Thursday, May 31, 2018

Transferable Skills to Telephone Solicitor, Part 1 -- the OOH

Vocational expert assumes the presence of a work history that includes selling cable television service to walk-in customers.

    Contacts homeowners, apartment managers, and other prospects to sell cable television service: Compiles list of prospective customers from lists of homes that do not have cable television and lists of residential addresses with names of owners and occupants. Travels throughout assigned territory to call on prospective customers in their homes to solicit orders. Performs duties as described under SALES REPRESENTATIVE (retail trade; wholesale tr.) Master Title.
GOE: 08.02.06 STRENGTH: L GED: R4 M3 L4 SVP: 3 DLU: 88

The ALJ directs the VE to assume a limitation to sedentary work.  Vocational expert identifies the occupation:

299.357-014 TELEPHONE SOLICITOR (any industry) alternate titles: telemarketer; telephone sales representative
    Solicits orders for merchandise or services over telephone: Calls prospective customers to explain type of service or merchandise offered. Quotes prices and tries to persuade customer to buy, using prepared sales talk. Records names, addresses, purchases, and reactions of prospects solicited. Refers orders to other workers for filling. Keys data from order card into computer, using keyboard. May develop lists of prospects from city and telephone directories. May type report on sales activities. May contact DRIVER, SALES ROUTE (retail trade; wholesale tr.) 292.353-010 to arrange delivery of merchandise.
GOE: 08.02.08 STRENGTH: S GED: R3 M3 L3 SVP: 3 DLU: 88

The regulations describe transferability:
(2) How we determine skills that can be transferred to other jobs. Transferability is most probable and meaningful among jobs in which—
(i) The same or a lesser degree of skill is required;
(ii) The same or similar tools and machines are used; and
(iii) The same or similar raw materials, products, processes, or services are involved.
We assume each of those factors for this discussion.

Focusing in on the object occupation, telephone solicitor, we discover that it belongs to the occupational group of telemarketers, SOC 41-9041.  The O*NET OnLine describes an SVP of 4.0 to < 6.0.  That detail page does not contain a link to the Occupational Outlook Handbook.  That means that the OOH does not contain detailed information about telemarketers.  The occupation is on the long list of occupations not covered in detail.  The OOH describes telemarketers:

Telemarketers
Solicit donations or orders for goods or services over the telephone.
  • 2016 employment: 216,600
  • May 2017 median annual wage: $24,460
  • Projected employment change, 2016–26:
    • Number of new jobs: 0
    • Growth rate: 0 percent (Little or no change)
  • Education and training:
    • Typical entry-level education: No formal educational credential
    • Work experience in a related occupation: None
    • Typical on-the-job training: Short-term on-the-job training
  • O*NET links:

How many DOT codes are inside this group called "telemarketers?"  Just one, telephone solicitor.  

The Commissioner takes administrative notice of the OOH.  Administrative notice proves facts without evidence.  Suggested approaches:
Q:  The occupation of telephone solicitor, how many of those just read a script?
Q:  How many telephone solicitors require a month or less of training?
Q:  If the Department of Labor classified telephone solicitor as unskilled in a different publication, would you defer to that classification?
Q:  How does the OOH classify telemarketers, skilled, semi-skilled, or unskilled?
Q:  If a worker couldn't function without assistance within the first month, would that person get terminated?
Administrative notice of the DOT permits rebuttal.  Due process requires the ability to rebut presumptions made in administrative notice.  Technology has changed since the DLU of 1988 and the OOH captures that shift.  We have heard vocational experts in other cases claim that at least part of the occupational base is unskilled.  Beat that drum in the face of transferable skills testimony -- the occupation is no longer semi-skilled.  

Wednesday, May 30, 2018

The Continuing Presumption of Non-Disability in the Post-Conn Era



AR 94-2(4): Lively v. Secretary of Health and Human Services, 820 F.2d 1391 (4th Cir. 1987) (Rescinded 1/12/2000)

AR 00-1(4): Albright v. Commissioner of the Social Security Administration, 174 F.3d 473 (4th Cir. 1999) (Interpreting Lively v. Secretary of Health and Human Services)

AR 98-3(6): Dennard v. Secretary of Health and Human Services, 907 F.2d 598 (6th Cir. 1990)

AR 98-4(6): Drummond v. Commissioner of Social Security, 126 F.3d 837 (6th Cir. 1997)

AR 97-4 (9): Chavez v. Bowen, 844 F.2d 691 (9th Cir. 1988)

Those are the five cases that pain the landscape of the continuing presumption of non-disability.  They are inconsistent with agency policy and understanding of the Social Security Act and the Commissioner's regulations:
if the subsequent claim involves deciding whether the claimant is disabled during a period that was not adjudicated in the final determination or decision on the prior claim, SSA considers the issue of disability with respect to the unadjudicated period to be a new issue that prevents the application of administrative res judicata. Thus, when adjudicating a subsequent disability claim involving an unadjudicated period, SSA considers the facts and issues de novo in determining disability with respect to the unadjudicated period. SSA does not adopt findings from the final determination or decision on the prior disability claim in determining whether the claimant is disabled with respect to the unadjudicated period.
or 
In a subsequent disability claim, SSA considers the issue of disability with respect to a period of time that was not adjudicated in the final determination or decision on the prior claim to be a new issue that requires an independent evaluation from that made in the prior adjudication. Thus, when adjudicating a subsequent disability claim involving an unadjudicated period, SSA considers the facts and issues de novo in determining disability with respect to the unadjudicated period. SSA does not consider prior findings made in the final determination or decision on the prior claim as evidence in determining disability with respect to the unadjudicated period involved in the subsequent claim.
In three of the 11 circuits, the agency does not follow this national policy but instead forces claimants to come forward with evidence that something has changed since the last decision by an ALJ.  The continuing presumption of non-disability applies not just to the period adjudicated but flows forward in time to effectively bar claims in the future -- until something changes.  A change in the regulation that plainly states what the Commissioner has already stated in the rulings would wipe the continuing presumption off the face of the legal landscape under the doctrine of Brand X deference

For the agency, the continuing presumption makes quick work of cases that have already suffered an ALJ unfavorable decision.  The claimant loses without a material change in medical condition, past work falling off the relevant time-frame, crossing into an age category that requires application of a favorable grid rule, or some other factor.  That administrative application to boost the productivity of the ALJ corps of a judicially-made rule, that the Commissioner says is wrong, should strike the casual observer as both odd and wrong. 

But it comes at a price.  A title II claimant with a piece of insured status left or an SSI claimant that just wants to start over -- they cannot.  Those people must take the prior claim to federal court to prevent finality from attaching while filing a subsequent claim.  Those claimants must tread water in court just to keep hope alive on that subsequent claim whether the court filing has a 1% or a 100% chance of obtaining a favorable disposition. 

Which brings us back to the title of this blog.  In the post-Conn era, allowance rates dropped nationwide by the ALJs and the Appeals Council has loosened its sieve on the review of those unfavorable decisions.  That equates to about 50,000 cases a year.  For claimants in the fourth, sixth, and ninth circuits, they would have gotten benefits BCE (before Conn era).  Some of those suffer attrition of giving up, some of the claimants expire, and some just retire.  But a large chunk of those cases in the three affected circuits end up in court burdening an already burdened court system, the agency legal staff at the Office of General Counsel, the claimants' bar, and most importantly the claimants themselves. 

It is time for the courts or the agency to bring the national program into singular national focus.  Administrative res judicata is supposed to be loosely applied.  But here it applies in ways that would not hold in civil or criminal proceedings.  It applies to effectively bar claims for periods of time not considered.  Kill  the beast that is the continuing presumption of non-disability.  The few cases where the shield has turned into the claimant's sword are not worth the carnage of further stressing the administrative and judicial review processes. 

Tuesday, May 29, 2018

Why Every Representative Must Own the Resource Used by Vocational Experts

Vocational experts typically state that they use the Bureau of Labor Statistics, Job Browser Pro, and the Occupational Employment Quarterly.  The BLS data is available on the internet.  Job Browser Pro is available from SkillTran.  The Occupational Employment Quarterly is available from US Publishing

Every representative should own or have access to these data sources.  Vocational experts rely on them.  Any effective cross-examination on job numbers must start with a comparison of what the data sources say and testimony of the vocational expert.  Take the recent district court decision in Beamesderfer v. Berryhill.  From the court decision:
The ALJ then proposed several hypotheticals to the VE. (AR 51-55). As relevant to this matter, the VE testified that a person with Plaintiff's RFC could perform the following jobs: 
Sweeper/cleaner, DOT code 389.683-10 (sic), a medium, unskilled (SVP 2) occupation, with 96,500 positions in the national economy.
Floor waxer, DOT code 381.687-034, a medium, unskilled (SVP 2) occupation, with 97,000 positions in the national economy.
Laundry worker I, DOT 361.684-014, a medium, unskilled (SVP 2) occupation, with 38,500 positions in the national economy.
Mary Jesko testified that she "relies on a computer program known as SkillTRAN." 
First, don't you mean Job Browser Pro?  
The company that published the program is SkillTran.  The companies other products do not estimate job numbers for a DOT code except in the incidence of a single DOT code comprising the entire know content of the SOC group.   
  • Job Browser Pro reports 16,881 jobs as a sweeper-cleaner industrial.  Why is JBP off by a factor of six?
  • Job Browser Pro reports 22,784 jobs as a floor waxer.  Why is JBP off by a factor of four?
  • Job Browser Pro reports 5,346 jobs as a laundry worker I?  Why is JBP off by a factor of seven? 
The witness should explain why she departs from that on which she relies.  We are still in harmless error territory so we have to keep going.  But the jab sets up the power punch. 

  • Do you agree with JBP as to the SOC code assignments?
  • Do you agree with JBP as to the industries?
  • Do you agree with JBP as to the presence of other DOT codes within that SOC code and the specified industries?

Floor waxer and sweeper cleaner are in the same SOC.  So keep going:  

  • Janitors and cleaners, except maids and housekeeping cleaners has 15 DOT codes and five of them are semi-skilled.  Do they have the same incidence in the industries in which more than one DOT code works?
  • Laundry and dry-cleaning workers has 23 DOT codes and 15 are skilled or semi-skilled.  Do they have the same incidence in the industries in which more than one DOT code works?

Jesko and others like her think that you are too cheap to invest in the program and look over their shoulders.  If you don't have the program, you can't learn it on the fly and many ALJs will not let you look at their screens (except in the Seventh Circuit). 

As the representatives, we just have access to everything that the vocational experts cite and rely upon.  So go get your copy of Job Browser Pro and buy an annual copy of the OEQ.  OccuCollect collected relevant data from the Dictionary of Occupational Titles; Selected Characteristics of Occupations; O*NET OnLine; Occupational Requirements Survey; and Occupational Outlook Handbook.

Monday, May 28, 2018

Cross-Examination on Typical Education and Training Requirements of Occupations -- DOT -- O*NET -- OOH -- ORS

Take the run-of-the-mill occupation identified by a vocational expert at a Social Security hearing.  Running a DOT crosswalk through the O*NET OnLine and then comparing that SOC code on the Occupational Outlook Handbook will result in a moderate-training time result. 

Models typically require no formal education and no on-the-job training.  Twenty-five occupations listed by the OOH typically require no formal education and short-term on-the-job training -- up to 30 days.    Twenty-five occupations typically require a high school education or equivalent and short-term on-the-job training -- up to 30 days. 

Compare that typical entry level requirement listed in the OOH to the description of work in the DOT.  Social Security Ruling 00-4p states that the DOT describes the "maximum requirements of occupations as generally performed."  The maximum as generally performed is an oxymoron.  We discussed this before.  The DOT that that:
definitions in the DOT are written to reflect the most typical characteristics of a job as it occurs in the American economy. Task element statements in the definitions may not always coincide with the way work is performed in particular establishments or localities.
 DOT Appendix D.  "Typical characteristics" found in the DOT and "the starting level for workers who are new to an occupation" found in the OOH are congruent.  Add in that on-the-job training carries the definition of "training or preparation that is typically needed for a worker," and we get symmetry if not absolute parity.  The Department of Labor is consistent in its approach. 

For occupations having a data statement, the OOH provides both a job zone statement that includes Specific Vocational Preparation code and a statement of education held by incumbent job holders.  Helpers - Production Workers (SOC 51-9198) is typical.  The O*NET states that the occupations in the group have an SVP range of 4.0 to < 6.0 and an educational range of 49% high school diploma or equivalent; 32% less than high school diploma; and 18% post-secondary certificate. 

Relying on different data collection sources and methods, the OOH states that Helpers - Production Workers (51-9198) has a typical education and training of high school diploma or equivalent; no work experience required; and moderate-term on-the-job training. 

Enter the Occupational Requirements Survey into the mix.  The ORS states that 65.3% of helpers - production workers have a short demonstration up to one month

The ORS reports that for  12.7% of helpers - production workers have a training period of over one month and up to three months

Median post-employment training time is 25.34 days

The ORS reports that 51.9% of helpers - production workers have no minimum education requirement and 48.1% have a minimum education requirement of a high school diploma.   

To get more confused, the employment projections report that incumbents in the helpers - production workers occupational group have less than a high school diploma in 36.3% of job holders; a high school diploma or equivalent in 38.7% of job holders; and a greater level of education in the balance. 

Education and training provide a useful adjunct tool to cross-examine vocational experts.  Labor has 553 separate DOT codes in the group representing an aggregate of 426,000 jobs.  They do warrant an explanation from the vocational expert because an absence of education or experience in a field is always erosive and the Commissioner takes administrative notice of the OOH.  But at the hearing, the objective must be to whittle the occupational group down one job requirement or attribute at a time with education and training in the mix. 


Production Workers, All Other, and Temporary Jobs

The "go-to" employment category is production workers all other.  The is SOC group 51-9199 that contains 1,526 DOT codes.  The O*NET continues to list 1,590 DOT codes.  That list includes one duplicate which is why US Publishing cites 1,589 codes.  Labor moved 62 DOT codes to food production workers, all other, SOC 51-3099. Labor moved to other codes to other groups which leaves the group with 1,526 DOT codes.  For more details, see Understanding Production Workers All Other -- SOC 51-9199.

The employment projections list 263,500 jobs in production workers, all other.  The O*NET rounds that up to 264,000.  When we go to the employment projections and scroll down to the Administrative and Support and Waste Management and Remediation Services (NAICS sector 560000), we find that the employment projections lists 96,400 jobs.  The Temporary Help Services industry (NAICS 561320) employs 90,400 jobs.  The Census Bureau describes the industry:
561320 Temporary Help Services
This industry comprises establishments primarily engaged in supplying workers to clients' businesses for limited periods of time to supplement the working force of the client. The individuals provided are employees of the temporary help services establishment. However, these establishments do not provide direct supervision of their employees at the clients' work sites.Illustrative
  • Examples:
  • Help supply services
  • Model supply services
  • Labor (except farm) contractors (i.e., personnel suppliers)
  • Temporary employment or temporary staffing services
  • Manpower pools
Any estimate of the occupations within production workers, all other, group must remove 90,400 jobs if there are any restrictions on exertion or non-exertional activities. That wipes out over a third of the number of jobs in the occupational group.  The employment projections list 113,500 jobs in the manufacturing sector.  No manufacturing occupation that falls into production workers all other can ever represent more than a fraction of that number.

Sunday, May 27, 2018

The Interesting Puzzle of Barker -- Does it Exist and in How Many Jobs

I received a challenge to disassemble the occupation of barker.  The DOT describes it:
342.657-010 BARKER (amuse. & rec.) alternate titles: carney; spieler
Attempts to attract patrons to entertainment by exhorting passing public, describing attractions of show and emphasizing variety, novelty, beauty, or some other feature believed to incite listeners to attend entertainment. May conduct brief free show, introducing performers and describing acts to be given at feature performance.
GOE: 01.07.02 STRENGTH: L GED: R3 M2 L3 SVP: 2 DLU: 77
The O*NET says that barker belongs to amusement and recreation attendants.  The O*NET reports an occupational base of 300,000 jobs.  The OOH uses the same data set and reports the same number of jobs, 300,000.  The 2017 release of the OOH (2016-18) links to the BLS reports in the Occupational Employment Statistics (OES).  The OES reports 310,970 jobs as amusement and recreation attendants as of May 2017.

The OES gives industry profile data.  About half the jobs exist in the Other Amusement and Recreation Industries (NAICS 713900) and another large chunk in Amusement Parts and Arcades (NAICS 713100).  Those two industries employ 204,490 amusement and recreation attendants.

To figure out how many barkers exist, we need to know how many occupations exist in that group of amusement and recreation attendants.  The answer is 25 per the DOT crosswalk in the O*NET.

195.367-030 Recreation Aide
340.367-010 Desk Clerk, Bowling Floor
340.477-010 Racker
341.367-010 Recreation-Facility Attendant
341.464-010 Skate-Shop Attendant
341.665-010 Ski-Tow Operator
341.677-010 Caddie
341.683-010 Golf-Range Attendant
342.357-010 Weight Guesser
342.657-010 Barker
342.657-014 Game Attendant
342.663-010 Ride Operator
342.665-010 Fun-House Operator
342.667-010 Wharf Attendant
342.667-014 Attendant, Arcade
342.677-010 Ride Attendant
343.467-014 Floor Attendant
343.577-010 Cardroom Attendant II
349.477-010 Jinrikisha Driver
349.664-010 Amusement Park Worker
349.674-010 Animal-Ride Attendant
349.677-010 Cabana Attendant
349.677-014 Coach Driver
352.667-010 Host/Hostess
372.667-026 Flagger

Those occupations work in 14 different sectors according to the employment projections (a two digit NAICS code). Job Browser Pro lists 13 of these as occurring in the amusement and recreation industries. Those are the foundations for cross-examination.The DOT lists 217 codes that work in the amusement and recreation industries, not including those common to several industries.
Q: What is the SOC code for the barker occupation? 
Q: In what industry -- by NAICS code -- does the occupation of barker occur?
Q: How many DOT codes in "Amusement and Recreation Attendants, SOC 39-3091" exist? 
Q: How many other DOT codes in "Amusement and Recreation Attendants, SOC 39-3091" work in Amusement, gambling, and recreation industries?
Q: How many of the DOT codes in that intersection of occupation and industry require light exertion and can be learned in 30 days or less?
 To play the numbers game, we have to use Job Browser Pro. When we develop an ability to use JBP seamlessly, then we can jump into the employment projections and County Business Patterns. It all starts with affirming the DOT, SOC, and NAICS codes. Without those three pieces of data -- and how many other DOT codes exist in that intersection -- we cannot defeat the Bayliss/Purdy assumption of expertise and capacity of the vocational expert.

Monday, May 21, 2018

Occu Collect Users Guide


Users’ Guide
Occu Collect uses the data from the Dictionary of Occupational Titles (unskilled occupations), the printed and the electronic files of the Selected Characteristics of Occupations (unskilled occupations), the Occupational Outlook Handbook, the Occupational Information Network, and the Occupational Requirements Survey.  These are all publications of the Department of Labor through either the Bureau of Labor Statistics, the Employment and Training Administration, and/or the through a grant to the North Carolina Department of Commerce.  See our Documentation page for a list of sources and methods used for compiling the data from the five sources. 

Dictionary of Occupational Titles, 4th ed. Revised (Dept. of Labor 1991)
The DOT (unskilled occupations) reports contain a reference to a SOC code. The reference to the SOC code allows users to access the correct data in the OOH, the O*NET, and the ORS.  Each DOT report contains a hyperlink to the DOT-O*NET Crosswalk to allow users to verify the statement and to print the page as necessary. 
Occu Collect breaks down the four categories DOT/SCO reports (cognitive and mental; education, training, and experience; environmental conditions; and physical demands) into those categories.  Occu Collect does that to assist the user in focusing on the critical inquiry rather than inundating the user with all available data. 
All DOT reports contain the occupation title, DOT code, SOC code, link to the O*NET OnLine, link to the DOT-O*NET Crosswalk, and DOT narrative with the trailer information.  The three reports available for the DOT breakdown the available data:
          1.                Cognitive demands report contains the Data-People-Things codes from the DOT number and a definition of the DTP code. 
          2.                Education, training, and experience report contains the Specific Vocational Preparation code with definition; the Reasoning, Mathematical, and Language development levels with definitions. 
          3.                Physical demands report contains the strength designation with the DOT definition.

Selected Characteristics of Occupations Defined in the Revised Dictionary of Occupational Titles (Dept. of Labor 1993)
All SCO (unskilled occupations) reports contain the occupational title, DOT code, SOC code, and link to the O*NET OnLine.  The three reports available for SOC break down the available data:
          1.                Cognitive demands report contains the aptitudes and temperaments from the SCO electronic files. 
          2.                Environmental conditions report contains the SCO statement of environmental conditions with the SCO definitions. 
          3.                Physical demands report contains the SCO statement of physical demands with the SCO definitions.

Occupational Information Network (O*NET) (Dept. of Labor 2018)
Occu Collect has three sections for work abilities (two) and work context from the O*NET OnLine.  The O*NET OnLine has 24 different reports.  Occu Collect reports the three most important to the cross-examination of vocational experts.  This product focuses on the unskilled DOT codes (3,100) and ignores the skilled and semi-skilled DOT codes (another 10,000).  The O*NET OnLine provides the work abilities report in two flavors: importance and level.  Occu Collect provides that data.  The O*NET OnLine provides one flavor of work context and Occu Collect reports that data.  Occu Collect provides the data for all occupational groups. 
Occu Collect uses the same data fields and two versions of the reports for work abilities, importance and level.  Importance uses a five-point scale from not important to extremely important.  The O*NET provides a numerical score on a scale of 1 to 100, using the five-point scale as 20 points each.  Occu Collect reports that 1–100 score. 
The O*NET uses a eight-point scale that isn’t obvious without getting into the weeds of the data.  The O*NET provides examples of each scored item, converting the 0–7 score into a percentage.  The score for the actual level for the occupational group is reported on a 0–100 score with a bar graph.  Occu Collect reports that data with more detail than is provided in the O*NET.  
Work Abilities Reports
Occu Collect breaks down the importance and level work abilities reports (cognitive and mental; education, training, and experience; environmental conditions; and physical demands).  The importance and the level reports have the same categories but address the data in two different ways — importance and level.  The sorting of the data among the four broad areas of concern is the same.
Cognitive abilities reports:
1.          Oral Comprehension
2.          Written Comprehension
3.          Oral Expression
4.          Written Expression
5.          Fluency of Ideas
6.          Originality
7.          Problem Sensitivity
8.          Deductive Reasoning
9.          Inductive Reasoning
10.       Information Ordering
11.       Category Flexibility
12.       Mathematical Reasoning
13.       Number Facility
14.       Memorization
15.       Speed of Closure
16.       Flexibility of Closure
17.       Perceptual Speed
18.       Spatial Orientation
19.       Visualization
20.       Selective Attention
21.       Time Sharing

Physical demands reports – strength, endurance, flexibility, balance and coordination:
1.          Dynamic Flexibility
2.          Dynamic Strength
3.          Explosive Strength
4.          Extent Flexibility
5.          Gross Body Coordination
6.          Gross Body Equilibrium
7.          Stamina
8.          Static Strength
9.          Trunk Strength
10.       Arm-Hand Steadiness
11.       Control Precision
12.       Finger Dexterity
13.       Manual Dexterity
14.       Multilimb Coordination
15.       Rate Control
16.       Reaction Time
17.       Response Orientation
18.       Speed of Limb Movement
19.       Wrist-Finger Speed
Physical demands reports – visual, auditory and speech perception:
1.          Auditory Attention
2.          Depth Perception
3.          Far Vision
4.          Glare Sensitivity
5.          Hearing Sensitivity
6.          Near Vision
7.          Night Vision
8.          Peripheral Vision
9.          Sound Localization
10.       Speech Clarity
11.       Speech Recognition
12.       Visual Color Discrimination
Work Context Reports
How does Occu Collect break down the work context reports (cognitive and mental; education, training, and experience; environmental conditions; and physical demands)?
Cognitive work conditions:
          1.                Contact With Others
          2.                Coordinate or Lead Others
          3.                Deal with External Customers
          4.                Deal with Physically Aggressive People
          5.                Deal with Unpleasant or Angry People
          6.                Electronic Mail
          7.                Face-to-Face Discussions
          8.                Frequency of Conflict Situations
          9.                Letters and Memos
       10.                Public Speaking
       11.                Responsibility for the Outcomes and Results
       12.                Responsible for Others’ Health and Safety
       13.                Telephone
       14.                Work with Work Group or Team
Environmental work conditions:
          1.                Exposed to Contaminants
          2.                Exposed to Disease or Infections
          3.                Exposed to Hazardous Conditions
          4.                Exposed to Hazardous Equipment
          5.                Exposed to High Places
          6.                Exposed to Minor Burns, Cuts, Bites, or Stings
          7.                Exposed to Radiation
          8.                Exposed to Whole body Vibration
          9.                Extremely Bright or Inadequate Lighting
       10.                In an Enclosed Vehicle or Equipment
       11.                Indoors, Environmentally Controlled
       12.                Indoors, Not Environmentally Controlled
       13.                Outdoors, Exposed to Weather
       14.                Outdoors, Under Cover
       15.                Sounds, Noise Levels Are Distracting or Uncomfortable
       16.                Very Hot or Cold Temperatures
       17.                Wear Common Protective or Safety Equipment such as Safety Shoes, Glasses, Gloves, Hearing Protection, Hard Hats, or Life Jackets
       18.                Wear Specialized Protective or Safety Equipment such as Breathing Apparatus, Safety Harness, Full Protection Suits, or Radiation Protection
       19.                Physical Proximity
Physical demands report – postural:
          1.                Cramped Work Space, Awkward Positions
          2.                Spend Time Bending or Twisting the Body
          3.                Spend Time Climbing Ladders, Scaffolds, or Poles
          4.                Spend Time Keeping or Regaining Balance
          5.                Spend Time Kneeling, Crouching, Stooping, or Crawling
          6.                Spend Time Making Repetitive Motions
          7.                Spend Time Sitting
          8.                Spend Time Standing
          9.                Spend Time Using Your Hands to Handle, Control, or Feel Objects, Tools, or Controls
       10.                Spend Time Walking and Running
Physical demands report – exertional:
1.                Spend Time Sitting
2.                Spend Time Standing
3.                Spend Time Using Your Hands to Handle, Control, or Feel Objects, Tools, or Controls
4.                Spend Time Walking and Running
The O*NET does not provide detailed data for occupations with the format xx-xxx9.00.  The occupations that have the format xx-xx99.00 have an occasional subset.  E.g.  51-9199.00 for production workers, all other, has a subset of 51-9199.01 for recycling and reclamation workers.  That single subset does not consume the superset but does represent a certain number of jobs that lack a DOT code.  Some occupational groups have multiple constituent parts.  E.g. 43-5081.00 for stock clerks and order fillers contains four subsets:  43-5081.01 stock clerks, sales floor; 43-5081.02 marking clerks; 43-5081.03 stock clerks – stockroom, warehouse, or storage yard; and 43-5081.04 order fillers, wholesale and retail sales.  Occu Collect does not report the group titles (xx-xxxx.00) when the title represents a group of more specific occupations (xx-xxxx.01, .02, etc.).  When the O*NET provides specific data, Occu Collect reports it. 

Occupational Requirements Survey (Dept. of Labor 2017)
Occu Collect breaks down the ORS reports (cognitive and mental; education, training, and experience; environmental conditions; and physical demands) using the data format published by the Bureau of Labor Statistics.
                1.          Cognitive and mental demands
                2.          Education, training, and experience
                3.          Environmental conditions
                4.          Physical demands
Occu Collect reports the available data in the categories used by BLS. 
Cognitive and mental demands
1.          Adaptability
a.           Work schedules
b.          Work tasks
2.          Regular Contacts
a.           Type of interaction
b.          Frequency of interaction
3.          Other Contacts
a.           Type of interaction
b.          Frequency of interaction
4.          Decision-making
5.          Supervision
6.          Pace of work
7.          Control of work pace
Education, training, and experience
1.          Minimum formal education or literacy required
a.           Degree by type
b.          Associates degree time (days)
c.           Vocational associates degree time days)
d.          High school vocational time (days)
e.           Literacy (if no high school required)
2.          Other training & experience
f.            Pre-employment training (license, certification, other)
g.           Prior work experience
h.          Post-employment training
3.          Requirements calculated for SSA
i.            Specific vocational preparation (SVP)
Environmental conditions
1.          Extreme cold (non-weather related)
2.          Extreme heat (non-weather related)
3.          Wetness (non-weather related)
4.          Humidity
5.          Heavy vibration
6.          High, exposed places
7.          Proximity to moving mechanical parts
8.          Outdoors
9.          Hazardous contaminants
10.       Noise Intensity Level
Physical demands
1.          Sitting or standing/walking
a.           Standing and walking
b.          Sitting
c.           Sitting vs. standing at will
2.          Hearing
a.           One on one
b.          Group
c.           Telephone
d.          Other sounds
e.           Pass a hearing test
3.          Vision
a.           Near visual acuity
b.          Far visual acuity
c.           Peripheral vision
4.          Communication
a.           Verbal
5.          Climbing
a.           Ramps/stairs: structural only
b.          Ramps/stairs: work-related
c.           Ladders/ropes/scaffolds
6.          Lifting/carrying
a.           Weight (range) lifted/carried – seldom
b.          Weight (range) lifted/carried – occasionally
c.           Weight (range) lifted/carried – frequently
d.          Weight (range) lifted/carried – constantly
e.           Most weight ever lifted/carried (pounds)
7.          Manipulation
a.           Foot/leg controls
                                            i.                One or both
b.          Gross manipulation
                                           ii.                One or both
c.           Fine manipulation
                                         iii.                One or both
8.          Postural
a.           Crawling
b.          Crouching
c.           Stooping
d.          Kneeling
9.          Pushing/pulling
a.           With hand/arm
                                            i.                One or both
b.          With foot/leg
                                            i.                One or both
c.           With feet only
                                            i.                One or both
10.       Reaching
a.           Overhead
                                            i.                One or both
b.          At or below shoulder
                                           ii.                One or both
11.       Tasks
a.           Keyboarding: traditional
b.          Keyboarding: touch screen
c.           Keyboarding: 10-key
d.          Keyboarding: other
e.           Keyboarding: any keyboarding
f.            Driving, type of vehicle
12.       Strength

Occu Collect reports only the data the BLS provides.  The ORS does not report all occupations currently nor all data fields for all occupations that it does report. 

Kosher Inspector - 529.687-126; Coal Sampler - 922.687-038 - Occasional Handling, No Fingering

We used the  SCO and the aptitudes for dexterity  to show that there really are not a significant number of jobs for a person limited to lig...