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. 


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