Saturday, January 11, 2020

The Industries Assigned to Small Products Assembler I -- DOT Conflict

We addressed the use of DOT industry designations and narrative job descriptions to create unexplained conflict between the DOT and Job Browser Pro using lens inserter as our example.  We can now examine a bigger and more damaging problem in the occupation of small products assembler I (DOT 706.684-022).  We start with the DOT entry for the occupation:
706.684-022 ASSEMBLER, SMALL PRODUCTS I (any industry) alternate titles: bench assembler 
Performs any combination of following repetitive tasks on assembly line to mass produce small products, such as ball bearings, automobile door locking units, speedometers, condensers, distributors, ignition coils, drafting table subassemblies, or carburetors: Positions parts in specified relationship to each other, using hands, tweezers, or tongs. Bolts, screws, clips, cements, or otherwise fastens parts together by hand or using handtools or portable powered tools. Frequently works at bench as member of assembly group assembling one or two specific parts and passing unit to another worker. Loads and unloads previously setup machines, such as arbor presses, drill presses, taps, spot-welding machines, riveting machines, milling machines, or broaches, to perform fastening, force fitting, or light metal-cutting operation on assembly line. May be assigned to different work stations as production needs require or shift from one station to another to reduce fatigue factor. May be known according to product assembled.
GOE: 06.04.23 STRENGTH: L GED: R2 M1 L1 SVP: 2 DLU: 79
 The first thing to notice is the designation of any industry.  Here is what the DOT says about that any industry designation:
Occupations which characteristically occur in nearly all industries, or which occur in a number of industries, but not in most industries and which are not considered to have any particular industrial attachment, are assigned the designation of "any industry."
The mass production of small products such as ball bearings, automobile door locking units, speedometers, condensers, distributors, ignition coils, drafting table subassemblies, or carburetors do not occur in nearly all industries but do occur n a number of industries, not most industries.  When the vocational expert identifies small products assembler, it is incumbent to establish those self-evident facts.

So what does JBP describe as the industries?  We take them groups as a time.
311100 Animal food manufacturing
311200 Grain and oilseed milling
311300 Sugar and confectionery product manufacturing
311400 Fruit and vegetable preserving and specialty food manufa
311500 Dairy product manufacturing
311600 Animal slaughtering and processing
311700 Seafood product preparation and packaging
311800 Bakeries and tortilla manufacturing
312100 Beverage manufacturing
314000 Textile product mills
316000 Leather and allied product manufacturing
321100 Sawmills and wood preservation
321200 Veneer plywood and engineered wood product manufact
321900 Other wood product manufacturing
322000 Paper manufacturing
323000 Printing and related support activities
324000 Petroleum and coal products manufacturing
3250A1 Chemical manufacturing
3250A2 Chemical manufacturing
325400 Pharmaceutical and medicine manufacturing
These industries would not appear to manufacture small products on an assembly line.
326100 Plastics product manufacturing
326200 Rubber product manufacturing
These categories are possible and do not create an easily established apparent conflict.
331200 Steel product manufacturing from purchased steel
331300 Alumina and aluminum production and processing
331400 Nonferrous metal (except aluminum) production and proc
331500 Foundries
3320A1 Fabricated metal product manufacturing
3320A2 Fabricated metal product manufacturing
332710 Machine shops
332800 Coating engraving heat treating and allied activities
More questionable industries.  
3330A1 Machinery manufacturing
333300 Commercial and service industry machinery manufacturin
333500 Metalworking machinery manufacturing
333600 Engine turbine and power transmission equipment manuf
334100 Computer and peripheral equipment manufacturing
334200 Communications equipment manufacturing
334300 Audio and video equipment manufacturing
334400 Semiconductor and other electronic component manufact
334500 Navigational measuring electromedical and control instr
334600 Manufacturing and reproducing magnetic and optical medi
335100 Electric lighting equipment manufacturing
335200 Household appliance manufacturing
335300 Electrical equipment manufacturing
335900 Other electrical equipment and component manufacturing
336100 Motor vehicle manufacturing
336200 Motor vehicle body and trailer manufacturing
336300 Motor vehicle parts manufacturing
336400 Aerospace product and parts manufacturing
336900 Other transportation equipment manufacturing
337000 Furniture and related product manufacturing
339000 Miscellaneous manufacturing
339100 Medical equipment and supplies manufacturing
Some of these facially fit the DOT occupation description.  Others require an explanation. 
4230A1 Merchant wholesalers durable goods
423100 Motor vehicle and motor vehicle parts and supplies merch
423400 Professional and commercial equipment and supplies mer
423800 Machinery equipment and supplies merchant wholesaler
4240A1 Merchant wholesalers nondurable goods
4240A2 Merchant wholesalers nondurable goods
4240A3 Merchant wholesalers nondurable goods
424300 Apparel piece goods and notions merchant wholesalers
424500 Farm product raw material merchant wholesalers
425000 Wholesale electronic markets and agents and brokers
441000 Motor vehicle and parts dealers
444000 Building material and garden equipment and supplies deal
445000 Food and beverage stores
448000 Clothing and clothing accessories stores
451000 Sporting goods hobby musical instrument and book stor
453000 Miscellaneous store retailers
454000 Nonstore retailers
493000 Warehousing and storage
561320 Temporary help services
Wholesalers and retailers do not manufacture.  They employ production workers, all other, but not this DOT code, not without a reasonable explanation.
624300 Vocational rehabilitation services
Sheltered work does not count. 
811200 Electronic and precision equipment repair and maintenanc
Workers repairing and maintaining do not manufacture. 
TE1100 TESelf-employed workers
 This last category of self-employed production workers probably does not fit the unskilled mantra.

The industries listed by JBP for small products assembler are questionable for many of those listed.  This is fertile grounds for cross-examining the VE.



Lawrence Rohlfing, The Industries Assigned to Small Products Assembler I -- DOT Conflict," California Social Security Attorney (January 11, 2020),

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