Monday, April 3, 2017

Production Workers, All Other -- Are There Significant Numbers of Unskilled Jobs?

We discuss, again, the often cited occupational group of production workers, all other.  This occupational group travels under the Standard Occupational Classification code 51-9199.  The O*NET lists 1,590 DOT codes in this group.  The Occupational Outlook Handbook moved 60 DOT codes to food processing workers, all other (SOC 51-3099) between 2010 and 2012.  We can prove that another day.  The focus of this article addresses the question of whether unskilled production worker, all other jobs exist in significant numbers.

We start with the concept of administrative notice.  The Commissioner "will take administrative notice" of the OOH.  20 C.F.R. §§ 404.1566(d)(5); 416.966(d)(5).  Because the Commissioner takes administrative notice of the OOH, we can use it to rebut vocational expert testimony.  Since the Commissioner takes administrative notice of the OOH, we need to examine what it says about this huge accumulation of DOT codes:

Production workers, all other
All production workers not listed separately.
  • 2014 employment: 236,200
  • May 2015 median annual wage: $27,950
  • Projected employment change, 2014–24:
    • Number of new jobs: 7,700
    • Growth rate: 3 percent (Slower than average)
  • Education and training:
    • Typical entry-level education: High school diploma or equivalent
    • Work experience in a related occupation: None
    • Typical on-the-job training: Moderate-term on-the-job training
  • O*NET:
The occupational group requires a high school diploma or equivalent.  That means that the majority of these occupations are unavailable to individuals with a limited or marginal education absent some factor that suggests a higher educational level capacity than achieved in school.  

The occupational group does not require experience.  These are entry-level jobs.  

The occupational group entails moderate-term on-the-job training.  These jobs are not unskilled.  

Are there some unskilled occupations and jobs inside of production workers, all other?  Maybe, but not very many.  The occupational group exists in industries not encompassed by the DOT.  The economy changed between 1977 when some of the DOT codes were last updated and changed again since 1991 when Labor last published the revised DOT.  The OOH is a source of administrative notice; it is listed on the Vocational Expert Handbook as mandatory familiarity for the vocational expert.  But when a vocational expert testifies to 30,000 sedentary unskilled and 100,000 light unskilled jobs in this occupational base, the responsible representative must ask for an explanation.  Ignorance of the OOH just means that the witness cannot provide a reasonable basis for resolving the conflict.  

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