Vocational Expert Claims that Simple is a Subjective Matter of Definition

At a recent hearing, the vocational expert testified that "simple" is a matter of disagreement depending on the definition of the word.  The cases don't prevent a vocational expert from identifying a reasoning level 3 occupation as simple -- just that an apparent conflict exists that requires an explanation.  

There are 87 unskilled DOT codes that carry a reasoning level of 3.  Of those 87 DOT codes, 22 of them require medium or heavy exertion.  We focus on the 65 unskilled DOT codes with a reasoning level of 3 and that require either sedentary or light exertion.  We first review the DOT definition of reasoning level 3:

Apply commonsense understanding to carry out instructions furnished in written, oral, or diagrammatic form. Deal with problems involving several concrete variables in or from standardized situations.

Reasoning level 3 requires that ability to understand, remember, and carry out instructions furnished not just orally or in writing, but also diagrammatically.  Reasoning level 3 requires the ability to handle problems that involve several different concrete variables.  The definition of reasoning level 3 does not sound "simple."  Reasoning level 4 is even more complex.

The DOT lists 68 unskilled sedentary and light DOT codes with a reasoning level of 3 or 4.  The DOT lists 46 occupations with a significant data worker function (the fourth digit of the DOT code); 40 occupations with a significant people worker function (the fifth digit in the DOT code); and 29 with a significant thing worker function (the sixth digit of the DOT code).  The DOT list 6 occupations that have significant worker functions in all three categories; 23 with significant data and people; 11 with significant data and things; and 2 with significant people and things.  The DOT explains data-people-things coding:

Much of the information in this publication is based on the premise that every job requires a worker to function, to some degree, in relation to Data, People, and Things. These relationships are identified and explained below. They appear in the form of three listings arranged in each instance from the relatively simple to the complex in such a manner that each successive relationship includes those that are simpler and excludes the more complex. (As each of the relationships to People represents a wide range of complexity, resulting in considerable overlap among occupations, their arrangement is somewhat arbitrary and can be considered a hierarchy only in the most general sense.) The identifications attached to these relationships are referred to as Worker Functions, and provide standard terminology for use in summarizing how a worker functions on the job. 

The fourth, fifth, and sixth digits of the occupational code reflect relationships to Data, People, and Things, respectively. These digits express a job's relationship to Data, People, and Things by identifying the highest appropriate function

The DOT lists 20 DOT codes with two Work Fields and three DOT codes with three work fields. The Revised Handbook for Analyzing Jobs defines the concept of work fields:

Work Fields. a component of Work Performed. are categories of technologies that reflect how work gets done and what gets done as a result of the work activities of a job: the purpose of the job. There are 96 Work Fields identified for use by the USES for classification of all jobs in the economy in terms of what gets done on the job.

The DOT lists eight DOT codes with two Materials, Products, Subject Matter, and Services ("MPSMS") codes.  The RHAJ defines the concept of MPSMS codes in the context of the overall structure of the DOT data set:

MPSMS is the final link in a chain describing (I) what the worker does (Worker Functions); (2) what gets done (Work Fields); (3) to what (MPSMS).

Of the 68 unskilled sedentary and light DOT codes with a reasoning level of 3 or 4, the DOT lists 30 that have a temperament for repetitive work.  Of that list of 30 DOT codes, 21 have a temperament for attaining precise set limits, tolerances, and standards; two have a temperament for working under specific instruction; and eight have a temperament for working with people beyond receiving instructions.  The 38 DOT codes that do no have a temperament for repetitive work, seven have a temperament for influencing people; eight have a temperament for performing a variety of tasks; 16 have a temperament for attaining precise set limits, tolerances, and standards; one has a temperament for working under specific instruction; 27 have a temperament for working with people beyond receiving instructions; and 14 have a temperament for making judgments and decisions.  Two of the occupations have a temperament for repetitive work and no other required temperament.  Temperaments means:

The category Temperaments is one of the components of job analysis because different job situations call for different personality traits on the part of the worker. Experience in placing individuals in jobs indicates that the degree to which the worker can adapt to work situations is often a determining factor for success. A person's dissatisfaction or failure to perform adequately can sometimes be attributed to an inability to adapt to a work situation rather than to an inability to learn and carry out job duties.

Adapt and adjust have the same contextual meaning.  Adjust is the legal term use to define the ability to perform other work at step 5 of the sequential evaluation process.

 Of the approximately 1,708 light and sedentary unskilled DOT codes.  We have already counted 68 with reasoning level 3 and 4.  The vast majority, 1,607 occupations, have a significant things code (the sixth digit).  The DOT lists 1,398 occupations with one work field; 1,588 occupations with one MPSMS code.  The DOT lists 1,587 occupations with the temperament for repetitive work.  Most of the 1,708 light and unskilled DOT codes meet the requirements for simple and repetitive work.  Reasoning knocks out 68 DOT codes.  Data-people-things; work fields; MPSMS codes; and temperaments warrant further consideration in an occupation-by-occupation basis alongside the narrative of the DOT code in question.  And it is not a subjective determination; it is a matter of looking at statistical data and drawing conclusions from that data with a subjective pre-determined outcome.