Showing posts with label ORS. Show all posts
Showing posts with label ORS. Show all posts

Thursday, September 18, 2025

Addresser -- A Persistent Favorite of Vocational Witnesses

Assume a person of the same age, education, and work experience of the claimant and assume that the person is limited to sedentary work, sitting six hours in an eight-hour day, frequent handling, frequent fingering, and limited to simple work with no more than occasional interactions with coworkers, supervisors, and the public. Any work?

That person could work as an addresser representing 30,000 jobs in the national economy. 

Is that occupation performed as described in the DOT.

Sometimes workers use typewriters and hand-address labels and envelopes. Sometimes the worker will simply apply labels to envelopes, packages, and cards.

We have heard the mantra. It is nonsense. It is also the recommended explanation that SSA gives to VW in their training. Let's also beat them at their own game.

SkillTRAN estimates that addresser works in eight industries and is also self-employed for a total of 1,952 jobs. Self-employed work is not unskilled work -- it is running a business. Most of the jobs exist in local government, 1,253 jobs. SkillTRAN does not support the existence of 30,000 addresser jobs. 

The OEWS estimates 36,030 jobs for word processors and typists (SOC 43-9022). The EP, OOH, and O*NET reporting the same data set estimate 40,000 jobs. It is curious that a word processor is applying labels. There might be people applying pre-printed labels but they are not word processors and typists, they are general office clerks or mail clerks. The crosswalk places addresser in word processors and typists. The OEWS and OOH defines word processors and typists:

Use word processor, computer, or typewriter to type letters, reports, forms, or other material from rough draft, corrected copy, or voice recording. May perform other clerical duties as assigned. Excludes “Court Reporters and Simultaneous Captioners” (27-3092), “Medical Transcriptionists” (31-9094), “Secretaries and Administrative Assistants” (43-6010), and “Data Entry Keyers” (43-9021).

The O*NET omits the "excludes" portion of the description but is otherwise identical. None of the descriptions leave room for application of labels. 

The crosswalk tells us that word processors and typists contains eight DOT codes, one of them is unskilled, all are sedentary. We should doubt that all word processors and typists are unskilled addressers. 

The 2023 ORS confirms that word processors and typists represent sedentary work in greater than 99.5% of jobs. Call it 100% and move on. The ORS estimates that 26.3% of jobs have up to one month of training. Semi-skilled and skilled work represent 70.6% of jobs. The "less than" estimate of 10% of jobs with a short demonstration (up to four hours) contains all the standard error. If the five state estimates are accurate, the residual is 3.1% of jobs. Let's round up and call it 30% of jobs are unskilled. That means that 10,800 jobs are sedentary and unskilled. Call that progress. 

The ORS describes greater than 50% of jobs have a choice of sitting or standing, less than 50% do not have a choice. Word processors and typists sit 75% of the day at the 10th percentile and more than 75% of the day at all other reported percentiles. Because the "choice" of sitting or standing is "when" and not "how much," the conclusion would leave a person limited to six hours of sitting in a day to 1,080 jobs. 

The O*NET confirms the obvious -- clerical employees work together with other employees. Word processors and typists have constant contact with other in 69% of jobs and most of the time in 31% of jobs. Any limitation on contact or interaction with others eliminates all jobs. The ORS describes all jobs as requiring at least basic people skills. The ORS states that word processors and typists have verbal interactions less than hourly in 23.8% of jobs. The ORS might lead to 2,400 jobs. 

Finally, my favorite source of job numbers. The OEQ assumes 258,841 word processor and typist jobs with one-eighth of them sedentary and unskilled, to wit 32,385 jobs. The SOEUQ suggests 22,695 jobs. Both sources claim reliance on the OES which is the OEWS. We started with the OEWS -- 36,030 jobs total. 

The existence of 30,000 addresser jobs is not sustainable. The only source consistent with that estimate is the OEQ. The SOEUQ contradicts that estimate and comes from the same publisher. Both sources state reliance on the OES, which does not exist. The OEWS and the EP/OOH/O*NET are wholly inconsistent with the OEQ/SOEUQ. And we end where we started, word processors and typists do not affix labels to envelopes, packages, and cards. That is not their job.

The Emergency Message tells the adjudicator to get a further explanation for addresser. When the adjudicators suggest and explanation without looking at the occupational description, we end with a conspiracy to commit idiocy. SSA should go back to the promise made almost 50 years ago -- take administrative notice of jobs, requirements, and job numbers. 

Disgusted.


___________________________


Suggested Citation:

Lawrence Rohlfing, Addresser -- A Persistent Favorite of Vocational Witnesses, California Social Security Attorney (September 12, 2025) https://californiasocialsecurityattorney.blogspot.com


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



















Monday, September 15, 2025

The Problems with the ORS -- Jeff Truthan Speaks at NOSSCR

If you did not attend NOSSCR in San Diego either in person or virtually, you missed out on a very important message from Jeff. He detailed the incomplete nature of the Occupational Requirements Survey (ORS) and data conflict within the ORS. SkillTRAN holds me out as an important reviewer and co-presenter with Jeff. I have standing to comment. 

  1. The ORS covers 477 of 848 civilian Standard Occupational Classification (SOC) codes in the second wave. It does cover 90% of the jobs in the national economy and additional SOC codes get covered in the first or third waves.   
  2. The ORS does not cover General Educational Development (GED) and therefore does not cover Reasoning, Math, and Language (RML). It does cover limited education under the heading of no minimum education required as well and literacy in not required.  
  3. The ORS does not cover either Aptitudes or Temperaments. SSA rejects them anyway. 
  4. The ORS does not cover Balancing, Feeling, or Tasting. In 40 years, theses physical requirements have never been an issue. 
  5. The ORS does not cover visual Accommodation, Color Vision, or Depth Perception. The need for depth perception does arise in some cases. 
  6. The ORS does not consistently report Specific Vocational Preparation (SVP). This is a problem if the case turns on transferability of skills, which is less and less likely with the short past relevant work period. 
  7. The ORS does not consistently merge educational and certificate requirements into SVP. This is a problem because it could lead to the misidentification of work as unskilled when it is not. 
  8. The ORS does not consistently report Strength. Not all strength levels matter so the criticism lacks context. The DOT also contains exertion mistakes -- escort vehicle driver for instance. 
  9. The ORS does not cover Work Fields or Materials, Products, Subject Matter, or Services (MPSMS). This is again a transferability issue; SSA recognizes this data in POMS but does not ask witnesses to use the data.
  10. The ORS does not cover Guide to Occupational Exploration (GOE) codes. The DOT and SCO do report the GOE codes. No one uses them. They are potentially relevant in the little or no adjustment issues for older workers in transferability. But no one uses them. 
  11. The ORS does not cover job duties or tasks. Jeff suggests that the Occupational Wage and Employment Statistics and O*NET cover this data. For our purposes, actual job duties come up under SSR 00-4p, which is now rescinded. 

We have some data. Some data is better than no data. New data is better than out-of-date data. Where the data is missing or the analysis of that data is incomplete, we still have the DOT. And SSA needs to grow up and start using the O*NET for the data points that are unrelated to exertion -- for the same reasons. Some data is better than no data or out-of-date data. The Courts must start enforcing the administrative notice regulation. 20 CFR 404.1566(d). 

If you missed the San Diego conference, get the sessions from NOSSCR. Not just this session but certainly including this session. 

Just do it. 

___________________________


Suggested Citation:

Lawrence Rohlfing, The Problems with the ORS -- Jeff Truthan Speaks at NOSSCR, California Social Security Attorney (September 12, 2025) https://californiasocialsecurityattorney.blogspot.com


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
















Friday, July 25, 2025

It Is the Percentage of the Day, Not the Hours of the Day that Matters

In a NOSSCR CLE and in hearings before SSA, I heard presenters, vocational witnesses, and ALJs express reliance on the hours of the day for sitting and standing (including walking) relying on the Occupational Requirements Survey. In Social Security disability hearings, reliance on hours in a day is a mistake.  

We use packers and packagers, hand (SOC 53-7064) as our example of the day. The ORS reports:

Occupational Requirements – sitting, standing (including walking)

2018

2023

2024

choice of sitting or standing is allowed

4.3

2.3

<0.5

choice of sitting or standing is not allowed

95.7

97.7

>99.5

Percent of Day standing is required (10th percentile)

90

90

100

Percent of Day standing is required (25th percentile)

100

100

100

Percent of Day standing is required (50th percentile - median)

100

100

100

Percent of Day standing is required (75th percentile)

100

100

100

Percent of Day standing is required (90th percentile)

100

100

100

Percent of Day standing is required, mean

95.5

95.9

98

hours of standing (10th percentile)

4

4

6

hours of standing (25th percentile)

5

5.88

6

hours of standing (50th percentile - median)

8

8

8

hours of standing (75th percentile)

8

8

8

hours of standing (90th percentile)

8

8

12


The amount of standing at the 10th and 25th percentiles falls within the generally used (and wrong) assumption that light and medium work require six hours of standing/walking during a workday. The question is whether those jobs are full-time work. Packers and packagers stand 90 to 100% of the workday at the 10th and 25th percentiles. How can that be? The jobs are part-time. If a job requires four to six hours of standing during the workday and that standing represents at least 90% of the workday, the person is not working and eight-hour workday. Algebraically:

                                Workday x 90% = 4 hours

Divide each side by 90%. 

                                Workday = 4 hours / 90%

                                Workday = 4.44 hours

The O*NET reports that all packers and packagers work at least a 40-hour workweek.  The ORS disagrees. In the special release dataset for "SVP 1-2 and 35-40 weekly hours - reference year 2023," the downloaded XLSX spreadsheet states that 58.2% of packers and packagers work 35-40 hours and requires a high school diploma or less; 44.4% of packers and packagers have no minimum education requirement. The ORS reports  that 18.2% of packers and packagers require a high school diploma and 70.3% have no minimum education requirement. How do we get from 88% and 70% down to 58% and 44%? Some of the jobs require more than 40 hours and some represent part-time work. 

SSR 96-8p is clear that full-time work satisfies the Commissioner's burden at step five - the existence of other work assuming the claimant's medical-vocational profile. (A "regular and continuing basis" means 8 hours a day, for 5 days a week, or an equivalent work schedule.). At step four, part-time work may matter. (The ability to work 8 hours a day for 5 days a week is not always required when evaluating an individual's ability to do past relevant work at step 4 of the sequential evaluation process. Part-time work that was substantial gainful activity, performed within the past 15 years, and lasted long enough for the person to learn to do it constitutes past relevant work, and an individual who retains the RFC to perform such work must be found not disabled.). 

Do not allow vocational witnesses to use "hours" as a substitute for "percentage of the day" when assessing the requirements of work. Part-time work does not count. 

That was not always the case. Prior to 2003, the regulations provided for a step-five finding of the ability to perform other work "on a full-time or reasonably regular part-time basis." 20 CFR 404.1562, 416.962 (2002). SSA deleted that language in 2003. 68 Fed. Reg. 51153 (Aug. 26, 2003). The notice explains:

However, in SSR 96-8p, we explain that at step 5 we consider only full-time work when we consider other work you are able to do. (See 61 FR 34474, 34475 (July 2, 1996).) 

The number of hours that includes consideration of part-time work is not probative at step five. The percentage of the day is the better measure of how much time a worker will spend sitting or standing/walking during a full-time workday. 


___________________________

Suggested Citation:

Lawrence Rohlfing, It Is the Percentage of the Day, Not the Hours of the Day that Matters, California Social Security Attorney (July 25, 2025)  https://californiasocialsecurityattorney.blogspot.com


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




 


Tuesday, March 4, 2025

ORS Reports for SVP 1 or 2, 35-40 Hours per Week by Minimum Education

BLS reports "SVP level 1 or 2 and 35-40 weekly hours by Minimum Education Requirement" in an excel spreadsheet. This same report is replicated by SOC code on OccuCollect.com. Today, we look at electrical and electronic equipment assemblers (SOC 51-2022). Line 358 of the ORS report:

SOC

Occupation

Illiterate

No Min

HS or less

512022

Electrical and electronic equipment assemblers

<10

[15]

<10

[15]

26.3

10.1



The second number in each column is the standard error. If a user runs this report in OccuCollect, that person will get a null result. Why? Thanks for asking. The OOH and OEWS report combines SOC 51-2022 and 51-2023 to form electrical, electronic, and electromechanical assemblers, except coil winders, tapers, and finishers (SOC 51-2028). The OccuCollect report, sans the ORS header, reports:

51-2022 - Electrical and electronic equipment assemblers

SVP level 1 or 2 and 35-40 weekly hours by Minimum Education Requirement


The OOH Dataset does not report a Job numbers for this SOC.

Minimum Education Required

Percentage

# of Jobs

Total Jobs (OOH 2023)

100%

Not Reported

No literacy

<10%

Not Reported

No Minimum

<10%

Not Reported

High School Diploma

26.3%

Not Reported


There are job numbers in the OEWS and OOH. Running the OEWS data on the report states:

51-2028 -

SVP level 1 or 2 and 35-40 weekly hours by Minimum Education Requirement

Minimum Education Required

Percentage

# of Jobs

Total Jobs (OEWS 2023)

100%

267,440

No literacy

Not Reported

Not Reported

No Minimum

Not Reported

Not Reported

High School Diploma

Not Reported

Not Reported


Users can put those two together. There are less than 10% of jobs (< 26,744) jobs that do not require a high school education, some of those may not require literacy.  The problem gets worse. The 2018 and 2023 ORS date report on education states:

Occupational Requirements – education

2018

2023

2024

no minimum education requirement

26.7

23.1

no minimum education required, and literacy is not required

--

<10

no minimum education required, and literacy is required

--

<35

minimum education level is a high school diploma

66.8

66.7

minimum education level is a high school vocational degree

-

-

--

minimum education level is an associate's degree

-

-

minimum education level is an associate's vocational degree

-

-

--

minimum education level is a bachelor's degree

-

<0.5

minimum education level is a master's degree

-

<0.5

minimum education level is a doctorate degree

-

<0.5

minimum education level is a professional degree

-

<0.5

The ORS reports two-thirds of jobs require a high school education or equivalent (see the Collections Manual for the definition of high school education) and 23.1 to 26.7% of jobs have no minimum education requirement. Of those jobs that do not have a minimum education requirement, less than 35% require literacy and les than 10% do not require literacy. Less than 35% plus less than 10% equal 23.1%. That's stats. 

This aggregation of 90+% of jobs includes all skill levels. The ORS reports for skill level SVP1 and 2:

 

Occupational Requirements – specific vocational preparation

2018

2023

2024

specific vocational preparation is short demonstration only

-

<0.5

specific vocational preparation is beyond short demonstration through 1 month

29.2

29.2

The difference between 29.2% of jobs as unskilled and the report of 26.3% of jobs as requiring a high school diploma or less is answered by two syllables, part-time. There are approximately 70,300 jobs in the national economy for a person limited to unskilled work. Less than 10% of those jobs exist for a person limited to simple work, less than 7,000 jobs at all exertional levels. 

The regulations define a high school education as having the "abilities in reasoning, arithmetic, and language skills acquired through formal schooling." 20 CFR 404.1564(b)(4). A limitation to simple work is in fact a limitation on the ability to access a high school education under subsection (b), "the numerical grade level that you completed in school may not represent your actual educational abilities."

Of those less than 7,000 jobs at all exertion levels, the ORS tells us that less than 3,000 are sedentary and less than 1,500 are light jobs:

Occupational Requirements – strength, exertion

2018

2023

2024

strength required is sedentary

-

34

strength required is light work

28.3

20.8

In today's economy, the number of sedentary and light jobs for a person with a limited education or a limitation to simple work is less than 4,500. Less than is the critical phrase. Because SSA defines full-time work as a 40-hour workweek or an equivalent schedule, the reliable number is even lower. 

Proper presentation of the number of jobs as rebuttal evidence requires chasing the rabbit all the way down the hole, ignoring the Cheshire Cat, evading the Queen of Hearts, and escaping the a-statistical methodology used by witnesses with a request that the agency adhere to its promise -- administrative notice. 20 CFR f404.1566(d).

Be not afraid. 

___________________________

Suggested Citation:

Lawrence Rohlfing, ORS Reports for SVP 1 or 2, 35-40 Hours per Week by Minimum Education, California Social Security Attorney (March 1, 2025)  https://californiasocialsecurityattorney.blogspot.com


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





Wednesday, February 26, 2025

What's Wrong with SSR 24-3p?

 SSR 24-3p introduces a new interpretation of the stable administrative notice regulation, 20 CFR 404.1566(d). The Commissioner has long held as a matter of law to the proposition that when it comes to unskilled sedentary, light, and medium work, the Commissioner will take administrative notice of reliable governmental and other (private) published data for the requirements and numbers of jobs. SSR 00-4p responded to a growing number of cases -- and a split in the circuits -- that the ALJ must address conflicts between vocational testimony and the Dictionary of Occupational Titles (DOT). 20 CFR 404.1566(d)(1). The Commissioner conceded to the fact that the Selected Characteristics of Occupations (SCO) was part of the single data set. SSR 00-4p imposed on the ALJ the duty to investigate the existence of a conflict or apparent conflict and to resolve that conflict based on evidence. 

But the DOT and its dataset never stated job numbers, never. Job numbers are now and in 1978 stated in the Occupational Outlook Handbook (OOH) and County Business Patterns (CBP). 20 CFR 404.1566(d)(2), (5).Now, the Bureau of Labor Statistics publishes online the Employment Projections (EP) and the Occupational Employment and Wage Statistics (OEWS, formerly the OES). 

Labor abandoned the DOT and its data set never updating the DOT fourth edition, revised published in 1991 or the SCO published in 1993. Labor transferred responsibility of the Employment Training Administration from the DOT to the Occupational Information Network (ONET). Recognizing the problem that 10,000 of the 13,000 DOT codes had a date last updated of 1977, the Commissioner was forced to collaborate with Labor to develop a new data set -- the Occupational Requirements Survey (ORS). 

Private sources published data as well. United Stat Publishing published and publishes what is now known as the Occupational Employment Quarterly (OEQ) in various formats for national, state, and local data. That publication uses the equal distribution method of estimating job numbers -- each DOT code within a Standard Occupational Classification (SOC) represents the same number of jobs. The OEQ publishes the job numbers sorted by exertion/skill combinations. United Stat Publishing also publishes the Specific Occupational Employment - Unskilled Quarterly (SOEUQ). The SOEUQ estimates sedentary occupations by industry. The SOEUQ does not state its methodology. 

SkillTRAN publishes OccuBrowse, Job Browser Pro, and OASYS. The latter two estimate job numbers by DOT code. SkillTRAN uses a SOC/OEWS code intersection with selected industries (NAICS codes) and uses equal distribution to estimate the number of jobs per DOT code at those SOC-NAICS intersections. SkillTRAN uses a proprietary and unpublished methodology and does not use the data from the EP or OEWS that publish SOC-NAICS data. SkillTRAN uses the CBP to modify the data. The SkillTRAN SOC-NAICS data resembles but does not duplicate either the EP or OEWS SOC-NAICS data. 

That is the basic lay of the data. Job requirements are still found in the DOT and the Commissioner clings to that data set. Job requirements are found with current data in the ONET and the ORS. Job numbers are still found in the OOH and CBP -- they are up to date -- as well as the EP and OEWS. Three data sets for requirements and four data sets for job numbers. No one should use the OEQ for any purpose. JBP and OASYS continue to have utility for stating the SOC-NAICS intersection job numbers but does not parse that data based on occupational classifications nor erode for any impairment. JPB and OASYS are starting points. 

Here is the problem. The vocational witness claims to have considered the broad range of data along with their vast (local and anecdotal) experience to derive a job numbers based on no discernible methodology. Some will default to JBP/OASYS. That is at least a defensible starting point. Some will claim that the OEQ remains in the mix. That is bogus. 

And the ALJ corps blindly accepts testimony that is incoherent and meaningless. The witnesses are not consistent across time. They are not consistent with each other according to the cases. Because the claimants have privacy of their medical data, we never get to see the testimony that the witnesses give in different cases or to compare different witnesses in same and similar cases. The system lacks accountability and reliability. The system invoked by SSR 24-3p creates vocational witness lottery. That is not a system of administrative justice; it is legalized gambling with people's lives and the social safety net. 

But I never get passionate about these issues. 


___________________________

Suggested Citation:

Lawrence Rohlfing, What's Wrong with SSR 24-3p?, California Social Security Attorney (February 26, 2025)  https://californiasocialsecurityattorney.blogspot.com


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




Tuesday, January 7, 2025

Helpers--Production Workers Require Medium Exertion

 Helpers-Production Workers (SOC 51-9198) is a large group of occupations. The O*NET Crosswalk beaks down:

553 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report
12 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Sedentary
      2 are SVP 1      10 are SVP 2
176 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Light
      31 are SVP 1      126 are SVP 2
221 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Medium
      16 are SVP 1      156 are SVP 2
137 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Heavy
      12 are SVP 1      93 are SVP 2
7 DOT title(s) in this DOT-SOC O*NET-SOC Crosswalk Report are Very Heavy
      1 are SVP 1      5 are SVP 2

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

 With 553 DOT codes contains 452 SVP 1 and 2 occupations. The 2023 EP X OEWS Job Numbers Crosswalk Report 

51-9198 - Helpers--production workers
Sector & Sub Sector - 2 & 3 Digit NAICS

NAICS

INDUSTRY

EP 2023 #'s

OEWS 2023 #'s

TE1000

Total employment

183,500

181,810

TE1000

Self-employed workers

1,700

No Data

TE1000

Total wage and salary employment

181,800

No Data

The Employment Projections (EP) "total employment" includes self-employed people. The Occupational Employment and Wage Statistics (OEWS) does not include self-employed people. The two BLS data sources agree that Helpers--Production Workers represent 181,800 jobs. The ORS 2018/2023/2024 report for physical requirements states:

51-9198 - Helpers--production workers

Physical Demands (values are Percentages, Pounds, or Hours)

Occupational Requirements – strength, exertion

2018

2023

2024

strength required is sedentary

-

<5

<0.5

strength required is light work

-

12.9

4.9

strength required is medium work

49.2

76.5

91.8

strength required is heavy work

-

10

3.4


While the 2023 data set suggests 12.9% of jobs represent light work, the 2024 data set reports 4.9%  represent light work. We also know that the ORS defines light work as occasional lifting/carrying up to 25 pounds. We next examine the specific vocational preparation (SVP) for helpers--production workers. 

51-9198 - Helpers--production workers

Education, Training, And Experience (values are Percentages or Days)

Occupational Requirements – specific vocational preparation

2018

2023

2024

specific vocational preparation is short demonstration only

-

5.7

-

specific vocational preparation is beyond short demonstration through 1 month

68.3

88.4

71.1


Most helpers--production workers engage in unskilled work. The OccuCollect Calculator puts the data together for 2023:

51-9198 - Helpers--Production Workers

Job Number Calculations

# of OEWS Jobs

% Full-Time

# Full-Time

181,810

94%

170,901

# of Jobs

% Unskilled

# Unskilled

170,901

94.1%

160,818

# of Jobs

% Light

# Light

160,818

12.9%

20,746


and for 2024:

51-9198 - Helpers--Production Workers

Job Number Calculations

# of OEWS Jobs

% Full-Time

# Full-Time

181,810

94%

170,901

# of Jobs

% Unskilled

# Unskilled

170,901

71.1%

121,511

# of Jobs

% Light

# Light

121,511

4.9%

5,954    

Whether the witness uses the 2023 data set claiming 20,000 jobs or the 2024 data set claiming 6,000 jobs, that identification covers 157 DOT codes. The number of jobs must be reduced to reflect the greater lifting requirements in the modern definition of light work and eroded again for any additional exertional and non-exertional limitations. 

A sample of the light unskilled DOT codes from the 2019 O*NET-SOC to DOT Crosswalk Report:

Reporting O*NET Dataset 29.1
51-9198.00-Helpers--Production Workers

DOT Code

DOT Title

SVP

Strength

230.687-010

Advertising-Material Distributor

2

L

369.687-018

Folder

2

L

520.687-046

Mexican Food Maker, Hand

2

L

520.687-066

Blending-Tank Tender Helper

2

L

529.687-010

Basket Filler

1

L


These occupations individually represent a rare incidence of work in the national economy.

Don't let vocational witnesses identify codes within SOC 51-9198 without submitting the rebuttal evidence from the ORS and O*NET applied to the EP or OEWS. 

___________________________

Suggested Citation:

Lawrence Rohlfing, Helpers--Production Workers Require Medium Exertion, California Social Security Attorney (January 7, 2025) https://californiasocialsecurityattorney.blogspot.com


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