Showing posts with label soeuq. Show all posts
Showing posts with label soeuq. Show all posts

Thursday, September 18, 2025

Addresser -- A Persistent Favorite of Vocational Witnesses

Assume a person of the same age, education, and work experience of the claimant and assume that the person is limited to sedentary work, sitting six hours in an eight-hour day, frequent handling, frequent fingering, and limited to simple work with no more than occasional interactions with coworkers, supervisors, and the public. Any work?

That person could work as an addresser representing 30,000 jobs in the national economy. 

Is that occupation performed as described in the DOT.

Sometimes workers use typewriters and hand-address labels and envelopes. Sometimes the worker will simply apply labels to envelopes, packages, and cards.

We have heard the mantra. It is nonsense. It is also the recommended explanation that SSA gives to VW in their training. Let's also beat them at their own game.

SkillTRAN estimates that addresser works in eight industries and is also self-employed for a total of 1,952 jobs. Self-employed work is not unskilled work -- it is running a business. Most of the jobs exist in local government, 1,253 jobs. SkillTRAN does not support the existence of 30,000 addresser jobs. 

The OEWS estimates 36,030 jobs for word processors and typists (SOC 43-9022). The EP, OOH, and O*NET reporting the same data set estimate 40,000 jobs. It is curious that a word processor is applying labels. There might be people applying pre-printed labels but they are not word processors and typists, they are general office clerks or mail clerks. The crosswalk places addresser in word processors and typists. The OEWS and OOH defines word processors and typists:

Use word processor, computer, or typewriter to type letters, reports, forms, or other material from rough draft, corrected copy, or voice recording. May perform other clerical duties as assigned. Excludes “Court Reporters and Simultaneous Captioners” (27-3092), “Medical Transcriptionists” (31-9094), “Secretaries and Administrative Assistants” (43-6010), and “Data Entry Keyers” (43-9021).

The O*NET omits the "excludes" portion of the description but is otherwise identical. None of the descriptions leave room for application of labels. 

The crosswalk tells us that word processors and typists contains eight DOT codes, one of them is unskilled, all are sedentary. We should doubt that all word processors and typists are unskilled addressers. 

The 2023 ORS confirms that word processors and typists represent sedentary work in greater than 99.5% of jobs. Call it 100% and move on. The ORS estimates that 26.3% of jobs have up to one month of training. Semi-skilled and skilled work represent 70.6% of jobs. The "less than" estimate of 10% of jobs with a short demonstration (up to four hours) contains all the standard error. If the five state estimates are accurate, the residual is 3.1% of jobs. Let's round up and call it 30% of jobs are unskilled. That means that 10,800 jobs are sedentary and unskilled. Call that progress. 

The ORS describes greater than 50% of jobs have a choice of sitting or standing, less than 50% do not have a choice. Word processors and typists sit 75% of the day at the 10th percentile and more than 75% of the day at all other reported percentiles. Because the "choice" of sitting or standing is "when" and not "how much," the conclusion would leave a person limited to six hours of sitting in a day to 1,080 jobs. 

The O*NET confirms the obvious -- clerical employees work together with other employees. Word processors and typists have constant contact with other in 69% of jobs and most of the time in 31% of jobs. Any limitation on contact or interaction with others eliminates all jobs. The ORS describes all jobs as requiring at least basic people skills. The ORS states that word processors and typists have verbal interactions less than hourly in 23.8% of jobs. The ORS might lead to 2,400 jobs. 

Finally, my favorite source of job numbers. The OEQ assumes 258,841 word processor and typist jobs with one-eighth of them sedentary and unskilled, to wit 32,385 jobs. The SOEUQ suggests 22,695 jobs. Both sources claim reliance on the OES which is the OEWS. We started with the OEWS -- 36,030 jobs total. 

The existence of 30,000 addresser jobs is not sustainable. The only source consistent with that estimate is the OEQ. The SOEUQ contradicts that estimate and comes from the same publisher. Both sources state reliance on the OES, which does not exist. The OEWS and the EP/OOH/O*NET are wholly inconsistent with the OEQ/SOEUQ. And we end where we started, word processors and typists do not affix labels to envelopes, packages, and cards. That is not their job.

The Emergency Message tells the adjudicator to get a further explanation for addresser. When the adjudicators suggest and explanation without looking at the occupational description, we end with a conspiracy to commit idiocy. SSA should go back to the promise made almost 50 years ago -- take administrative notice of jobs, requirements, and job numbers. 

Disgusted.


___________________________


Suggested Citation:

Lawrence Rohlfing, Addresser -- A Persistent Favorite of Vocational Witnesses, California Social Security Attorney (September 12, 2025) https://californiasocialsecurityattorney.blogspot.com


The author has been AV-rated since 2000 and listed in Super Lawyers since 2008.



















Wednesday, February 26, 2025

What's Wrong with SSR 24-3p?

 SSR 24-3p introduces a new interpretation of the stable administrative notice regulation, 20 CFR 404.1566(d). The Commissioner has long held as a matter of law to the proposition that when it comes to unskilled sedentary, light, and medium work, the Commissioner will take administrative notice of reliable governmental and other (private) published data for the requirements and numbers of jobs. SSR 00-4p responded to a growing number of cases -- and a split in the circuits -- that the ALJ must address conflicts between vocational testimony and the Dictionary of Occupational Titles (DOT). 20 CFR 404.1566(d)(1). The Commissioner conceded to the fact that the Selected Characteristics of Occupations (SCO) was part of the single data set. SSR 00-4p imposed on the ALJ the duty to investigate the existence of a conflict or apparent conflict and to resolve that conflict based on evidence. 

But the DOT and its dataset never stated job numbers, never. Job numbers are now and in 1978 stated in the Occupational Outlook Handbook (OOH) and County Business Patterns (CBP). 20 CFR 404.1566(d)(2), (5).Now, the Bureau of Labor Statistics publishes online the Employment Projections (EP) and the Occupational Employment and Wage Statistics (OEWS, formerly the OES). 

Labor abandoned the DOT and its data set never updating the DOT fourth edition, revised published in 1991 or the SCO published in 1993. Labor transferred responsibility of the Employment Training Administration from the DOT to the Occupational Information Network (ONET). Recognizing the problem that 10,000 of the 13,000 DOT codes had a date last updated of 1977, the Commissioner was forced to collaborate with Labor to develop a new data set -- the Occupational Requirements Survey (ORS). 

Private sources published data as well. United Stat Publishing published and publishes what is now known as the Occupational Employment Quarterly (OEQ) in various formats for national, state, and local data. That publication uses the equal distribution method of estimating job numbers -- each DOT code within a Standard Occupational Classification (SOC) represents the same number of jobs. The OEQ publishes the job numbers sorted by exertion/skill combinations. United Stat Publishing also publishes the Specific Occupational Employment - Unskilled Quarterly (SOEUQ). The SOEUQ estimates sedentary occupations by industry. The SOEUQ does not state its methodology. 

SkillTRAN publishes OccuBrowse, Job Browser Pro, and OASYS. The latter two estimate job numbers by DOT code. SkillTRAN uses a SOC/OEWS code intersection with selected industries (NAICS codes) and uses equal distribution to estimate the number of jobs per DOT code at those SOC-NAICS intersections. SkillTRAN uses a proprietary and unpublished methodology and does not use the data from the EP or OEWS that publish SOC-NAICS data. SkillTRAN uses the CBP to modify the data. The SkillTRAN SOC-NAICS data resembles but does not duplicate either the EP or OEWS SOC-NAICS data. 

That is the basic lay of the data. Job requirements are still found in the DOT and the Commissioner clings to that data set. Job requirements are found with current data in the ONET and the ORS. Job numbers are still found in the OOH and CBP -- they are up to date -- as well as the EP and OEWS. Three data sets for requirements and four data sets for job numbers. No one should use the OEQ for any purpose. JBP and OASYS continue to have utility for stating the SOC-NAICS intersection job numbers but does not parse that data based on occupational classifications nor erode for any impairment. JPB and OASYS are starting points. 

Here is the problem. The vocational witness claims to have considered the broad range of data along with their vast (local and anecdotal) experience to derive a job numbers based on no discernible methodology. Some will default to JBP/OASYS. That is at least a defensible starting point. Some will claim that the OEQ remains in the mix. That is bogus. 

And the ALJ corps blindly accepts testimony that is incoherent and meaningless. The witnesses are not consistent across time. They are not consistent with each other according to the cases. Because the claimants have privacy of their medical data, we never get to see the testimony that the witnesses give in different cases or to compare different witnesses in same and similar cases. The system lacks accountability and reliability. The system invoked by SSR 24-3p creates vocational witness lottery. That is not a system of administrative justice; it is legalized gambling with people's lives and the social safety net. 

But I never get passionate about these issues. 


___________________________

Suggested Citation:

Lawrence Rohlfing, What's Wrong with SSR 24-3p?, California Social Security Attorney (February 26, 2025)  https://californiasocialsecurityattorney.blogspot.com


The author has been AV-rated since 2000 and listed in Super Lawyers since 2008.




Sunday, September 12, 2021

Comparison of the NAICS Code Assignments for JBP and the SOEUQ


 

Comparing data points of the occupation industry intersection between Job Browser Pro and Specific Occupational Employment - Unskilled Quarterly for sedentary occupation in production workers all other (SOC 51-9199). 

52 SEDENTARY UNSKILLED PRODUCTION WORKERS, ALL OTHER –

JPB AND SOEUQ NAICS

 

 

51-9199 -- Production Workers, all other

 

 

DOT

Title

Strength

SVP

O*NET

JBP NAICS

SOEUQ NAICS

 

017.684-010

TAPER, PRINTED CIRCUIT LAYOUT (electronic component)

S

2

51-9199

334200
334300
334400
334500
335200
335300
336400

334412

529.685-058

CIGAR-HEAD PIERCER (tobacco)

S

2

51-9199

312200

312229

559.687-034

EGG PROCESSOR (pharmaceuticals)

S

2

51-9199

325400

325414

579.684-022

MICA-PLATE LAYER, HAND (mine & quarry)

S

2

51-9199

212300
213000

327990

585.665-010

NAPPER TENDER (knitting)

S

2

51-9199

315000

315110

654.687-014

PAGER (machinery mfg.)

S

2

51-9199

3330A1
333300

333293

685.687-026

TOPPER (knitting)

S

2

51-9199

315000

315100

689.585-018

STRINGING-MACHINE TENDER (textiles, other)

S

2

51-9199

314000

314911
316993

692.685-206

STOP ATTACHER (button & notion)

S

2

51-9199

339900

339911
339993

700.687-018

BRIMER (metal products, other)

S

2

51-9199

3320A1
332800

331491

700.687-026

CHARGER II (jewelry-silverware)

S

2

51-9199

**

339911

700.687-062

PREPARER (jewelry-silverware)

S

2

51-9199

339910

339911
339914

706.684-030

ATOMIZER ASSEMBLER (fabrication, nec)

S

2

51-9199

3250A2
339900

339999
325620

713.687-018

FINAL ASSEMBLER (optical goods)

S

2

51-9199

339100

339115
446130

713.687-026

LENS INSERTER (optical goods)

S

2

51-9199

339100

339915

715.684-010

ADJUSTER, ALARM MECHANISM (clock & watch)

S

2

51-9199

334500

334518

715.684-026

BENCH HAND (clock & watch)

S

2

51-9199

334500

334518

715.684-082

DIAL-SCREW ASSEMBLER (clock & watch)

S

2

51-9199

334500

334518

715.684-146

OILER (clock & watch)

S

2

51-9199

334500

334518

715.684-178

SET-STAFF FITTER (clock & watch)

S

2

51-9199

334500

334518

715.685-038

MAINSPRING WINDER AND OILER (clock & watch)

S

2

51-9199

334500

334518

715.687-010

BAND ATTACHER (clock & watch)

S

2

51-9199

334500

334518
316993

715.687-018

CRYSTAL ATTACHER (clock & watch)

S

2

51-9199

334500

334518

715.687-022

DIAL BRUSHER (clock & watch)

S

2

51-9199

334500

334518

715.687-078

MAINSPRING FORMER, ARBOR END (clock & watch)

S

2

51-9199

334500

334518

715.687-082

MAINSPRING FORMER, BRACE END (clock & watch)

S

2

51-9199

334500

334518

715.687-094

MOUNTER, CLOCK AND WATCH HANDS (clock & watch)

S

2

51-9199

334500

334518
423940

715.687-114

ROTOR ASSEMBLER (clock & watch)

S

2

51-9199

334500

334518

723.687-010

PATCHER (household appliances)

S

2

51-9199

3330A1
335200
335900

335211

725.687-022

GETTERER (light fixtures)

S

2

51-9199

334400
334500
335100
335900
336300

335110

731.687-014

FINISHER (fabrication, nec)

S

2

51-9199

333300
335100
335200
339900

339931

732.587-010

GOLF-BALL TRIMMER (toy-sport equipment)

S

2

51-9199

339900
811400

339920

732.684-062

FISHING-REEL ASSEMBLER (toy-sport equipment)

S

2

51-9199

339900

339920

734.684-010

FEATHER SHAPER (button & notion)

S

2

51-9199

333300
335100
339900
453900

339914

734.687-010

ACETONE-BUTTON PASTER (button & notion)

S

2

51-9199

339900

339911
339993

734.687-018

ASSEMBLER (button & notion)

S

2

51-9199

339900

339999
541890

734.687-034

BUCKLE-WIRE INSERTER (button & notion)

S

1

51-9199

339900

339911
339993

734.687-058

HOT-STONE SETTER (button & notion)

S

2

51-9199

339900

339914
339993
339999

734.687-074

SLIDE-FASTENER-CHAIN ASSEMBLER (button & notion)

S

2

51-9199

339900

339993
339999

734.687-09-0

STICKER (button & notion)

S

1

51-9199

333300
335100
335200
339900
453900

333999
453100

735.687-022

PIN-OR-CLIP FASTENER (jewelry-silverware)

S

2

51-9199

**

339911
339914
339999

735.687-034

STONE SETTER (jewelry-silverware)

S

2

51-9199

339910

339911
339914
339999

739.684-094

LAMP-SHADE ASSEMBLER (fabrication, nec)

S

2

51-9199

326000
326100
326200
335100
339900

335121

739.685-050

TAPPER, SHANK (fabrication, nec)

S

2

51-9199

339900
453900

339999

739.685-054

UMBRELLA TIPPER, MACHINE (fabrication, nec)

S

2

51-9199

339900

339999

739.687-066

COMPACT ASSEMBLER (jewelry-silverware)

S

2

51-9199

3250A2


325620

739.687-086

EYE-DROPPER ASSEMBLER (glass products)

S

2

51-9199

**

339911
339914
339999

774.687-014

LACER (nonmetallic mineral)

S

2

51-9199

**

327112

779.684-034

LEVEL-VIAL SEALER (cutlery-hardware)

S

2

51-9199

3320A1


327215

784.684-030

FOUNDATION MAKER (hat & cap)

S

2

51-9199

314000
315000

315991

788.687-158

VAMP-STRAP IRONER (boot & shoe)

S

2

51-9199

316000

316999

789.687-022

BUFFING TURNER-AND-COUNTER (textiles, other)

S

2

51-9199

314000

331499


These 52 occupations reveal discrepancies between industry assignments between JBP and the SOEUQ.  Where the two publications agree to the non-zero digits, the designation with more non-zero digits is more detailed.  Where the two publications disagree on the industry assignments at the third or forth digit, JBP and the SOEUQ have a material conflict.

Taper, printed circuit layout has seven NAICS codes.  JBP identifies four industry groups within the computer and electronic product manufacturing subsector (NAICS 334000), two industry groups within electrical equipment, appliance, and component manufacturing (NAICS 335000), and one industry group within transportation equipment manufacturing (NAICS 336000).  The SOEUQ designates the single six-digit industry of bare printed circuit board manufacturing (NAICS 334412).  That creates a conflict that requires resolution.  All the sedentary occupation industry selections for the 52 production worker, all other, occupations have a conflict between JBP and the SOEUQ. 

This list reveals an additional structural defect in JBP as between occupations.   JBP assigns other miscellaneous manufacturing (NAICS 339900) in 15 different DOT codes.  JBP assigns jewelry and silverware manufacturing (NAICS 339910) in two occupations.  Jewelry and silverware manufacturing industry (five digits) is a subset of other miscellaneous manufacturing industry group (four digits).  Failure to account for the two occupations in jewelry and silverware manufacturing when estimating the job numbers for those DOT codes assigned to other miscellaneous manufacturing, and vice versa, results in an overestimate of job numbers for those 17 DOT codes.  The job numbers are small in this instance.  Other occupations outside of production workers, all other, involve significant over and double counting of jobs.  

 It matters because industry is an integral and inseparable part of every DOT description.  DICOT, Introduction, parts of the occupational definition. 

___________________________

Suggested Citation:

Lawrence Rohlfing, Comparison of the NAICS Code Assignments for JBP and the SOEUQ, California Social Security Attorney (September 12, 2021)  https://californiasocialsecurityattorney.blogspot.com