Storage-Facility Rental Clerk -- The SkillTRAN Estimate and Reliability

The vocational witness (VW) identifies storage-facility rental clerk as an available occupation at step five of the sequential evaluation process. Relying on SkillTRAN (Job Browser Pro or OASYS) (ST), the VW describes 62,000 full-time light unskilled jobs. That is what ST says. A representative must unpack the ST estimate. 

 

1. ST says that storage-facility rental clerk is a counter and rental clerk (SOC 41-2021) occupation.
2. ST says that storage-facility rental clerk works in 

            a. Warehousing and storage (NAICS 493000) - three DOT codes
            b. Real estate (NAICS 531000) - one DOT code
            c. Drycleaning and laundry services (NAICS 812300) - eight DOT codes

Real estate employs 60,000 counter and rental clerks. Focus there. If the representative cannot beat back real estate, the game is over. I first check the occupation-industry intersection for the EP and OEWS. OccuCollect calls this the 2023 EP X OEWS Job Numbers Crosswalk Report. That report lists 97,100 and 94,630 jobs in the EP and OEWS respectively. 

NAICS	INDUSTRY	EP 2023 #'s	OEWS 2023 #'s
531000	Real estate	97,100	94,630

 ST reports 59% of jobs as full-time. A small reduction but not much. The O*NET reports 60% as full-time jobs.

 The 2022 County Business Patterns reports:

531	Real estate	1,801,455
5311	Lessors of real estate	600,728
5312	Offices of real estate agents and brokers	416,530
5313	Activities related to real estate	784,197

 Storage-facility rental clerk works in leasing storage units. The NAICS group lessors of real estate, a third of the real estate job numbers. Drill down again:

NAICS	Industry Title	Jobs
531	Real estate	1,801,455
5311	Lessors of real estate	600,728
53111	Lessors of residential buildings and dwellings	345,421
531110	Lessors of residential buildings and dwellings	345,421
53112	Lessors of nonresidential buildings (except miniwarehouses)	172,451
531120	Lessors of nonresidential buildings (except miniwarehouses)	172,451
53113	Lessors of miniwarehouses and self-storage units	47,056
531130	Lessors of miniwarehouses and self-storage units	47,056

And there is the answer. Storage-facility rental clerk do not work in residential buildings and dwellings or nonresidential buildings; that occupation exists in the industry of lessors of miniwarehouses and self-storage units. That industry employs 47,000 people in all occupations including counter and rental clerks.

Storage-facility rental clerk cannot amount to 60,000 full-time or 100,000 part-time jobs where the occupation has the purpose of “Leases storage space to customers of rental storage facility.” DICOT 295.367-026.

The case needs better information. The representative should follow the hyperlink to the BLS native EP report, and then selects counter and rental clerks (SOC 41-2021), the BLS reports no data for the groups or industries in NAICS 531. The EP does report that 24% of counter and rental clerks work in the subsector NAICS 531 and that 5.2% of the jobs in NAICS 531 work as counter and rental clerk. The representative should use that number, 5.2%, against industry employment of 47,000 jobs. The result is less than 5,000 jobs. The full-time number of jobs is less than 3,000.

Why is ST unreliable for storage-facility rental clerk? ST uses the industry subsector for estimating jobs. ST uses the industry subsector because neither the EP nor the OEWS report jobs for the industry groups or specific industries. Users must compare the DOT code to the scope of NAICS 531 as reported by the Census Bureau (use the NAICS Manual) or County Business Patterns. This also means that other DOT codes or non-DOT alternate titles for counter and rental clerk exist within the NAICS 531 subsector. The estimate of 60,000 full-time jobs is untenable and indefensible.

Nor does the data support 60,000 jobs as a storage-facility rental clerk to the exclusion of all other light unskilled DOT codes. The O*NET reports 60% of the 390,300 counter and rental clerk jobs are full-time. The 2023 ORS reports 65% of jobs represent SVP 2 work. The ORS reports 49.5% of jobs require light exertion. The OccuCollect calculator reports:

41-2021 - Counter and Rental Clerks

Job Number Calculations
# of OEWS Jobs	% Full-Time	# Full-Time
390,300	60%	234,180
# of Jobs	% SVP 2	# SVP 2
234,180	65%	152,217
# of Jobs	% Light	# Light
152,217	49.5%	75,347

 There are 24 DOT codes associated with this SOC group, you can find more information on these DOT codes by running the 2019 O*NET-SOC To DOT Crosswalk Report 

The SOC-DOT crosswalk reports eight light unskilled DOT codes resident in counter and rental clerks.

24 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report
1 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Sedentary
19 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Light
      8 are SVP 2
4 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Medium
      2 are SVP 2

Users should consult the O*Net Alternate Titles Report for a more comprehensive list of occupations within this group.

This data suggests that relying on the generic title of counter and rental clerks (SOC 41-2021) as representing 75,300 jobs satisfies the Commissioner’s step five burden. The agency has not yet said that SOC code descriptions are enough. The agency could say that and SSR 24-3p leaves that possibility open.

If the claimant is under 55 and capable of the full range of light work, that person will lose. The representative must develop the record to establish other limitations whether physical, cognitive, environmental, or educational to further erode this SOC group.

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Suggested Citation:

Lawrence Rohlfing, Storage-Facility Rental Clerk -- The SkillTRAN Estimate and Reliability, California Social Security Attorney (January 5, 2025) https://californiasocialsecurityattorney.blogspot.com

The author has been AV-rated since 2000 and listed in Super Lawyers since 2008.