Common DOT Codes -- Sedentary Unskilled -- Lens Block Gauger; Table Worker; Touch-Up Screener

Sedentary work that does not exceed six hours of sitting in an eight-hour day represents a small window.  The DOT and the regulations define sedentary work as involving standing or walking not more than occasionally, 2.3 hours.  Sedentary work as depicted by a residual functional capacity question with a lower limit of 5.7 hours an upper limit of 6.0 hours constitutes a slender reed.  

 Understanding sedentary work rests on the difference between and and or.  Light work exists (1) when it requires walking or standing to a significant degree; OR (2) when it requires sitting most of the time but entails pushing and/or pulling of arm or leg controls; AND/OR (3) when the job requires working at a production rate pace entailing the constant pushing and/or pulling of materials even though the weight of those materials is negligible.  

Sedentary work exists when the work (1) when it does not require walking or standing to a significant degree; AND (2) when it requires sitting most of the time and does not involve pushing and/or pulling of arm or leg controls; AND (3) when the job requires working at a production rate pace but does not entail the constant pushing and/or pulling of materials even though the weight of those materials is negligible.  Transgressing the standing/walking, lifting/carrying, pushing/pulling with the arms or legs, or production rate pace strips away any hope for that sedentary label.  

The cadre of vocational experts rely on 16 different DOT codes in the sedentary range.  Ignoring obsolescence and industry, the question is whether the occupations are unskilled, sedentary, and do not exceed 6.0 hours of sitting in a full-time workday.  

9.  Lens Block Gauger 

10.  Table Worker

11.  Touch-Up Screener

Lens block gauger, table worker, and touch-up screener belongs to the occupational group Inspectors, Testers, Sorters, Samplers, and Weighers (SOC 51-9061) (inspectors).  Inspectors represent about 550,000 jobs in the national economy.  Inspectors contains 782 DOT codes, 14 sedentary and unskilled.  This group contains 135 light unskilled DOT codes.  The significant segment of the unskilled occupational base for sedentary and light work are right here.    

The O*NET Resource Center describes the three component of SVP: on-the-job training, related work experience, and required level of education separately.  

On-the-Job Training
Duration	Value
None or short demonstration	0%
Anything beyond short demonstration, up to and including 1 month	22.61%

Related Work Experience
Duration	Value
None	43.9%
Up to and including 1 month	0%

Required Level of Education
Education Level	Value
Less than a High School Diploma	0%
High School Diploma or the equivalent	69.81%

Using the O*NET Resource Center, incumbent data suggests that 23% of the jobs are unskilled.

The ORS data corresponds with the OTJ information from the O*NET Resource Center, about 18% of inspector jobs represent unskilled work.  The OccuCollect calculator uses the Occupational Outlook Handbook numbers, about 100,980 unskilled inspector jobs at all exertion levels.  

The next step in estimating the number of unskilled sedentary inspector jobs is to tease that conclusion from the data.  We start again with the O*NET OnLine:

Exertional	%	Response
Spend Time Sitting — How much does this job require sitting?	0	Continually or almost continually
	14	More than half the time
	25	About half the time
	44	Less than half the time
	17	Never

Spend Time Standing — How much does this job require standing?	41	Continually or almost continually
	7	More than half the time
	44	About half the time
	8	Less than half the time
	0	Never

Spend Time Walking and Running — How much does this job require walking and running?	35	Continually or almost continually
	18	More than half the time
	12	About half the time
	35	Less than half the time
	1	Never

The O*NET suggests that there are no sedentary inspector jobs in the national economy.  We check that conclusion against the ORS:

Sitting is Required
% Of Day	Percentile
<= 39.2%	Mean
<= -%	10th
<= 15%	25th
<= 25%	50th
<= 75%	75th
<= 90%	90th

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

The sitting alone would allow an inference of 25% or more sedentary inspector jobs.  The specific statement reduces that percentage to 10%.  This means that there are 15% or more of inspector jobs that are sit down and light or greater in exertion.  

Treating skill and exertion as independent variables, about 10,100 inspector jobs could qualify as unskilled sedentary work in 14 different DOT codes.  The jobs most likely to qualify as sedentary require sitting 90% of the workday.  It is unlikely that any of these jobs permit sitting not more than six hours in an eight-hour day based on that measure.  

The ORS reports that inspectors have a choice of sitting or standing during the workday in 36% of jobs.  The ORS reports that 55% of inspectors have the ability to pause work.    Over 96% of inspectors work at either a fast pace or a varying work pace.  Whether any of these occupations would represent a sedentary work environment with a sit-stand option as opposed to sitting down during light and medium work would require a formal job analysis of a statistically relevant sample of those jobs.  

Without that statistical analysis, the best informed inference would treat the presence of sedentary and the choice of sitting or standing as independent variables.  That would put an estimate of around 4,000 jobs in 14 DOT codes.  There is no basis for dividing the choice of when to perform duties that require standing/walking from a true unaccommodated choice of sitting or standing at the workstation.  Estimating the number of jobs with a workstation sit-stand option is a probably pulled out of a hat.  

___________________________

Suggested Citation:

Lawrence Rohlfing, Common DOT Codes -- Sedentary Unskilled -- Lens Block Gauger; Table Worker; Touch-Up Screener, California Social Security Attorney (December 31, 2021)  https://californiasocialsecurityattorney.blogspot.com   

Sedentary, Simple Repetitive Tasks Equals No Significant Work

 The title of this piece sets forth the foundation and conclusion.  It does not matter whether the person is 21 years with a Ph.D. in astrophysics from MIT awarded at the age of 18.  Sedentary with simple repetitive tasks equals no significant number of jobs.

Here is the hypothetical from a real case:

Q And the first hypothetical I'd like you to consider is where the individual could perform a full range of sedentary work as it's defined in regulations. And can understand, remember and carry out simple routine tasks for up to two-hour periods of time; with only occasional interaction with the general public. There should be no fast-paced production or assembly line type work, and only minimal changes in workplace setting or routine. Given these limitations would this individual be able to perform any of the work that the claimant has performed in the past?

A No, Your Honor.

Q Would there be other work that such an individual could perform, and if so can you provide me with three examples?

A Yes. Surveillance system monitor, sedentary, SVP 2, the DOT is 379.367-010, approximately 150,000 full-time jobs in the national economy which I would erode by 50 percent down to 75,000 jobs based upon the DOT designating it, that precludes the government positions. Sedentary SVP 2, the job is assembler, the DOT is 734.687-018, approximately 125,000 full-time jobs in the national economy. And sedentary SVP 2, the job is table worker, the DOT is 739.687-182, approximately 40,000 full-time jobs in the national economy.

Q All right. Let me give you a second hypothetical, and this is adding on to the first. If the individual required at least one unscheduled break of 15 to 20 minutes in addition to regular breaks and lunch in an eight-hour workday, due to chronic pain, side effects with medication and/or possibly psychological symptoms, would that preclude those jobs that you identified in response to hypothetical number one?

A Yes.

Q Would there be any other work at that level?

A No. That would, that would call for an accommodation.

Q Is your testimony consistent with the Dictionary of Occupational Titles?

A It is.

There are so many things wrong with this vocational testimony that a representative might feel overwhelmed by the force of experience and administrative momentum.  Clearly the second hypothetical question is the opioid slipped to the claimant to make him/her think that he/she was finally heard and will win the case.  We know that the feel good will disappear when the hearing decision comes.  Advocate it all you want, but we know better.  The anecdotal experience that one time the ALJ went that way is just that, anecdotal lightning in a bottle.  

It is incumbent on the responsible representative to go after the vocational expert.  We discussed this before, "what is your methodology for determining the number of jobs as a surveillance systems monitor, assembler, and table worker?"  Lock that down.  If the vocational expert gives the opaque black box testimony, leave it there and move on.  This is not a time to argue, it is a time to allow the witness to hang him/herself.  

Regardless of the methodology the vocational expert regurgitates, present conflicting evidence. 

1. Job Browser Pro

a. Job Browser Pro assigns SSM to two occupational groups.  JBP currently states that that OEWS/SOC group of school bus monitors and protective service workers, all other (33-9098) represents in the aggregate 144,310 jobs.  Gaming surveillance officers and gambling investigations  (33-9031) represents 8,340 jobs.  Those two occupational groups together represent about 10,000 jobs attributed to SSM. 

b. JBP assigns assembler to production workers, all other (51-9199) representing 194,360 jobs in 1,528 occupations. Assembler identified by the vocational expert represents an estimated 17 jobs in the nation.  

c. JBP assigns table worker to inspectors, testers, sorters, samplers, and weighers (51-9061)representing 549,200 jobs in 782 occupations.  Table worker identified by the vocational expert represents an estimated 962 jobs.  

The ALJ must resolve the conflict in the evidence with a logical and rational basis.  Administrative notice is the preferred method of estimating job numbers.  20 CFR 404.1566(d).  Testimony answers questions that notice cannot answer.  20 CFR 404.1566(e).  Create the conflict and submit the JBP reports for the OEWS Group and the DOT Employment Estimate.  JBP considers industry and the vocational expert did not.  

2. Occupational Data

a. SSM is a reasoning level 3 occupation and therefore has an apparent conflict with simple repetitive work.  The OOH states that gambling officers and investigators are semi-skilled and skilled.  The O*NET OnLine states that gambling officers and investigators do not deal with the public as an important or fairly important job function in 34% of jobs.  The O*NET resource center states that gambling officers and investigators have on-the-job training not exceeding one month in 16.8% of jobs.  Gambling officers and investigators sit 90% of the day or more in all jobs according to the ORS.  Neither the ORS nor the O*NET provide data for school bus monitors and protective service workers, all other.  

b. Assembler is a reasoning level 1 occupation.  It is simple with little changes.  Assembler does require constant use of the hands for reaching, handling, and fingering.  That creates a conflict with no fast paced work.  The OOH states that production workers are semi-skilled and skilled representing 203,600 jobs.  The ORS states that production workers engage in unskilled work in 28.7% of jobs.  Production workers stand 90% of the day or more at every reported percentile.  Production workers engage in medium work in 68.9% of jobs.  

c. Table worker is a reasoning level 1 occupation.  It is simple with little changes. Table worker requires working on a conveyor belt.  That creates a conflict with no assembly line type of work.  The OOH states that inspectors are semi-skilled and skilled representing 557,900 jobs.  The O*NET OnLine states that inspectors do not deal with the public as an important or fairly important job function in 18% of jobs.  The ORS states that inspectors engage in unskilled work in 21.3% of jobs.  Inspectors engage in light work in 53.6% of jobs and medium work in 28.1% of jobs.  Inspectors sit 75% (six hours) at the 75th percentile and 90% of the day at the 90th percentile.  Assuming 20% of the jobs are sedentary  and 20% of those jobs are unskilled (a combined 4%) results in fewer than 40,000 jobs claimed by the vocational expert.  The industries that would employ table workers (plastic and rubber products manufacturing) employ 30,200 inspectors.  Applying the 4% for sedentary and unskilled to that job number results in 1,200 jobs.  That's more than what JBP estimated but reasonably close.  

Competent representation presents either JBP or occupational data to the ALJ post-hearing.  Good representation presents both.  Be good.

___________________________

Suggested Citation:

Lawrence Rohlfing, Sedentary, Simple Repetitive Tasks Equals No Work, California Social Security Attorney (October 16, 2021)  https://californiasocialsecurityattorney.blogspot.com/2021/10/sedentary-simple-repetitive-tasks.html

Table Worker and the ORS

Table Worker (fabrication, nec) has the job of examining linoleum tiles.  The DOT-O*NET crosswalk informs that the occupation belongs to inspectors, testers, sorters, sampler, and weighers (SOC 51-9061).  The sedentary, unskilled, reasoning level 1 occupation is one of 67 sedentary unskilled occupations, five of which have reasoning level 1, out of a total of 782 unique DOT codes.  The Occupational Outlook Handbook reports 520,700 jobs having typical entry level requirements of a high school diploma (or equivalent) and moderate-term on-the-job training. 

Before we turn to the Occupational Requirements Survey, we know that the majority of these jobs require a high school education and are semi-skilled.  The ORS confirms those inferences from the OOH:  83% of inspectors, testers require more than 30 days of training (12.5% require SVP 3; 11.5% require SVP 5; 17.4% require SVP 6; 17.9% require SVP 7; and 13.7% require SVP 8).  The ORS reports that 16.5% require SVP 2.  The two unreported SVP levels are 1 and 4.  They may share 0.5% or those jobs may reside in just one SVP.  The data leaves that hole.  The four sedentary reasoning level 1 occupations require SVP 2; four light occupations require SVP 1 and reasoning level 1; there are 34 DOT codes at all exertion levels that require reasoning level 1.  There are 173 unskilled DOT codes within this group out of the total 782 DOT codes.  Those 173 unskilled DOT codes represent 86,000 jobs if the 16.5% SVP 2 jobs is correct. 

The ORS confirms the OOH observation of education levels:  66.9% have a minimum education level of high school diploma.  Based on HR reporting, the ORS states that 22.4% of jobs have no minimum educational requirement.  That observation does not offend the 86,000 estimate of unskilled jobs in this group spread out among 173 unskilled DOT codes. 

The sitting demands implicate few fall into the sedentary classification.  The ORS reports that at the 90th percentile, inspectors, testers sit 7.2 hours per day.  At the 75th percentile, inspectors testers sit 5 hours per day.  Five hours does not qualify as sedentary so something more than 10% but less than 25% sit enough to qualify as sedentary work.  Inspectors, testers have the flexibility to sit/stand at will in 31.5% of jobs.  The median inspector, tester lifts 25 pounds maximum during the day.  These jobs involve lifting/carrying up to 50 pounds seldom in 56.3% of jobs.  I use Occu Collect to run these reports quickly. 

The SOC-crosswalk lists 67 sedentary DOT codes within inspectors, testers: one unskilled reasoning level 3; nine unskilled reasoning level 2; and four unskilled reasoning level 1.  The other 53 sedentary DOT codes are semi-skilled or skilled. 

Without considering industry, the probable number of unskilled inspector, tester jobs is less than 86,000 jobs and the number of those with sedentary exertion is between 9,000 and 21,500.  Using the equal-distribution method at this end of the line, table workers (fabrication, nec) have a statistical job incidence of less than 5,000.  Using the occupational-density model, we came up with circa 3,000 jobs yesterday. 

Table Worker (fabrication, nec), Examined and Dismantled

The ALJ propounds a sedentary residual functional capacity with a reasoning level of 1.  The vocational expert identifies table worker (739.687-182) (fabrication, nec).  The DOT lists four occupations with the name table worker as the whole title or part of the title:

DOT Code	DOT Title	INDTTL	SVP	STRENGTH	GEDR
739.687-182	TABLE WORKER	(fabrication, nec)	2	S	1
521.687-102	PICKING-TABLE WORKER	(sugar & conf.)	1	L	1
783.687-030	TABLE WORKER	(leather prod.)	1	L	1
788.687-142	TABLE WORKER	(boot & shoe)	2	L	2

The one that meets the hypothetical is the sedentary table worker in the fabrication, not elsewhere classified industry.  The DOT has a short description of this occupation:

739.687-182 TABLE WORKER (fabrication, nec) alternate titles: spotter

    Examines squares (tiles) of felt-based linoleum material passing along on conveyor and replaces missing and substandard tiles. 
GOE: 06.03.02 STRENGTH: S GED: R1 M1 L1 SVP: 2 DLU: 77

What does "fabrication, nec" mean?  Going back to the DOT:

fabrication, nec--MISCELLANEOUS FABRICATED PRODUCTS, NOT ELSEWHERE
CLASSIFIED: This designation includes occupations concerned with
manufacturing and repairing miscellaneous items not included under
another specific designation. These include brooms and brushes of
all types; signs and advertising displays; burial caskets and
related materials, except those made from concrete; floor
coverings, not elsewhere classified; fuel briquettes; candles;
articles, such as wigs, from human, animal, and artificial hair;
matches; models, patterns, mannequins, and wax figures; smoking
pipes; and umbrellas and canes.

That is a long list of examples of what workers manufacture in the fabrication, nec industry.  But the narrative for table worker does not include brooms, sign, caskets, briquettes, candle, matches, mannequins, pipes, umbrellas, or canes.  Table workers inspect linoleum, replacing missing and substandard tiles.  The NAICS Manual contains an explanation that helps:

326199 Tiles, floor (i.e., linoleum, rubber, vinyl), manufacturing

NAICS 326199 is a broad industry designation.  According to Census, the classification has examples:

326199 All Other Plastics Product Manufacturing

This U.S. industry comprises establishments primarily engaged in manufacturing plastics products (except film, sheet, bags, profile shapes, pipes, pipe fittings, laminates, foam products, bottles, and plumbing fixtures).

Illustrative Examples:Inflatable plastics swimming pool rafts and similar flotation devices manufacturingPlastics air mattresses manufacturingPlastics bottle caps and lids manufacturingPlastics bowls and bowl covers manufacturingPlastics clothes hangers manufacturingPlastics cups (except foam) manufacturingPlastics dinnerware (except foam) manufacturingPlastics gloves manufacturingPlastics hardware manufacturingPlastics siding manufacturingPlastics trash containers manufacturingResilient floor coverings (e.g., sheet, tiles) manufacturing

Now that we know a little about the occupation and the industry in which the DOT describes and studied its existence, we need the SOC code used in the modern Labor classification of the occupation.  I use Occu Collect.

DOT Code: 739.687-182

SOC Code: 51-9061.00

O*NET URL: https://www.onetonline.org/link/summary/51-9061.00

DOT-O*NET Crosswalk: https://www.onetonline.org/crosswalk/DOT?s=739.687-182&g=GO

51-9061 Inspectors, testers, sorters, samplers, and weighers

Typical Education Needed	High school diploma or equivalent
Work Experience in a Related Occupation	None
Typical On-The-Job Training Needed to Attain Competency	Moderate-term on-the-job training
2016 Employment	520,700

The first thing that pops out is that this occupational group typically requires a high school or equivalent education and is typically semi-skilled.  The employment projections report 21,000 jobs:

Employment by industry, occupation, and percent distribution, 2016 and projected 2026
51-9061 Inspectors, testers, sorters, samplers, and weighers
(Employment in thousands) Industries with fewer than 50 jobs, confidential data, or poor quality data are not displayed
	Industry		2016
Sort Order	Code	Title	Employment	Percent of industry
1	TE1000	Total employment	520.7	0.3
74	326100	Plastics product manufacturing	21.0	3.7
Source: Employment Projections program, U.S. Department of Labor, U.S. Bureau of Labor Statistics

Two problems arise from this observation: first, table worker is one of 18 DOT codes classified in inspectors, testers; second, this is the industry group, not the industry in which linoleum is manufactured.

CB1600A11
Geography Area Series: County Business Patterns
2016 Business Patterns

		Meaning of		Paid employees
Geographic area name	2012 NAICS code	2012 NAICS code	Year	for pay period including March
				12 (number)
United States	326199	All other plastics product manufacturing	2016	357,473

Source: U.S. Census Bureau, 2016 County Business Patterns.
1 of 1                                                                                     09/14/2018

A statistical estimate 13,226 is reasonable based on the percent of industry employment applied to the specific industry. Job Browser Pro uses the industry group reported by the EP and the industry group for rubber product manufacturing with 7 and 24 total DOT codes at the SOC/NAICS intersection. With those assumptions, JBP estimates less than 3,200 jobs as a table worker (fabrication, nec).

The all other plastic products manufacturing industry covers a wide range of products and no data suggests that those occupations employ sedentary inspectors.  The best conclusion to draw from this analysis is simple -- Job Browser Pro overestimates the number of jobs in the economy .