Common DOT Codes -- Sedentary Unskilled -- Polisher, Eyeglass Frames

Sedentary work that does not exceed six hours of sitting in an eight-hour day represents a small window.  The DOT and the regulations define sedentary work as involving standing or walking not more than occasionally, 2.3 hours.  Sedentary work as depicted by a residual functional capacity question with a lower limit of 5.7 hours an upper limit of 6.0 hours constitutes a slender reed.  

 Understanding sedentary work rests on the difference between and and or.  Light work exists (1) when it requires walking or standing to a significant degree; OR (2) when it requires sitting most of the time but entails pushing and/or pulling of arm or leg controls; AND/OR (3) when the job requires working at a production rate pace entailing the constant pushing and/or pulling of materials even though the weight of those materials is negligible.  

Sedentary work exists when the work (1) when it does not require walking or standing to a significant degree; AND (2) when it requires sitting most of the time and does not involve pushing and/or pulling of arm or leg controls; AND (3) when the job requires working at a production rate pace but does not entail the constant pushing and/or pulling of materials even though the weight of those materials is negligible.  Transgressing the standing/walking, lifting/carrying, pushing/pulling with the arms or legs, or production rate pace strips away any hope for that sedentary label.  

The cadre of vocational experts rely on 16 different DOT codes in the sedentary range.  Ignoring obsolescence and industry, the question is whether the occupations are unskilled, sedentary, and do not exceed 6.0 hours of sitting in a full-time workday.  

13.  Polisher, Eyeglass Frames

Polisher, eyeglass frames belongs to the occupational group of grinding, lapping, polishing, and buffing machine tool setters, operators, and tenders (SOC 51-4033) (grinders).  Grinders represent about 68,500 jobs in 73 DOT codes.  The ORS reports that 58.1% of grinders engage in unskilled SVP 2 work.  Grinders engager in medium work in 66% of jobs and heavy work in 10.3% of jobs.  Grinders lift/carry up to 20 pounds at the 10th percentile.  Grinders sit 90% of the workday at the 10th percentile.  Grinders have the choice of sitting or standing on 2.2% of jobs.   

The O*NET reports that 3% of grinders do not engage in full-time work.  Survey of incumbents describe standing and walking for grinders:

Exertional	%	Response
Spend Time Using Your Hands to Handle, Control, or Feel Objects, Tools, or Controls — How much does this job require using your hands to handle, control, or feel objects, tools or controls?	93	Continually or almost continually
	7	More than half the time
	0	About half the time
	0	Less than half the time
	0	Never
Spend Time Walking and Running — How much does this job require walking and running?	12	Continually or almost continually
	35	More than half the time
	3	About half the time
	7	Less than half the time
	43	Never

The ORS data permits an inference that some range of work could qualify as sedentary, les than 10% of total jobs.  The O*NET does not permit the inference that sedentary work exists, none of the jobs stand less than half the time or never.  The sitting data from the O*NET conflicts with the standing but conforms to the ORS:

Exertional	%	Response
Spend Time Sitting — How much does this job require sitting?	7	Continually or almost continually
	0	More than half the time
	2	About half the time
	53	Less than half the time
	37	Never

Based on the combination of data, testimony that 7% of grinders could engage in sedentary work is reasonable.  But grinders are sitting 90% of the workday at the 90th percentile.  The 93rd to 100th percentiles must sit more.  Assuming that sedentary grinder positions exist, the limitation to sitting 6.0 hours maximum in a workday could occur in 2.2% of jobs.  

That 2.2% of jobs with a sit-stand choice could represent a work station with a stool, could represent the presence of workplace accommodation, or could represent jobs that have functions that require some standing/walking and the worker has flexibility when to perform those functions.  

The ORS does report a choice of sitting or standing is allowed in 91.1% of jobs.  The 2020 Collections Manual describes the choice:

This element captures jobs that have the ability to choose or control how and when they respond to external factors. When collecting for this element, consult the job’s documented task list to determine whether any of the critical tasks assigned would prevent the ability to sit/stand at will. 

The ORS instructs:

The ability to alternate between Sitting/Standing at Will is present when the following conditions exist:
• Workers typically have the flexibility to choose between sitting and standing throughout the day and
• There is no assigned time during the day to sit or stand and
• No external factors determine whether an employee must sit or stand.

A worker that has flexibility to choose when to engage in the activities has a "choice of sitting or standing" during the workday.  The presence of choice or at will sitting/standing in the ORS data does not mean that the person can assume any posture they choose.  The presence of choice or at will sitting/standing allow the worker to divide up the day as they choose but does not alter the amount of sitting or standing required to perform the job.  

The ORS also codes sitting where:

Workers may choose between sitting and standing for a given task. For example, office workers can choose a standing desk.

A standing desk may represent an accommodation and therefore irrelevant for Social Security purposes.  SSR 00-1c.  The ORS instructs employers to assess the performance of critical tasks without accommodation, how most workers perform the job.  The example of a standing desk would apply if workers typically have a standing desk at the workstation without asking for one.  

The ORS excludes "incidental tasks" from the assessment of work requirements.  The fourth example provided by the ORS to code choice or at will describes an office clerk that can choose when to file and typically stands while filing invoices.  The ORS instructs employers to code that occupation as "At Will is Yes" because the organization of the worker's day is "Worker's Choice."  

The percentage of grinders that engage in unskilled work and the percentage of grinders that could engage in sedentary work leads to a soft inference that 685 jobs might qualify for a 6.0 hour sitting limitation.  Because worker choice of sitting versus standing/walking is predicated on different job duties and because no reason exists to assume that those workers are engaged in sedentary as opposed to a higher level of exertion, there does not exist a statistical basis for reliably conclude that polisher, eyeglass frames exists in any significant numbers.  

Polisher, eyeglass frames works in the optical goods industry.  That fact requires that the size of the industry form part of the analysis in showing that this is not a viable option regardless of any sitting limitation.  

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Suggested Citation:

Lawrence Rohlfing, Common DOT Codes -- Sedentary Unskilled -- Polisher, Eyeglass Frames, California Social Security Attorney (January 4, 2022)  https://californiasocialsecurityattorney.blogspot.com