EM-21065 -- SSA Does Consider O*NET -- Kind of, Part 3

We pick up from the discussion of DPT and Temperaments and GED and Aptitudes.  EM-21065 says on interesting thing that is kind of helpful and also myopic:

O*NET information. The information in O*NET has been grouped in such a way that it is not readily usable in our adjudication process. The data is not as specific as the DOT and is not associated with individual DOT occupations. However, adjudicators may use O*NET coding to search for similar DOT occupations for a TSA assessment. See DI 25015.017.

The O*NET is not banned from consideration.  Nor can SSA ban reliable published governmental information.  That is the definition of the scope of administrative notice.   It is also axiomatic that "when an agency takes official or administrative notice of facts, a litigant must be given an adequate opportunity to respond."  Heckler v. Campbell.  

So let's test this proposition that the data in the O*NET is not as specific as the DOT and therefore not useful.  First, the DOT is a statement of the typical way in which an occupation is performed within local and employer variances.  DOT Appendix D.  Typical does not mean the majority of jobs.  M-W defines typical as "combining or exhibiting the essential characteristics of a group," "conforming to a type," or "constituting or having the nature of the type."  This would include the majority but also include a plurality or the median of a particular set.  The DOT is, by definition, a statistical fudge.  

So is the O*NET.  For well over 100 SOC-O*NET codes, the data describes a single DOT code.  Take telephone solicitor as an example.  It is the only DOT code in telemarketers.  The O*NET describes telemarketers as semi-skilled to skilled.  But the O*NET Resource Center describes telemarketers as overwhelmingly requiring less than 30 days of on-site training, on-the-job training, and related work experience.  The vast majority of telemarketers do not require more than a high school education.  The data suggests that telemarketers are typically unskilled.  We have heard the mantra, they just read from a script.  The O*NET tells the world that most telemarketers work less than 40 hours per week.  Most telemarketers work in groups or teams and all have more than occasional contact or interactions with others.  The data in the O*NET is more specific.  

Hand packager is another good example.  The DOT never states the amount of sitting or standing/walking required, except for sedentary work is at least 5.7 hours per day.  The O*NET  states that hand packagers never sit in 50% of jobs.  That is important information when a person has a 6.0 hour standing/walking limitation.  There are 59 DOT codes but this is good information about how packers typically work and to explore the vocational witness's understanding of how much standing/ walking packagers actually do and how the VW acquired that information.  

When it comes to the nature and requirements of work, SSA is not the expert agency.  SSA's expertise is the medical evidence and the nature of impairments.  There, the agency gets deference.  In terms of occupational information, SSA must get that information from one or two agencies:  the Department of Labor and the Census Bureau.  What does DOL say about the DOT and the O*NET?  This:

The Dictionary of Occupational Titles (DOT) was created under the sponsorship by the Employment and Training Administration (ETA), and was last updated in 1991. The DOT was replaced by the O*Net, and ETA no longer supports the DOT.

The O*Net is now the primary source of occupational information. It is sponsored by ETA through a grant to the North Carolina Department of Commerce. Thus, if you are looking for current occupational information you should use the O*Net.

The DOT was loaded onto the OALJ website because it was a standard reference in several types of cases adjudicated by the OALJ, especially immigration related matters. Time has passed, DOL’s regulations have changed, and OALJ now rarely adjudicates cases that reference the DOT.

So, why is the DOT still on the Office of Administrative Law Judges (OALJ) website? It is because the DOT is still used in Social Security disability adjudications and the OALJ copy of the DOT is often cited as an authoritative source of the DOT.

The Social Security Administration (SSA) is developing a new Occupational Information System (OIS), which will replace the DOT as the primary source of occupational information for use in the SSA disability adjudication process. SSA intends to have the OIS operational and to make necessary regulatory and policy updates by 2020.

Because the EM comes form the non-expert agency, it fails the basic deference test.  Kisor v. Wilkie.  When we want information about the requirements of work in the national economy, we should always use the most recent DOL published information.  

That takes us to the rub.  The VW has local experience.  The VW projects to the nation what the VW saw one time in a plant or office 20 years ago or assumes that the accommodation that VW worked out with an employer for one person 15 years ago is the norm.  The VW must answer the question and explain how the witness "extrapolat[es] those findings to the national economy by means of a well-accepted methodology."  The VW never has one.  The courts and the agency have swallowed the Kool-Aid that any VW appearing at the hearing is doing anything other than flying by the seat of his/her pants.  Administrative notice is the basic concept of establishing the number of jobs and the requirements of those jobs.  The O*NET serves that purpose.  A VW can help interpret that data, but even that assumes that the VW has statistical training.  They don't.  

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Suggested Citation:

Lawrence Rohlfing, EM-21065 -- SSA Does Consider O*NET -- Kind of, Part 3, California Social Security Attorney (July 1, 2022) https://californiasocialsecurityattorney.blogspot.com

Escort-Vehicle Driver -- Does Not Exist in Significant Numbers

We all have our own anecdotal experience.  "Wide Load" is the sign that we see on the back of some small car following a very large truck hauling heavy equipment or some wide load.  Those workers move that wide load during daylight hours. We have all seen it.  Certainly that trailing driver is the escort-vehicle driver described in the DOT.  But is that the only job that drivers do, every day, on a full-time basis?   We start with the DOT:

919.663-022 ESCORT-VEHICLE DRIVER (motor trans.) Drives vehicle equipped with warning lights and signs to escort trucks hauling mobile homes on public thoroughfares: Precedes escort and maintains specified distance between pilot vehicle and escort to provide warning to other motorists and to clear traffic at locations. Communicates by two-way radio with truck and other pilot vehicle drivers to coordinate changes in speed and route, emergencies, or traffic congestion. 

GOE: 05.08.03 STRENGTH: S GED: R2 M1 L2 SVP: 2 DLU: 77

Sedentary, unskilled, reasoning level 2.  Sounds simple enough.  Despite the described use of using a radio to communicate, the SCO states that this occupation requires no talking or hearing.  Just a tad inconsistent unless talking and hearing do not include giving and receiving instructions.  

Escort-vehicle driver is a light truck driver occupation (SOC 53-3033).  The OOH describes the group as having typical education requirement of a high school or equivalent education and short-term on-the-job training. Light truck drivers represent over 1 million jobs.  The Employment Projections tell us that 15.7% of incumbents have less than a high school education. 

The O*NET states that light truck drivers have contact with others half the time or more in all jobs.  Light truck drivers work with a group or team in 98% of jobs.  Light truck drivers work full-time in 51% of jobs.  Light truck drivers sit continually or almost continually in 8% of jobs.  

The O*NET Resource Center lists the requirements of light truck driver.  Light truck drivers have on-the-job training one month or less in 69% of jobs.  Light truck drivers do not require related work experience of more than one  month in almost 40% of jobs.  Light truck drivers require a high school diploma or less in 97% of jobs.  

The Occupational Requirements Survey describes light truck drivers as engaged in SVP 6 work in just under 12% of jobs.  We find no description for the other 88% of jobs.  Light truck drivers lift up to 50 pounds at the 10th percentile and up to 70 pounds at the median and above.  Light truck drivers sit 75% of the day at the 90th percentile.  

Escort-vehicle driver exists in the motor transportation industry.  Census and the OES classify Truck Transportation at NAICS 484000.  The OES states that this industry group employs 51,410 light truck drivers.  County Business Patterns describes truck transportation subsector in two groups:  general freight trucking; and specialized freight trucking.  Two-thirds of the jobs exist in general freight trucking.  The NAICS Manual points to specialized freight trucking, local as the correct industry (NAICS 484220).  Specialized freight (except used goods) trucking, local employs 222,047 workers.  The Employment Projections state that 3.4% of truck transportation workers have employment as a light truck driver.  Most workers have employment as heavy and tractor-trailer truck drivers (59% of jobs).  

We apply the math: 222,047 x 3.4% = 7,772.  That is not the number of escort-vehicle drivers but the maximum number of escort vehicle drivers.  Local specialized freight trucking hauls agricultural products, dump trucks, boats, livestock, and bulk liquids.  Long distance specialized freight trucking hauls automobiles, refrigerated products, liquids, waste, and hazardous materials.  Adding in long distance trucking will increase the number of jobs by 6,150 but requires more significant reductions for other products hauled.  

The data does not support a significant number of sedentary jobs.  The data does not support significant numbers of jobs within the industries appropriate to the DOT industry designation.  There does not exist a significant number of jobs that exist for escort-vehicle driver.  

Anecdotal experience and $4 buys coffee.  It is not reliable evidence upon which to adjudicate a claim worth $250K to $500K in benefits under the Social Security Act.  That is not how reasonable people handle serious affairs.  

I provided links to the original source material.  It would take hours to find all this data even if the searcher knew that the data existed.  For that reason, I recommend www.OccuCollect.com.  

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Suggested Citation:

Lawrence Rohlfing, Escort-Vehicle Driver -- Does Not Exist in Significant Numbers, California Social Security Attorney (February 17, 2021) https://californiasocialsecurityattorney.blogspot.com/2021/02/escort-vehicle-driver-does-not-exist-in.html

OccuCollect's Specialized Reports

The frequency of contact with others recurs in residual functional capacity assessments.  OccuCollect added a Contact With Others (CWO) Report as a custom report for subscribers.  The report is generated by entering a DOT code or entering a SOC/O*NET codes and then selecting a DOT code from the list.  The numbers generated reflect occupations with the characteristics as a percentage of the occupational group.  The job numbers reported reflect the Occupational Outlook Handbook, which is based on the Employment Projections published bi-annually by the Bureau of Labor Statistics.  What's in the report?

The DOT description contains the full narrative and the trailer information.  It also includes the data-people-things codes as defined in Appendix B of the DOT along with the rating of significant (S) or not significant (N) stated in the complete DOT data set.  In this CWO Report, our focus is typically on the fifth digit of the DOT code, people.  The fourth digit will frequently come into play.  Data addresses people in compiling (3) and comparing (6).  The sixth digit is important for contact with others in terms of driving-operating (3).

The OOH states the basic summary for the occupational group:  entry-level education, work experience needed, on-the-job training, and number of jobs.  The CWO report contains the hyperlinks to the OOH page, the Employment Projections list of education and training by occupational group, the employment projections listing industry employment for that occupation, and the entire industry-occupation matrix, by occupation.

The O*NET OnLine data in the CWO Report includes:

1. Contact with Others
2. Coordinate or Lead Others
3. Deal with External Customers
4. Face-to-Face Discussions
5. Work with a Group or Team
6. Duration of a Typical Work Week

We always need to discard part-time work.  In the absence of a full-time description, further evidence would be necessary to establish that part-time work amounts to substantial gainful activity.

The O*NET Resource Center data sets out the education, training, and experience for the occupational group.  The two data points included are:

1. On-the-Job Training 
2. Related Work Experience

The Occupational Requirements Survey reports the education, training, and experience reported by BLS.  We are typically interested in the unskilled employment numbers.  This data gives a third point of reference for establishing Specific Vocational Preparation:  the OOH, the O*NET Resource Center, and the ORS.  The standard OOH report (a free report, no subscription required, just sign in) reports the education level of incumbents.

The OccuCollect Calculator puts the percentage of the group in the five categories from the O*NET for contact and interaction with other people, the O*NET statement about full-time versus part-time work, and also the number of jobs for the SVP levels reported by the ORS.  Here is a sample of the conclusions:

• Helpers - Production Workers have occasional or no contact with other in 61,700 jobs.
• Helpers - Production Workers do not coordinate or lead other in 74,821 jobs.
• Helpers - Production Workers do not work with a group or team in 27,304 jobs.
• Helpers - Production Workers do not deal with external customers in 202,122 jobs. 
• Helpers - Production Workers rarely have face-to-face discussions in 36,382 jobs.
• Helpers - Production Workers have on-the-job training up to one month is 156,804 jobs.
• Helpers - Production Workers require related work experience up to one month in 145,138 jobs.
• Helpers - Production Workers work full-time in 211,377 jobs.  
• Helpers - Production Workers have SVP 2 classification in 242,192 jobs.  

Occasional contact with others will never prove disability by itself.  When coupled with other limitations, we can whittle down the size of the vocational base.  No teamwork or superficial contact with others as implicating one or more of the categories and a limitation to light or sedentary work will leave few jobs available in this category.

The CWO Report joins the easy to use custom reports already in the OccuCollect library;  the Unskilled Exertion Job Number Report; the Sitting, Standing, and Walking Report; the Reaching, Handling, and Fingering Report; and the Lifting & Carrying Report.  Using one or more of these reports reduces the search and calculation time for a post-hearing submission dramatically.  Users can still print to PDF the full reports from each database in the more complex cases.

_______________________________________________________

SUGGESTED CITATION:

Lawrence Rohlfing, OccuCollect's Specialized Reports, California Social Security Attorney (December 14, 2019),
http://californiasocialsecurityattorney.blogspot.com/2019/12/occucollects-specialized-reports.html

Why OccuCollect Provides a More Reliable Job Number Estimate -- A Cascading of Occupational Attributes

The nature of work has changed since the Dictionary of Occupational Titles was last published in 1991 and certainly changed since 10,000 of the 13,000 DOT codes were last updated in 1977.  Occupations have become obsolete; new occupations emerged; and other occupations morphed into something new.  When we look at an occupation and ascertain its job numbers, we typically examine gross job numbers (Occupational Outlook Handbook, Employment Projections, and Occupational Employment Statistics) and then whittle that number down using industry (Employment Projections, and Occupational Employment Statistics).  Once we get that that density model of occupational groups existing within specific industries, the trick requires an estimation of the number of jobs attributable to different occupations at that occupation-industry intersection.  The Occupational Employment Quarterly uses equal distribution at the occupational level.  Job Browser Pro uses equal distribution at the occupation-industry intersection.

OccuCollect uses a different methodology.  OccuCollect examines the gross number of jobs within the occupational group and then uses either the Occupational Requirements Survey or the O*NET Resource Center report of education, training, and experience to ascertain the number of unskilled jobs within the group.  Cascading the work requirements on the Specific Vocational Preparation separates the jobs by strength, sitting, standing, walking, or manipulation ... for example.  For the cognitive-emotional requirements of work, the O*NET Work Context reports work best for establishing the amount of contact with others, interaction with the public, dealing with conflict, and the need for teamwork ... for example.

Job Browser Pro and the Occupational Employment Quarterly assume the presence of unskilled work or the presence of light work based on the number of DOT codes counted.  That method assumes a fact without evidence.  Better to use the estimates of the percentage of jobs that represent unskilled and light work from the survey of the economy conducted by the Department of Labor.

See When to Use Occu Collect.

Why is Job Browser Pro Wrong in Moving DOT Codes to Food Processing Workers, All Other?

Food processing workers, all other, is a 2010 SOC addition to the SOC family.  Our friends a Job Browser Pro put 61 DOT codes in the group, for example 524.687-022 Bakery Worker, Conveyor Line,  The question is whether the movement of the DOT codes is appropriate; does it yield reliable job data?

First, the O*NET OnLine publishes the crosswalk and does not move the 61 DOT codes to food processing workers, all other.  The list of DOT codes for production workers, all other contains the 61 food-related codes.  Food processing workers, all other lists no constituent DOT codes.  The O*NET OnLine does not place any of the 61 DOT codes within food processing workers, all other.  Any placement of a DOT code within that group should be carefully considered and justified.

The O*NET Resource Center provides alternate titles to each SOC/O*NET code.  Food processing workers, all other has four alternate titles:

Olive Pitter
Pasta Press Operator
Poultry Hanger
Yeast Maker

Each of those designations has the source code of 04.  That designation means that the occupations come from the SOC.  Code 08 means the DOT or some other related designation.  

Compare that data and source to 40 alternate titles for recycling and reclamation workers (O*NET 51-9199.01), the detailed subset of production workers, all other (SOC 51-9199).  Of those 40 alternate titles, 10 come from the DOT or related source.  The other 30 alternate titles from form incumbent data and employer job postings.  

Production workers, all other (SOC 51-9199) has 2,749 alternate titles.  This includes 1,413 titles that are lifted in whole or in part from the DOT and related sources.  That balance come from the SOC, the Census Bureau, the Department of Labor, and employer job postings.  

Within that list are olive pitter, pasta press operator, poultry hanger, and yeast maker.  Those move over to food processing workers.  The other food-related production worker occupations -- those stay right there.  Bakery worker, conveyor line and its ilk are production worker, not food processing worker occupations. 

See When to Use Occu Collect.

Word Processors and Typists (SOC 43-9022) - Very Few Unskilled Jobs

We covered the concept that Specific Vocational Preparation (SVP) is more than on-the-job training.  It includes prior work experience, training, and apprenticeship programs.  We discussed the proposition that at least five occupations in the DOT are obsolete.  This piece explores the proposition that Word Processors and Typists are typically semi-skilled.  This occupational group includes the nefarious Addresser.  We start with the Occupational Outlook Handbook. 

43-9022 Word processors and typists

Typical Education Needed	High school diploma or equivalent
Work Experience in a Related Occupation	None
Typical On-The-Job Training Needed to Attain Competency	Short-term on-the-job training
2016 Employment	74,900

The OOH sets the bar at high school education and short-term on-the-job training. High school education is not an SVP add-on. Short-term on-the-job training implies an unskilled occupational group. The Bureau of Labor Statistics provides data on the education level of incumbents through the employment projections:

Education Levels of Incumbents

43-9022 Word processors and typists

Typical Education Needed	High school diploma or equivalent
Less than a High School Education	2.8
High School Education or Equivalent	28
Some College, No Degree	32.1
Associates Degree	14.3
Bachelor's Degree	18.2
Masters's Degree	3.8
Doctoral or Professional Degree	0.7

This report points out that almost 70% of incumbents hold a greater level of education than the OOH describes as typical. The Department of Labor tells us to look to the O*NET for up-to-date information about work, so we do:

On-the-Job Training
Duration	Value
None or short demonstration	3.99%
Anything beyond short demonstration, up to and including 1 month	47.55%
Over 1 month, up to and including 3 months	6.01%
Over 3 months, up to and including 6 months	8.32%
Over 6 months, up to and including 1 year	3.66%
Over 1 year, up to and including 2 years	13.63%
Over 2 years, up to and including 4 years	3.28%
Over 4 years, up to and including 10 years	13.39%
Over 10 years	0.18%

Related Work Experience
Duration	Value
None	4.03%
Up to and including 1 month	0%
Over 1 month, up to and including 3 months	5.01%
Over 3 months, up to and including 6 months	3.11%
Over 6 months, up to and including 1 year	40.36%
Over 1 year, up to and including 2 years	28.1%
Over 2 years, up to and including 4 years	5.97%
Over 4 years, up to and including 6 years	13.25%
Over 6 years, up to and including 8 years	0%
Over 8 years, up to and including 10 years	0%
Over 10 years	0.18%

Required Level of Education
Education Level	Value
Less than a High School Diploma	1.96%
High School Diploma or the equivalent	49.61%
Post-Secondary Certificate	0%
Some College Courses	45.45%
Associate's Degree (or other 2-year degree)	2.98%
Bachelor's Degree	0%
Post-Baccalaureate Certificate	0%
Master's Degree	0%
Post-Master's Certificate	0%
First Professional Degree	0%
Doctoral Degree	0%
Post-Doctoral Degree	0%

The data for on-the-job training fits with the OOH report of short-term on-the-job training. The plurality of the jobs require one month of less of training. The required level of education puts the education level of incumbents into context; many workers in this occupation have more education than is required by the work functions. The majority of word processors and typists have a high school education (including equivalents) or less.

The related work experience provides the ah ha moment. The plurality of these jobs require more than six month of related work experience, 40.36% of them. The percentage of jobs requiring one month or less (but some) of training is 0% and and the percentage requiring no related work experience is 4.03%.

With 74,900 word processors and typists in the economy, that percentage of no related work experience means that the number of unskilled jobs cannot exceed 3,019 jobs.  The number of unskilled jobs cannot exceed the lowest rating withing training, experience, and education.  Using that number assumes that the work requiring no experience are the same jobs that require one month of training or less and a high school diploma or less.  

This conclusion is not surprising.  Of the eight DOT codes within Word Processors and Typists, one of them is unskilled, three of them are semi-skilled, and three are skilled.  

DOTCode	DOTTitle	SVP
209.587-010	ADDRESSER	2
203.362-010	CLERK-TYPIST	4
209.382-010	CONTINUITY CLERK	5
203.382-030	WORD PROCESSING MACHINE OPERATOR	5
203.582-050	TELEGRAPHIC-TYPEWRITER OPERATOR	4
203.582-058	TRANSCRIBING-MACHINE OPERATOR	5
203.582-066	TYPIST	3
203.582-078	NOTEREADER	5

Addresser - obsolete and if unskilled work exists for word processors and typists, it does not represent a significant number of jobs.

A word about the education, training, and experience report:  the data is available form the O*NET Resource Center, as are all O*NET data.  OccuCollect puts the data into a report format that is readable, usable, and presentable.  Click on Account and start your experience today.  

SVP is More than OTJ -- Education and Experience Count Too

The Department of Labor released Collection Manual 4.0 in August 2017.  Chapter 5 addresses the calculation of SVP.  Here is the general statement that incorporates SSA's requirements for the disability process:

SVP measures the minimum vocational preparation time needed for a job, not the type of knowledge required. Traditionally, SSA has used SVP as a proxy to quantify skill required by a job. SVP includes only vocationally relevant preparation time. Therefore, SVP excludes time spent completing general education requirements, non-vocationally relevant credentials, general experience, and probationary periods where workers aren’t actively receiving on the job training. Exclude any establishment hiring requirements that do not relate to the job’s critical tasks

From this statement, we can rest assured that the ORS will provide SVP in the same manner as SSA wants -- which is how the DOT was/is organized.  The Collection Manual continues:

 SVP consists of four components:
• Minimum Education
• Credentials
• Experience
• On the Job Training

High school is considered general education and therefore does not count for establishing SVP.  Credentials do count if they fall in the list:

• Certifications
• Licenses
• Educational Certificates
• Apprenticeships
• Vocational training
• Non-credit courses
• Credit courses that do not result in a degree 

Experience required for the job counts for SVP and includes:

•  Skills acquired or used in a similar job
• Progressively responsible levels of work
• Broad, yet related, vocational capabilities

And on-the-job training both counts and is broader than show and do:

• Time workers take to learn basic job tasks while being actively taught by a supervisor or a more experienced worker
• On the job training with verbal and written instruction, demonstration and observation, hands-on practice, or imitation
• Vocationally relevant classes or training needed to do the job, including in-plant or internal company training
• Time spent shadowing 

These reference points allow us to establish that an occupation is not unskilled with data available from the O*NET Resource Center and the ORS when the SVP is not specifically stated but the criteria for SVP are provided.  Occu Collect will post the education, training, and experience data next week. 

Electrical and Electronic Equipment Assemblers - SOC 51-2022

Vocational expert assumes a limitation to light or sedentary work with additional limitations including a sit-stand option and occasional superficial contact with coworkers and supervisors.  The vocational expert identifies an occupation on this list:

DOTCode	DOTTitle	SVP	STRENGTH
720.687-010	RECORD-CHANGER ASSEMBLER	2	L
725.384-010	TUBE ASSEMBLER, ELECTRON	2	L
725.684-018	STEM MOUNTER	2	S
726.687-022	ENCAPSULATOR	2	L
727.684-014	BATTERY ASSEMBLER, PLASTIC	2	L
727.687-022	ASSEMBLER, DRY CELL AND BATTERY	2	L
727.687-046	CELL TUBER, HAND	2	L
727.687-082	WAFER-LINE WORKER	2	L
729.684-046	SPARK-PLUG ASSEMBLER	2	L
729.684-054	SUBASSEMBLER	2	L
729.687-010	ASSEMBLER, ELECTRICAL ACCESSORIES I	2	L

According to the vocational expert, there are 20,000 jobs in the single occupation identified.  We check the Occupational Outlook Handbook to start the process of determining whether the vocational expert is reliable.  The OOH states that electrical and electronic equipment assemblers are summarized:

51-2022 Electrical and electronic equipment assemblers

Typical Education Needed	High school diploma or equivalent
Work Experience in a Related Occupation	None
Typical On-The-Job Training Needed to Attain Competency	Moderate-term on-the-job training
2016 Employment	218,900

The group includes 61 DOT codes at sedentary through heavy exertion and SVP 2 to 7 in skill level.  The occupation has typical requirements of a high school education or equivalent and is typically semi-skilled to skilled. 

The Occupational Requirements Survey does not provide data for this occupational group through the 2017 data release. 

The O*NET OnLine does not provide a basis for segregating out skilled and unskilled occupations much less by exertion.  We can just fold the tent and trust the vocational expert, break out Job Browser Pro which will divide the industries up equally among the 61 contenders, or keep working.  Let's use option number three. 

The O*NET Resource Center provides education, training, and experience data for occupations other than "all other" groups that do not have a specialty designation, i.e. **-***9.00.  The ORC reports:

51-2022 Electrical and electronic equipment assemblers

SVP	Percent
1	12.12
2	32.88
3	16.4
4	16.82
5	13.59
6	8.2
7	0
8	0
9	0

The 12 unskilled DOT codes (one more requires medium exertion) make up 45% of the jobs.  That starts the process at over 90,000 jobs.  That interim point begins the next phase of questioning about the individual requirements of the 12 DOT codes and whether nonexertional, education, or other factors erode the occupational base. 

Sometimes we explore an occupational group and find that while the vocational expert is not right, the testimony is at least plausible because of a lack of data.  When the Occupational Requirements Survey includes this occupational group, we will have data on strength as well as prolonged sitting, standing, and walking.