in this job?	4	Extremely important
	15	Very important
	13	Important
	11	Fairly important
	57	Not important at all

Responsible for Others' Health and Safety — How much responsibility is there for the health and safety of others in this job?	20	Very high responsibility
	14	High responsibility
	50	Moderate responsibility
	16	Limited responsibility
	0	No responsibility

Helpers - Production Workers not only engage in teamwork in 92% of jobs, they have moderate or greater responsibility for safety of other in 84% of jobs; deal with customers in 43% of jobs; coordinate or lead others in 79% of jobs; and most importantly have more than occasional contact with others in 83% of jobs.  

Here is the OOH report (from OccuCollect):  

Occupational Outlook Handbook Report

Quick Facts: Helpers--production workers
Typical Entry-Level Education	High school diploma or equivalent
Work experience in a related occupation	None
On the job training	Short-term on-the-job training
Number of jobs, 2016	426,000
Employment Projections	XLSX

While 8% of the number of jobs is a big number, how many of them have the other characteristics contained in the hypothetical question and how do you know that?  Vocational experts are not statisticians.  

Maids and Housekeeping Cleaners -- Standing, Walking; Full-Time; and Public

A staple of the vocational expert corps -- housekeeping cleaners and hospital cleaners as light unskilled work with simple repetitive tasks or one- and two step instructions and little public contact. 

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

323.687-014 CLEANER, HOUSEKEEPING (any industry) alternate titles: maid

    Cleans rooms and halls in commercial establishments, such as hotels, restaurants, clubs, beauty parlors, and dormitories, performing any combination of following duties: Sorts, counts, folds, marks, or carries linens. Makes beds. Replenishes supplies, such as drinking glasses and writing supplies. Checks wraps and renders personal assistance to patrons. Moves furniture, hangs drapes, and rolls carpets. Performs other duties as described under CLEANER (any industry) I Master Title. May be designated according to type of establishment cleaned as Beauty Parlor Cleaner (personal ser.); Motel Cleaner (hotel & rest.); or according to area cleaned as Sleeping Room Cleaner (hotel & rest.).
GOE: 05.12.18 STRENGTH: L GED: R1 M1 L1 SVP: 2 DLU: 86

 The O*NET OnLine informs as that this is a huge occupational base with 10 DOT codes covering 1,458,000 jobs.  The first line of attack focuses on standing and walking and the need to sit for two hours per day in most light work findings.  The work context report states that these jobs require standing continually or almost continually in 80% of jobs.  Walking or running are required continually or almost continually in 70% of jobs.  Sitting never happens in 91% of jobs.  A tenth of 1.4 million jobs is still a lot of jobs.  We need more reasons to erode this occupation as not a realistic option for the disabled beyond standing and walking six of eight hours as precluding this kind of work. 

Does the occupation represent substantial gainful activity as it is performed in the national economy?  The O*NET OnLine suggests, "no." 

22

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

 Most of the jobs are not full-time.  The occupation has median hourly wages of $10.48 per hour per the O*NET OnLine wages and employment trends report.  SGA for 2018 is $1,080 per month.  A worker needs 23.3 hours per week, every week, 52 weeks a years to get over that threshold.  Do the less than full-times maids and housekeepers work in excess of half-time and how does the vocational expert know that data? 

A third line to pursue in cross-examination focuses on the occasional public contact.  The  work context report states that these jobs involve contact with the public addresses the question on frequency and on the importance of contact with the public. 

87

Contact With Others — How much does this job require the worker to be in contact with others (face-to-face, by telephone, or otherwise) in order to perform it?

59    Constant contact with others 35    Contact with others most of the time 2    Contact with others about half the time 3    Occasional contact with others 2    No contact with others

35

Deal With External Customers — How important is it to work with external customers or the public in this job?

8    Extremely important 21    Very important 6    Important 34    Fairly important 31    Not important at all

Maids and housekeeping cleaners have more than occasional contact with others in 96% of jobs.  The contact with the public is at least fairly important in 69% of jobs. 

Putting the three moving parts together:  most maids and housekeepers require standing and walking to the exclusion of any sitting in over 90% of jobs; 60% of those jobs are not full-time; 96% of those jobs require frequent contact with others; and the contact with the public constitutes an important job function in 69% of jobs.  With limited standing and walking to six hours; simple repetitive tasks; and occasional contact with others -- there isn't much of anything left.