Vocational Expert Claims that Simple is a Subjective Matter of Definition

At a recent hearing, the vocational expert testified that "simple" is a matter of disagreement depending on the definition of the word.  The cases don't prevent a vocational expert from identifying a reasoning level 3 occupation as simple -- just that an apparent conflict exists that requires an explanation.  

There are 87 unskilled DOT codes that carry a reasoning level of 3.  Of those 87 DOT codes, 22 of them require medium or heavy exertion.  We focus on the 65 unskilled DOT codes with a reasoning level of 3 and that require either sedentary or light exertion.  We first review the DOT definition of reasoning level 3:

Apply commonsense understanding to carry out instructions furnished in written, oral, or diagrammatic form. Deal with problems involving several concrete variables in or from standardized situations.

Reasoning level 3 requires that ability to understand, remember, and carry out instructions furnished not just orally or in writing, but also diagrammatically.  Reasoning level 3 requires the ability to handle problems that involve several different concrete variables.  The definition of reasoning level 3 does not sound "simple."  Reasoning level 4 is even more complex.

The DOT lists 68 unskilled sedentary and light DOT codes with a reasoning level of 3 or 4.  The DOT lists 46 occupations with a significant data worker function (the fourth digit of the DOT code); 40 occupations with a significant people worker function (the fifth digit in the DOT code); and 29 with a significant thing worker function (the sixth digit of the DOT code).  The DOT list 6 occupations that have significant worker functions in all three categories; 23 with significant data and people; 11 with significant data and things; and 2 with significant people and things.  The DOT explains data-people-things coding:

Much of the information in this publication is based on the premise that every job requires a worker to function, to some degree, in relation to Data, People, and Things. These relationships are identified and explained below. They appear in the form of three listings arranged in each instance from the relatively simple to the complex in such a manner that each successive relationship includes those that are simpler and excludes the more complex. (As each of the relationships to People represents a wide range of complexity, resulting in considerable overlap among occupations, their arrangement is somewhat arbitrary and can be considered a hierarchy only in the most general sense.) The identifications attached to these relationships are referred to as Worker Functions, and provide standard terminology for use in summarizing how a worker functions on the job. 

The fourth, fifth, and sixth digits of the occupational code reflect relationships to Data, People, and Things, respectively. These digits express a job's relationship to Data, People, and Things by identifying the highest appropriate function

The DOT lists 20 DOT codes with two Work Fields and three DOT codes with three work fields. The Revised Handbook for Analyzing Jobs defines the concept of work fields:

Work Fields. a component of Work Performed. are categories of technologies that reflect how work gets done and what gets done as a result of the work activities of a job: the purpose of the job. There are 96 Work Fields identified for use by the USES for classification of all jobs in the economy in terms of what gets done on the job.

The DOT lists eight DOT codes with two Materials, Products, Subject Matter, and Services ("MPSMS") codes.  The RHAJ defines the concept of MPSMS codes in the context of the overall structure of the DOT data set:

MPSMS is the final link in a chain describing (I) what the worker does (Worker Functions); (2) what gets done (Work Fields); (3) to what (MPSMS).

Of the 68 unskilled sedentary and light DOT codes with a reasoning level of 3 or 4, the DOT lists 30 that have a temperament for repetitive work.  Of that list of 30 DOT codes, 21 have a temperament for attaining precise set limits, tolerances, and standards; two have a temperament for working under specific instruction; and eight have a temperament for working with people beyond receiving instructions.  The 38 DOT codes that do no have a temperament for repetitive work, seven have a temperament for influencing people; eight have a temperament for performing a variety of tasks; 16 have a temperament for attaining precise set limits, tolerances, and standards; one has a temperament for working under specific instruction; 27 have a temperament for working with people beyond receiving instructions; and 14 have a temperament for making judgments and decisions.  Two of the occupations have a temperament for repetitive work and no other required temperament.  Temperaments means:

The category Temperaments is one of the components of job analysis because different job situations call for different personality traits on the part of the worker. Experience in placing individuals in jobs indicates that the degree to which the worker can adapt to work situations is often a determining factor for success. A person's dissatisfaction or failure to perform adequately can sometimes be attributed to an inability to adapt to a work situation rather than to an inability to learn and carry out job duties.

Adapt and adjust have the same contextual meaning.  Adjust is the legal term use to define the ability to perform other work at step 5 of the sequential evaluation process.

 Of the approximately 1,708 light and sedentary unskilled DOT codes.  We have already counted 68 with reasoning level 3 and 4.  The vast majority, 1,607 occupations, have a significant things code (the sixth digit).  The DOT lists 1,398 occupations with one work field; 1,588 occupations with one MPSMS code.  The DOT lists 1,587 occupations with the temperament for repetitive work.  Most of the 1,708 light and unskilled DOT codes meet the requirements for simple and repetitive work.  Reasoning knocks out 68 DOT codes.  Data-people-things; work fields; MPSMS codes; and temperaments warrant further consideration in an occupation-by-occupation basis alongside the narrative of the DOT code in question.  And it is not a subjective determination; it is a matter of looking at statistical data and drawing conclusions from that data with a subjective pre-determined outcome. 

Unskilled and Reasoning Level 2 -- Simple, Repetitive Work? Not Necessarily

Over the past two posts, we discussed reasoning level 2 occupations that are not simple, repetitive work because they are skilled SVP 5 and 6 occupations.  One group carried the temperament for repetitive work but had other characteristics that explained why there were not simple, repetitive work.  The second group did not carry the temperament for repetitive work and necessarily had other characteristics that betrayed the idea of R2 equals simple, repetitive work.  Academically interesting but not informative since the ALJ asks about the ability to perform other unskilled work in the majority of disability cases.  In this and the next few posts, we will use what we learned about R2 skilled work to declassify R2 unskilled work from that simple, repetitive work mantra. 

Consider this list of 24 light, unskilled, reasoning level 2 occupations that do not carry the temperament for repetitive work but do carry the temperament for people. 

DOTCode	DOTTitle
159.647-010	AMUSEMENT PARK ENTERTAINER
371.567-010	GUARD, SCHOOL-CROSSING
372.667-042	SCHOOL BUS MONITOR
311.472-010	FAST-FOODS WORKER
352.677-018	WAITER/WAITRESS, CLUB
311.477-010	CAR HOP
319.464-014	VENDING-MACHINE ATTENDANT
344.677-010	PRESS-BOX CUSTODIAN
349.677-018	CHILDREN'S ATTENDANT
342.667-014	ATTENDANT, ARCADE
324.577-010	ROOM-SERVICE CLERK
335.677-014	HOT-ROOM ATTENDANT
346.677-018	SECOND
358.677-014	LOCKER-ROOM ATTENDANT
353.667-010	ESCORT
349.667-010	HOST/HOSTESS, DANCE HALL
249.366-010	COUNTER CLERK
295.467-010	BICYCLE-RENTAL CLERK
295.467-018	HOSPITAL-TELEVISION-RENTAL CLERK
291.454-010	LEI SELLER
291.457-010	CIGARETTE VENDOR
292.457-010	NEWSPAPER CARRIER
205.367-058	TRAFFIC CHECKER
245.367-014	BLOOD-DONOR-UNIT ASSISTANT

Several occupations on the list jump out as identified by vocational experts.  Some, like cigarette vendor, do not exist or exist in dwindling numbers -- my hunch with no data exploration.  Each of the occupations listed carry a "S" for significant on that middle digit, the people code in the data-people-things coding.  This significant-not significant coding is found in a variety of sources that compile the electronic files of the DOT-SCO data set, such as Occu Collect.  The people codes range from 4 to 7 in this set.  The DOT defines those classifications:

4 Diverting: Amusing others, usually through the medium of stage, screen, television, or radio.

 5 Persuading: Influencing others in favor of a product, service, or point of view.
 6 Speaking-Signaling: Talking with and/or signaling people to convey or exchange information. Includes giving assignments and/or directions to helpers or assistants.
 7 Serving: Attending to the needs or requests of people or animals or the expressed or implicit wishes of people. Immediate response is involved.

The words "others" or "people" are in the categories used and are designated as significant.  The temperament for people from the Revised Handbook for Analyzing Jobs (Dept. of Labor 1991) refines the concepts:

Dealing with PEOPLE: Involves interpersonal relationships in job situations beyond receiving work instructions.

This definition of the people temperament includes more than the interaction of receiving instructions; this definition requires the ability to engage in interpersonal relationships.  People are not simple.  The fifth example has the most application to unskilled work activity.  The RHAJ describes dealing with people by exemplar:

 Receives callers at establishment, determines nature of business, and directs callers to destination.

Embedded in this definition are the functions of making determinations of the intent or need of another person and making a decision how or who the caller needs to go to meet that need.  The 24 light unskilled occupations do not qualify as simple, repetitive tasks despite the presence of reasoning level 2 because of the significance of dealing with people beyond receiving work instructions   Occupations without the temperament for repetitive or short cycle work and with a temperament are not simple nor are they repetitive.  

Reasoning Level 2, Not Repetitive and Yes, Still Skilled Work

We discussed the finding of reasoning level 2 work with a temperament for repetitive work activity as skilled work and therefore not simple repetitive work.  The DOT lists another 14 occupations that have the designation of reasoning level 2, do not have the temperament for repetitive work, and are SVP 5 and 6 -- skilled work.  The 14 occupations:

DOT Code	DOT Name
378.684-022	INFANTRY INDIRECT FIRE CREWMEMBER
502.664-018	STEEL-POURER HELPER
514.582-010	VACUUM CASTER
575.684-026	GATHERER
619.484-010	ORNAMENTAL-METAL-WORKER HELPER
720.684-014	PHONOGRAPH-CARTRIDGE ASSEMBLER
732.684-118	SKI REPAIRER, PRODUCTION
774.384-010	INSPECTOR II
805.664-010	BOILERMAKER HELPER II
842.684-014	DRY-WALL APPLICATOR
863.664-010	BLOWER INSULATOR
951.685-014	FIRER, LOW PRESSURE
952.687-014	SUBSTATION-OPERATOR HELPER
962.687-022	GRIP

Like the list of R2 repetitive occupations, none of these occupations have a significant need to deal with people so that is not the reason for their skilled classification. Inspector II has a significant worker function for data, compiling:

3 Compiling: Gathering, collating, or classifying information about data, people, or things. Reporting and/or carrying out a prescribed action in relation to the information is frequently involved.

That "3" is the fourth digit in the data-people-things cluster. These occupations require significant worker functions with things, mostly "4" with one each of 2, 5, and 7. From Appendix B of the DOT:

2 Operating-Controlling: Starting, stopping, controlling, and adjusting the progress of machines or equipment. Operating machines involves setting up and adjusting the machine or material(s) as the work progresses. Controlling involves observing gauges, dials, etc., and turning valves and other devices to regulate factors such as temperature, pressure, flow of liquids, speed of pumps, and reactions of materials.

4 Manipulating: Using body members, tools, or special devices to work, move, guide, or place objects or materials. Involves some latitude for judgment with regard to precision attained and selecting appropriate tool, object, or material, although this is readily manifest.

5 Tending: Starting, stopping, and observing the functioning of machines and equipment. Involves adjusting materials or controls of the machine, such as changing guides, adjusting timers and temperature gauges, turning valves to allow flow of materials, and flipping switches in response to lights. Little judgment is involved in making these adjustments.

7 Handling: Using body members, handtools, and/or special devices to work, move, or carry objects or materials. Involves little or no latitude for judgment with regard to attainment of standards or in selecting appropriate tool, object, or materials.

These worker functions implicate the SSA definition of skilled work:

Skilled work requires qualifications in which a person uses judgment to determine the machine and manual operations to be performed in order to obtain the proper form, quality, or quantity of material to be produced. Skilled work may require laying out work, estimating quality, determining the suitability and needed quantities of materials, making precise measurements, reading blueprints or other specifications, or making necessary computations or mechanical adjustments to control or regulate the work. Other skilled jobs may require dealing with people, facts, or figures or abstract ideas at a high level of complexity.

Infantry indirect fire crewman is the only occupation that requires a temperament for working under stress. It also requires exercising judgment. Including the infantry crewman occupation, 12 of the 14 reasoning level 2 non-repetitive occupations require the exercise of judgment as a temperament. Ten of those occupations require the temperament for attaining precise set limits and tolerances. The remaining two occupations (boiler maker II and grip) require the temperament for performing a variety of duties.

The three key temperaments of use of judgment, attaining set limits, and performing a variety of tasks are defined in the Revised Handbook for Analyzing Jobs (Dept. of Labor 1991) as:

Performing a VARIETY of Duties: Involves frequent changes of tasks involving different aptitudes, technologies, techniques, procedures, working conditions, physical demands, or degrees of attentiveness without loss of efficiency or composure. The involvement of the worker in two or more work fields may be a clue that this temperament is required.

Attaining Precise Set Limits, TOLERANCES, and Standards: Involves adhering to and achieving exact levels of performance, using precision measuring instruments, tools, and machines to attain precise dimensions; preparing exact verbal and numerical records; and complying with precise instruments and specifications for materials, methods, procedures, and techniques to attain specified standards. 

Making JUDGMENTS and Decisions: Involves solving problems, making evaluations, or reaching conclusions based on subjective or objective criteria, such as the five senses, knowledge, past experiences, or quantifiable or factual data.

Performing a variety of tasks, attaining precise set limits, and making judgments are quintessentially inconsistent with a limitation to simple repetitive or routine tasks. Next we will look at unskilled occupations that share these temperaments with the same question, are they simple repetitive or routine tasks.

Simple Unskilled Work with the Work Function of Persuading

As we persist through the agonal days of the Dictionary of Occupational Titles, time still exists to disassemble vocational expert testimony based on apparent conflict with the DOT.  The typical basis for establishing conflict with the testimony and the DOT focus on the trailer information described in Appendix C.  I have suggested at NOSSCR conferences that we use the Data-People-Things codes found in Appendix B.  This post looks at the 11 unskilled occupations and one semi-skilled occupation occasionally identified as transitioned to unskilled with the fifth digit, of 5. 

The middle three digits "reflect relationships to Data, People, and Things, respectively. These digits express a job's relationship to Data, People, and Things by identifying the highest appropriate function in each listing." The 5th digit of the DOT code reflects the people function. When that 5th digit is a 5, the DOT informs that the occupation requires persuasion.

                               DOT             Name                                                St  SVP   GED

291.457-010	Cigarette Vendor	L	2	222
291.454-010	Lei Seller	L	2	222
292.457-010	Newspaper Carrier	L	2	222
295.357-018	Furniture-Rental Consultant	L	2	322
342.657-010	Barker	L	2	323
293.357-014	Fund Raiser II	L	2	323
293.357-018	Goodwill Ambassador	L	2	323
291.357-010	Sales Representative, Door-to-Door	L	2	323
342.357-010	Weight Guesser	L	2	323
291.457-014	Lounge-Car Attendant	M	2	222
291.457-022	Vendor	M	2	222
299.357-014	Telephone Solicitor	S	3	333

Some of the usual suspects are on the list. Furniture-rental consultant, fund raiser II, and telephone solicitor. The two medium occupations have reasoning level 2 as do three of the light occupations. The common factor in these 12 DOT codes is that 5th digit -- a 5. Appendix B defines that worker function as persuading. Appendix B refines that definition:

5 Persuading: Influencing others in favor of a product, service, or point of view.

The Revised Handbook for Analyzing Jobs gives examples of persuading as a worker function.

5 Persuading: Influencing others in favor of a product, service, or point of view.
5: 1 Sells services of industrial psychology firms to management officials.
5:2 Calls on farmers to solicit repair business and to sell new milking equipment. Demonstrates milking machines.
5:3 Offers articles at auction, asking for bids, attempting to stimulate buying desire of bidders and closing sales to highest bidder.
5:4 Sells all types of life insurance by pointing out company programs that meet clients' insurance needs.
5:5 Solicits membership for club or trade association. Visits or contacts prospective members to explain benefits and cost of membership and to describe organization and objective of club or association.
5:6 Contacts individuals and firms by telephone and in person to solicit funds for charitable organization.
5:7 Sells home appliances to customer after pointing out salable features of merchandise.
5:8 Calls on retail outlets to suggest merchandising advantages of company's trading stamp plan.
5:9 Promotes use of and sells ethical drugs and other pharmaceutical products to doctors, dentists, hospitals, and retail and wholesale drug establishments.
5:10 Purchases merchandise or commodities for resale.

Worker functions that require persuading are not simple. They might be a skills that a worker has to learn over time to gain proficiency. It is well beyond the suggestive-sell of a fast food worker, "you want fries with that?"

The ALJ must adduce a reasonable basis for accepting vocational expert testimony that conflicts with the DOT.  Social Security Ruling 00-4p.  Cross-examination becomes key.

"Do you consider the art of persuasion something that workers learn over time?"  
"If reading from a script is all that is necessary for telemarketers, do they need to learn how to read it persuasively?
"Is communicating in a persuasive manner a skill?"
"Is there anything in the medical-vocational profile framed in the ALJ's hypothetical question that suggests to you the ability to perform work functions that require the person to be persuasive?"

Demonstrate fluid application of the DOT in its native format and that might put an end to the VE punking you -- or do for you what it has done for me, provide convincing anecdotal evidence that the VE corps do not put much if any thought into their testimony.

Be aggressive on these "5" jobs, they require persuasion.

Investigator, Dealer Accounts: Reasoning, Math, Language, and Compiling

While on the road this weekend, I posted about the reasoning level 4 occupation of information clerk.  The other reasoning level 4 occupation that the DOT lists as having an unskilled Specific Vocational Preparation code is Investigator, Dealer Accounts. 

241.367-038 INVESTIGATOR, DEALER ACCOUNTS (financial) alternate titles: floor plan adjuster

    Visits dealers to verify purchases financed by bank against physical inventory of merchandise: Reviews computer printouts listing customer names, addresses, and descriptions of merchandise financed through bank credit and chattel mortgage accounts to plan itinerary of unannounced visits to dealer premises. Explains purpose of visit and locates merchandise in areas, such as showroom, storage room, or car lot. Observes features of merchandise, such as size, color, model, and serial number, to verify item against computer printout. Examines records and questions dealer to determine disposition of items missing from inventory and to elicit information on dealer arrangement for payment to bank for merchandise sold. Records findings on printout and notifies supervisor of unusual findings. 
GOE: 07.05.02 STRENGTH: L GED: R4 M3 L4 SVP: 2 DLU: 89

Nestled in the trailer is that reasoning level 4 code.  For the sake of completeness, the DOT defines reasoning level 4:

04 LEVEL REASONING DEVELOPMENT
Apply principles of rational systems to solve practical problems and deal with a variety of concrete variables in situations where only limited standardization exists. Interpret a variety of instructions furnished in written, oral, diagrammatic, or schedule form. (Examples of rational systems include: bookkeeping, internal combustion engines, electric wiring systems, house building, farm management, and navigation.)

This occupation has that same first digit of 3 in the middle group -- it requires compiling.  Appendix B of the DOT defines compiling as:

Gathering, collating, or classifying information about data, people, or things. Reporting and/or carrying out a prescribed action in relation to the information is frequently involved.

That definition of compiling drags the occupation outside of a classification of work requiring "little or no judgment to do simple duties."  The occupation isn't simple and requires the exercise of judgment.  The Revised Handbook for Analyzing Jobs provides an example of compiling that fits this occupation to a "t."

3 Compiling: Gathering, collating, or classifying information about data, people, or things. Reporting or carrying out a prescribed action in relation to the information is frequently involved.

3:4 Summarizes details of transactions in separate ledgers and transfers data to general ledger to maintain records of financial transactions of an establishment.

This example fits the narrative job description contained in the DOT.  The investigator shows up to verify the existence of property on the lot, compares the property to lists, and makes reports.  Not a simple occupation. 

Investigator, dealer accounts also requires math and language skills that might be in the wheel house of a high school graduate (but probably not) and clearly beyond the scope of a claimant with a limited education.  Investigators need math level 3 and language level 4.  Appendix C defines these two GED components:

03 MATHEMATICAL DEVELOPMENT 

Compute discount, interest, profit and loss; commission, markup, and selling price; ratio and proportion; and percentage. Calculate surfaces, volumes, weights, and measures.

Algebra:
Calculate variables and formulas; monomials and polynomials; ratio and proportion variables; and square roots and radicals.

Geometry:
Calculate plane and solid figures; circumference, area, and volume. Understand kinds of angles and properties of pairs of angles.

04 LANGUAGE DEVELOPMENT

Reading:
Read novels, poems, newspapers, periodicals, journals, manuals, dictionaries, thesauruses, and encyclopedias.

Writing:
Prepare business letters, expositions, summaries, and reports, using prescribed format and conforming to all rules of punctuation, grammar, diction, and style.

Speaking:
Participate in panel discussions, dramatizations, and debates. Speak extemporaneously on a variety of subjects.

A claimant that did not take geometry or and upper level language class may not meet the educational requirements not only of reasoning level 4 but also math level 3 and language level 4.  The representative must ask the vocational expert to explain the part of the hypothetical question that permitted the inference that the claimant has those educational achievements and retains those capacities years or decades later.  This job is not simple despite the ease of learning the occupation on the base of a high school graduate that took algebra, geometry, and honors English. 

Information Clerk, Reasoning Level 4, and Unskilled Work

The Dictionary of Occupational Titles lists 3,127 unskilled occupations.  The vast majority of those occupations require reasoning levels 1 and 2.  These levels of reasoning correspond with the regulatory recognition of unskilled work as generically simple.

There are 89 DOT codes that require reasoning level 3.  The cases have recognized that reasoning level 3 requires more than simple routine or repetitive work.  Today, we look at one of two occupations that require neither the simple range of reasoning levels 1 and 2 nor the non-simple range of reasoning level 3, we examine reasoning level 4.

237.367-018 INFORMATION CLERK (motor trans.; r.r. trans.; water trans.) alternate titles: travel clerk

    Provides travel information for bus or train patrons: Answers inquiries regarding departures, arrivals, stops, and destinations of scheduled buses or trains. Describes routes, services, and accommodations available. Furnishes patrons with timetables and travel literature. Computes and quotes rates for interline trips, group tours, and special discounts for children and military personnel, using rate tables.
GOE: 07.04.04 STRENGTH: L GED: R4 M2 L3 SVP: 2 DLU: 77

The DOT defines reasoning level 4:

04 LEVEL REASONING DEVELOPMENT

Apply principles of rational systems to solve practical problems and deal with a variety of concrete variables in situations where only limited standardization exists. Interpret a variety of instructions furnished in written, oral, diagrammatic, or schedule form. (Examples of rational systems include: bookkeeping, internal combustion engines, electric wiring systems, house building, farm management, and navigation.)

Dealing with a variety of concrete variables with limited standardization; understanding, remembering, and carrying out instructions provided in diagrammatic or schedule form in addition to the standard written or oral form fail the classification of simple, routine or repetitive.  That's the easy part.  Reasoning level 4 exceeds the complexity of reasoning level 3 and logically falls outside the pale of simple work as envisioned by the regulations.  

The middle three digits give more information beyond a distinguishing code.  The middle three digits signify the classification of data-people-things.  The first of the middle three digits, "3," denotes an occupational requirement of compiling.  Appendix B of the DOT defines compiling as:

Gathering, collating, or classifying information about data, people, or things. Reporting and/or carrying out a prescribed action in relation to the information is frequently involved.

That definition of compiling drags the occupation outside of a classification of work requiring "little or no judgment to do simple duties."  The occupation isn't simple and requires the exercise of judgment.  The Revised Handbook for Analyzing Jobs provides examples of compiling:

3 Compiling: Gathering, collating, or classifying information about data, people, or things. Reporting or carrying out a prescribed action in relation to the information is frequently involved.

3:1 Operates wire-drawing machine, observing operation of machine as work progresses and making adjustments to conform to written specifications.

3:2 Classifies aircraft flight data and submits data to Dispatcher for approval and flight authorization.

3:3 Collects, classifies, and records forest data, such as rainfall, stream flow, and soil moisture, to develop information tables.

3:4 Summarizes details of transactions in separate ledgers and transfers data to general ledger to maintain records of financial transactions of an establishment.

3:5 Collects and arranges flight arrival and departure times at specified points to construct flight schedule.

3:6 Receives telephone complaints from public concerning crimes or other emergencies, records complaints, and files them for future processing.

3:7 Catalogs library materials, such as books, films, and periodicals, according to subject matter.

3:8 Sells footwear, such as shoes, boots, overshoes, and slippers, in department store.

3:9 Sets up metal-stamping machines for other workers according to product specifications and prescribed procedures.

3:10 Prepares specialty foods, such as tacos and fish and chips, according to recipe using specific methods applicable to type of cookery.

3:11 Inspects precision optical and ophthalmic lenses at various stages of production to determine lenses meet company standards, according to work order and prescription specifications. using precision measuring instruments.

The examples of compiling belie the continued classification of this occupation as simple.  A person may be able to learn the occupation in less than 30 days only because education is a substitute for experience and training.  The intrepid representative should examine a vocational expert on education in general and reasoning in particular as well as hitting the occupational requirement for compiling.