Thursday, February 4, 2021

Update on Production Workers, All Other

 Production workers, all other (SOC 51-9199) remains a common set of occupations for vocational experts.  Production workers contains 1,590 DOT codes.  Sedentary unskilled work represents 52 of the occupations.  Light unskilled work represents 405 of the occupations.  When we consider that the DOT identifies 137 sedentary unskilled occupations total and 1,586 light unskilled occupations, we know that production workers represents a huge piece of the unskilled occupations.  

We start, as we always should, with the number of jobs.  The Occupational Outlook Handbook (2019) reports 238,600 jobs.  The Employment Projections (2019) reports 92,900 jobs in the manufacturing sector.  The Occupational Employment Statistics (2019) reports 222,230 total jobs and 91,940 manufacturing jobs.  Slightly different job numbers that are not statistically significant.  

The OOH has reported that the typical production worker engages in moderate-term on-the-job training -- more than 30 days and up to one year.  The OOH describes skilled and semi-skilled work.  The 2020 Occupational Requirements Survey reports 28.7% of production workers engage in work with SVP more than a short duration (four hours) and up to and including one month -- SVP 2.  The ORS states that 68.9% of production workers engage in medium work.  

At this point we have two assumptions to make.  First, the distribution of skill level and exertional level is even, that 68.7% of workers at all skill levels engage in medium work.  Second, that skilled and semi-skilled work are more likely to represent work at lower levels of exertion.  We take the least advantageous assumption to our clients, that 28.7% of sedentary and light jobs are unskilled.  

The number of unskilled production workers is 68,478 using the higher OOH job number.  Of those jobs, 47,181 require medium exertion.  That leaves fewer than 12,000 jobs that require sedentary, light, heavy, or very heavy jobs.  

"I have seen these jobs with a sit-stand option, a stool, and the worker can assume either posture at will."  So the testimony goes.  The vocational witness's anecdotal experience does not substitute for the prowess of the Department of Labor.  There does not exist a reliable articulated methodology for extrapolating what a VW saw one time or 10 times to the national economy.  What does Labor say?

Good question.  At the 10th percentile, production workers stand 90% of the workday.  If sedentary work exists, it represents less than 10% of the workforce and less than 30% of them perform unskilled work.  The number of jobs that stand less than 2.7 hours for sedentary work or equal to or less than 6.0 hours in a light occupation combined represent less than 7,000 jobs in the occupation and less than 2,800 in production work engaged in manufacturing, including food production.  

We have all seen the mantra -- math is hard.  So too, being an expert is hard.  Statistical data requires math, period.  The next time a VW claims that there are 20,000 lens inserters, 100,000 small products assemblers, or some other number of jobs, don't get mad.  Just get even.  

CAVEAT:  Labor redrew the SOC lines in the 2018 iteration. All 1,590 production worker DOT codes are also listed in Computer Numerically Controlled Tool Operators (SOC 51-9061) and Computer Numerically Controlled Tool Programmers (SOC 51-9062).   I have not run into a vocational expert that has updated the data and knows this.  Job Browser Pro lists several production worker occupations in Team Assemblers (SOC 51-2092).  JBP does not explain the assignment and without an explanation, it is indefensible.  See Goode v. Comm'r.  


Suggested Citation:

Lawrence Rohlfing, Update on Production Workers, All Other, California Social Security Attorney (February 4, 2021)


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