I have pointed out the double and triple counting of jobs in certain occupations in the DOT. Last week, SkillTRAN released version 1.7.4. Jeff Truthan gave me an advance copy at the NOSSCR conference and I took it for a spin. Unfortunately, my laptop did not have the right video output to share on the Reverse Engineering session on Friday afternoon.
In our unending quest for reliable job numbers, version 1.7.4 has eliminated the inconsistent use of three and four-digit NAICS codes in estimating job numbers. It remains critical to ask the vocational witness,
"What version of JBP are you using?"
The VW that subscribe to the online version always get the most recent version. The VW that use the desktop version and use an outdated version that double counts, allows the insertion or deletion of industries, and other nefarious problems. Ask, "What version of JBP are you using?"
As valuable as JBP is in identifying job numbers, the VW use of JBP does not end the inquiry, it is only the beginning. JBP continues to use equal distribution of job numbers between DOT codes at the occupation-industry (SOC-NAICS) intersection. With circa 13,000 DOT codes, estimating job numbers by the skill and exertion levels within the occupational group would constitute a Herculean undertaking.
That leaves the cross-examination of the VW up to the intrepid representative. Let's take a look at small products assembler I (DOT 706.684-022) as an example. JBP continues to list industry groups within the food manufacturing subsector. SkillTRAN does not explain its NAICS assignments. The VW must explain why people that "mass produce small products" perform those function in animal food manufacturing. Without a reasonable articulated basis, that industry assignment has an unresolved apparent conflict -- if and only if the JBP report is submitted into the record before the date of the ALJ decision.
JBP ver. 1.7.4 estimates that small products assembler I represents 18,445 jobs. Most of those jobs come in the temporary help services (NAICS 561320) industry. The WT hyperlink lists five DOT codes, four light and unskilled, one heavy and semi-skilled. But that is not the way that production workers pan out. The ORS available on the CBP hyperlink and of course in OccuCollect.com tells us that production workers engage in medium work between 64% and 85% of the jobs. None of the called out temp jobs require medium exertion. Nor does the assignment of 80% of the jobs in the temporary help services industry to light unskilled work conform to the reality that most of the jobs in the occupation are semi-skilled. A better set of assumptions are that most of the jobs in the occupation-industry intersection require medium exertion and at least half are skilled.
JBP reports the 2018 and 2021 data sets for the ORS. OccuCollect.com gives the 2017, 2018, 2019, 2020, and the 2021 data sets. The 2018 data set represents the final wave of the first set. The 2020 data set is the first of the second wave. The 2021 data set is the preliminary second wave data. The 2018 data set reports that 53% of production workers are unskilled. The 2020 data set describes production workers as engaged in unskilled work in 28.7% of jobs. The 2021 data set does not set forth SVP data for production workers. Whatever the percentages are, they are not 80% light and unskilled. For small products assembler I, the estimate of 11,000 jobs in temporary help services is not reliable. A substantial question also arises whether temporary help services constitutes sustained employment for purposes of substantial gainful activity under SSR 96-8p.
Just because it is written down somewhere does not mean that our job is over. Examine the data, the methodology, and ask questions like your client's life and quality of life depend on it. It does.
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Suggested Citation:
Lawrence Rohlfing, Job Browser Pro - Ver. 1.7.4 -- Example Small Products Assembler I, California Social Security Attorney (May 18, 2022) https://californiasocialsecurityattorney.blogspot.com
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