Advertising Distributor and Job Browser Pro -- Why is it Wrong?

 A vocational expert (VE) identifies advertising-material distributor (DOT 230.687-010) as a light, unskilled, simple 1-2 step occupation.  The VE says that the occupation represents about 30,000 jobs in the nation.  I think:  "That can't be right."  So I ask:  "How do you know that?"

The VE points to Job Browser Pro (JBP) as the basis for the testimony.  We are in the middle of the CV-19 crisis; the hearing is by telephone; I pull up JBP on the fly.  Damn, the VE is close, JBP says that advertising-material distributor represents 29,792 jobs in the nation.  Almost all of the jobs are in the employment services (NAICS 561300) industry.  Employment services is the industry group that contains temporary agencies.  "Don't temp agencies send people in all occupations?"  After some struggle back and forth, the VE affirms that that suspicion is true but that JBP is still a valid source for job numbers.  I now need to disassemble the occupation and its job numbers.  

JBP lists  advertising-material distributor and billposter (DOT 299.667-010) (medium unskilled) as helpers - production workers (SOC 51-9198) as existing in employment services.  Four digit industry designations represent industry groups that contain five and six-digit industries.  NAICS 561300 contains specific industries.  I need to find them and determine whether JBP has designated a specific industry and attributed all of those jobs to other DOT codes.  

JBP has a CBP hyperlink in the box describing the industries in which the DOT code exists.  CBP is the designation for County Business Patterns, #2 on the list of enumerated examples of administrative notice.  The CBP link takes me to the SkillTRAN Industry Analyzer.  I click on the Staffing Patterns button.   Clicking on the green "+" button for 51-9198, I find the DOT codes that SkillTran assigns to NAICS 561300.  Low and behold, there are not two but ten DOT codes:

SOC 51-9198 – Helpers – Production Worker
CODE	TITLE	INDUSTRY`	SVP	STR
230.667-014	TELEPHONE-DIRECTORY DELIVERER	business services	1	H
230.687-010	ADVERTISING-MATERIAL DISTRIBUTOR	any industry	2	L
299.667-010	BILLPOSTER	any industry	2	M
369.387-010	LAUNDRY WORKER III	any industry	3	L
529.687-094	GENERAL HELPER	oils & grease	2	M
609.684-014	LABORER, GENERAL	machine shop	2	H
619.687-014	MACHINE HELPER	any industry	3	H
741.687-014	PAINTER HELPER, SPRAY	any industry	3	M
922.687-058	LABORER, STORES	any industry	2	M
929.687-022	LABORER, SALVAGE	any industry	2	M

I change the 561310 to 561320.  This is the Temporary Help Services industry.  This has the green "+" button for 51-9198.  I click on it.  There is that same ten DOT code list that I saw for 561300.  Curiosity killed the cat so I meow and look at the specific five-digit industries.  I change the 561300 in the URL to 561310.  This is the industry designation for Employment Placement Agencies.  Sorting by SOC code, I see that SkillTRAN lists our two culprits, advertising-material distributor and billposter, but not the other eight.  

I change 561320 to 561330.  This is the Professional Employer Organizations industry.  This industry as a DOT list so I sort by SOC code.  The occupations from 51-9198 are advertising-material distributor and billposter.  

Back to JBP, I search randomly for store laborer (DOT 922.687-058).  JBP states that this occupation exists in industry 561320, that the industry employs 53,532 helpers - production worker, and that store laborer accounts for 6,691 of the jobs (which is almost all of the jobs attributed to store laborer by JBP).  JBP lists eight DOT codes:  the list of ten occupations less advertising-material distributor and billposter.  

I need to complete the circle.  Resorting to the OES May 2019 National Industry-Specific Occupational Employment and Wage Estimates for NAICS 561300.  The OES confirms that "Industries within NAICS 561300 - Employment Services" includes 561320 - Temporary Help Services.

The OES reports that Helpers - Production Workers represents 78,690 jobs as of May 2019.  

The OES reports that Helpers - Production Workers represents 68,130 jobs as of May 2019.  

The difference is 10,560 jobs.  The OES does not report job numbers for NAICS 561310 or 561320.  CBP does but I have already completed the circle.  

JBP double counted the 53,532 jobs that it places in NAICS 561320 in accounting for them all again in NAICS 561300.  Including the part-time work, JBP estimates that NAICS 561320 has 84,971 jobs and NAICS 561300 has 94,492 jobs.  JBP is starting 16,000 jobs too high.  

The question is, how many  advertising-material distributor jobs are there?  JBP uses equal distribution as its methodology.  JBP does not list the extra eight occupations in NAICS 561310 or 561330 but lists all ten occupations in NAICS 561320.  Using JBP's intersectional equal distribution, half of the 10,560 jobs and one-tenth of the 68,130 jobs to arrive at 12,063 jobs, full and part-time for  advertising-material distributor.  

JBP says that 37% of the jobs are part-time.  The O*NET says that 6% of helpers - production workers have part-time employment.  The industry-specific full versus part-time is more applicable.  Advertising material distributor represents 7,600 full-time jobs that matter at step five of the sequential evaluation process.   

This is the danger of failing to fastidiously stick to either three, four, and five digit NAICS codes by JBP.  The data limitation exists because JBP relies on the OES and the OES only reports statistically significant occupation clusters.  When JBP reports job numbers, the careful user must travel up and down the NAICS code tree to determine whether the industry designation is accurate and that the jobs were not over or undercounted.  The mantra must remain, trust but verify.  When it comes to vocational experts, they do not get paid enough to take that journey.  We have a fiduciary obligation to take the trip.  Bon voyage.    

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Suggested Citation:

Lawrence Rohlfing, Advertising Distributor and Job Browser Pro -- Why is it Wrong?, California Social Security Attorney (October 1, 2020), https://californiasocialsecurityattorney.blogspot.com/2020/10/advertising-distributor-and-job-browser.html