Another Missed Opportunity -- Superficial and Brief Contact with Coworkers in Shawver v. Kijakazi

We are back in Shawver v. Kijakazi looking at the limitations to superficial and brief contact with coworkers. We return to the district court decision in Misti Jo. S. v. Comm'r of Soc. Sec. for the residual functional capacity and occupations. In relevant part:

lift 20 pounds occasionally and 10 pounds frequently; stand/walk for up to 4 hours a day with ordinary breaks [...] The claimant is limited to simple, routine and repetitive tasks with occasional detailed work, only ordinary production requirement, and superficial and brief contact with coworkers and general public.

Resulting in: 

Routing Clerk, a Mail Routing Clerk, and a Marking Clerk.

We discussed the limitation to standing/walking for four hours yesterday. That exercise eroded routing clerk and mail clerk while eliminating marker. Vocational cross is a no quarter expedition, we seek to eliminate all jobs. The more common version of this genre of limitation is occasional contact or interaction with others. Superficial and brief is a separate classification having more to do with the quality of interaction, teamwork. 

Superficial and brief contact with others is not a vocationally relevant phrase. A person can have constant superficial and brief contact, nothing is in depth. Because it is conceivable and not classified by the data, the vocational witness gets carte blanche to pontificate. 

Routing clerk (222.687-022) is a shipping, receiving, and inventory clerks (SOC 43-5071) (shipping clerks) occupation. Shipping clerks have no or occasional contact with others in 0% of jobs according to the O*NET. A mere 1% do not coordinate or lead others. Dealing with external customers is "not important at all" in 4% of jobs. Never resolving conflict occurs in 16% of jobs. Working with a group or team is not important in 1% of jobs. 

Mail clerk (209.687-026) is a mail clerks and mail machine operators, except postal service (SOC 43-9051) (mail clerks) occupation. Mail clerks have no or occasional contact with others in 8% of jobs according to the O*NET. Coordinating or leading others is not important in 15% of jobs. Dealing with external customers is "not important at all" in 10% of jobs. Never resolving conflict occurs in 29% of jobs. Working with a group or team is not important in 0% of jobs. 

Marker (209.587-034) is a stockers and order fillers (SOC 53-7065) (stockers) occupation. Stockers have no or occasional contact with others in 4% of jobs according to the O*NET. Coordinating or leading others is not important in 6% of jobs. Dealing with external customers is "not important at all" in 6% of jobs. Never resolving conflict occurs in 29% of jobs. Working with a group or team is not important in 4% of jobs. 

In order to make this type and quality of evidence probative, we have to ask. 

    1. Is "contact with others (face-to-face, by telephone, or otherwise) in order to perform it" superficial and brief?

    2. Is "coordinate or lead others in accomplishing work activities in this job" superficial and brief?

    3. Is fairly important ability to "work with external customers or the public" superficial and brief?

    4. Is the encounter of "conflict situations" on the job superficial and brief?

    5. Is the ability to "work with others in a group or team" as fairly important superficial and brief?

It becomes a matter of extracting concessions from the witness. The follow up question is whether an occupation that required those five workplace requirements or expectations (BFOQ), would you agree that the work required more than superficial and brief contact with coworkers and the public?

When we allow a vocational witness to wax on about the existence of work without exploring the range of available data, we allow the witness and ALJ to take from our clients the benefits that were promised in the Social Security Act. We become a party to a breach of the social contract. 

Forge onward. 

___________________________

Suggested Citation:

Lawrence Rohlfing, Another Missed Opportunity -- Superficial and Brief Contact with Coworkers in Shawver v. Kijakazi, California Social Security Attorney (October 18, 2023)

https://californiasocialsecurityattorney.blogspot.com

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

Missed Opportunities -- Standing and Walking in Shawver v. Kijakazi

In Shawver v. Kijakazi, the claimant litigated the tried-and-true physician opinion evidence, the claimant testimony, the meeting or equaling of the listings, and the non-issue of whether the ALJ propounded a complete hypothetical question based on errors at step three, the assessment of residual functional capacity. 

But step five is always in play when the claimant establishes the inability to perform past relevant work. Misti Jo. S. v. Comm'r of Soc. Sec. gives us the rest of the story. The RFC:

lift 20 pounds occasionally and 10 pounds frequently; stand/walk for up to 4 hours a day with ordinary breaks; occasionally balance, stoop, kneel, crouch, or crawl; occasionally climb ladders, ropes, or scaffolds; avoid exposure to hazardous machinery or equipment; and work in an environment with no more than ordinary office level lighting or noise. The claimant is limited to simple, routine and repetitive tasks with occasional detailed work, only ordinary production requirement, and superficial and brief contact with coworkers and general public.

And the step five occupations:

Routing Clerk, a Mail Routing Clerk, and a Marking Clerk.

Standing/walking four hours in an eight-hour day does not represent a wide range of light work. Social Security Ruling 83-10 describes light work as requiring standing/walking six hours in an eight-hour day and sitting intermittently during the remaining time. There exists an apparent conflict between the agency's understanding of light work and the identification of light work that requires not more than four hours of standing/walking. 

Routing clerk (DOT 209.687-026) is a shipping, receiving, and inventory clerks (SOC 43-5071) (shipping clerks) occupation. Labor places 65 alternate titles including 20 DOT codes in this group. The Occupational Requirements Survey describes shipping clerks. Shipping clerks stand (including walk) half the day at the 25th percentile and 80% of the day at the 50th percentile (median). Shipping clerks engage in sedentary exertion in 7.5% of jobs and light exertion in 21.5% of jobs. Shipping clerks engage in unskilled work (SVP 2) in 46.3% of jobs. 

Mail clerk (DOT 222.687-022) is a mail clerks and mail machine operators, except postal service (SOC 43-9051) (mail clerks) occupation. Labor places 60 alternate titles including 14 DOT codes in this group. The Occupational Requirements Survey describes mail clerks. Mail clerks stand (including walk) half the day at the 50th percentile and 75% of the day at the 75th percentile. Mail clerks lift/carry 20 pounds maximum in at the 25th percentile and 25 pounds at the 50th percentile. Mail clerks engage in unskilled work (SVP 2) in 67.4% of jobs. 

Marker (DOT 209.587-034) is a stockers and order fillers (SOC 53-7065) (stockers) occupation. Labor places 209 alternate titles including 38 DOT codes in this group. The Occupational Requirements Survey describes stockers. Stockers stand (including walk) 80% of the day at the 10th percentile. Stockers lift/carry 25 pounds maximum in at the 10th percentile. Stockers engage in unskilled work (SVP 1 or 2) in 84.3% of jobs. 

To arrive at a reliable estimate of the number of light and unskilled work with standing/walking limited to four hours per day, a witness would have to assume the incidence of work that meets those criteria. The ORS and O*NET OnLine provides governmental data published according to OMB standards. The vocational witness has local (anecdotal) experience without a well-accepted methodology for extrapolating that experience to the national economy. 

In the case of these three occupations, markers are clearly eliminated. The intersection of unskilled and standing/walking four hours or less without crossing into sedentary work requires several assumptions. The expert must either assume that the exertional demands cut across the skill requirements OR must either have data or make assumptions about the requirements of skill and exertion correlation. Labor does not publish that data. 

Contact/interaction with coworkers and supervisors is cued up next. Teasing, none of the jobs make the cut. 

___________________________

Suggested Citation:

Lawrence Rohlfing, Missed Opportunities -- Standing and Walking in Shawver v. Kijakazi, California Social Security Attorney (October 17, 2023) https://californiasocialsecurityattorney.blogspot.com

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

Establishing the Vocational Expert's Methodology Requires Verification

The objective of cross-examination of the vocational expert must hone in one establishing that the vocational expert testimony is feeble or contradicted.  Biestek v. Berryhill instructs:

And of course, a different (maybe less qualified) expert failing to produce such data might offer testimony that is so feeble, or contradicted, that it would fail to clear the substantial-evidence bar.

The Ninth Circuit decision in Buck v. Berryhill establishes the same proposition:

"An ALJ may take administrative notice of any reliable job information, including information provided by a VE." Bayliss, 427 F.3d at 1218. "A VE's recognized expertise provides the necessary foundation for his or her testimony. Thus, no additional foundation is required." Id.

Buck erroneously reads the above language from Bayliss to require that the ALJ independently assess the reliability of VE testimony. However, as is clear from the language of Bayliss, at least in the absence of any contrary evidence, a VE's testimony is one type of job information that is regarded as inherently reliable; thus, there is no need for an ALJ to assess its reliability.

The representative must present contrary evidence and show that the vocational expert is not reliable.

In a hearing yesterday out of Evanston, Illinois, with the claimant appearing in Rockford by video conference and me on phone from sunny Santa Fe Springs, the vocational expert testified that the claimant's medical vocational profile permitted such a person to perform work as a mail clerk (DOT 209.687-026) as representing 10,400 jobs in the nation and office helper (DOT 239.567-010) representing 55,000 jobs in the nation.  After dancing around claiming to use the Occupational Employment Statistics and disavowing knowledge or use of the NAICS industry codes, the VE  distilled her methodology for estimating job numbers as relying on Job Browser Pro published by SkillTran.

Rebutting JBP is tough business.  Rebutting JBP requires reverse engineering and understanding the limits of the program as well as its use of equal distribution at the occupation-industry intersection.  But we don't have to go there.  We need to compare the VE testimony to the content of JBP.

JBP describes mail clerk as representing 2,130 jobs as of 2018.  That is a far cry from 10,400 jobs and marks substantial progress in showing conflict and feebleness of the VE testimony.

JBP describes office helper as representing 3,711 jobs as of 2018.  The drop from 55,000 jobs to 3,711 jobs is a change from clearly significant to insignificant.

Here is the probable explanation:  VEs do not go back and check their data.  Establishing conflict is as simple as owning a copy of JBP and running the numbers.  I take screen shots of the DOT estimate page to capture all of the statements of the aggregate number of jobs at the SOC-OES/NAICS intersection, the number of DOT codes, and the estimate applicable to the specific DOT code.  I then print the formal report that restates the DOT narrative (sans the industry designation), the number of DOT codes in the group, the incidence of full-time versus part-time, and then the SOC-OES/NAICS intersection without the statement of the number of DOT codes in that intersection.

In this case, the vocational expert has not offered testimony that is reliable.  In her own stated methodology, the number of jobs is wrong.  The testimony is feeble and contradicted.  The ALJ now has to deal with that conflict in the evidence.

Mail Clerk and Six Hours of Standing/Walking

Marian Marracco testified at a hearing yesterday.  Marracco has a bulk provider agreement to testify before the Social Security Administration as a vocational expert.  She was in New Jersey.  Now she works out of Desert Hot Springs.  She is prolific.

The ALJ directed Marracco to assume an ability to perform light work as defined in the regulations with other limitations.  Marracco identifies three occupations:  night cleaner; mail clerk; and garment sorter.  On cross-examination, the question turns to the medical expert's testimony: six hours of standing and walking in an eight-hour day.  Marracco says no change because the DOT defines light work as six hours of standing/walking in an eight-hour day.  Marracco further testifies that no light work ever requires more than six hours of standing/walking in a day; no light work requires standing/walking throughout the day; and Labor does not have data to the contrary.  We covered the DOT, regulation, and ruling in the preceding piece on this blog.  We turn our attention to mail sorter or mail clerk.

Marracco used DOT code 209.687-026.  Occu Collect confirms that Labor puts this occupation in maids and housekeeping cleaners (SOC 43-9051).

MAIL CLERK

209.687-026

DOT Narrative: 209.687-026 MAIL CLERK (clerical) alternate titles: mailroom clerk; mail sorter; postal clerk

Sorts incoming mail for distribution and dispatches outgoing mail: Opens envelopes by hand or machine. Stamps date and time of receipt on incoming mail. Sorts mail according to destination and type, such as returned letters, adjustments, bills, orders, and payments. Readdresses undeliverable mail bearing incomplete or incorrect address. Examines outgoing mail for appearance and seals envelopes by hand or machine. Stamps outgoing mail by hand or with postage meter. ay fold letters or circulars and insert in envelopes [FOLDING-MACHINE OPERATOR (clerical) 208.685-014]. May distribute and collect mail. May weigh mail to determine that postage is correct. May keep record of registered mail. May address mail, using addressing machine [ADDRESSING-MACHINE OPERATOR (clerical) 208.582-010]. May be designated according to type of mail handled as Mail Clerk, Bills (clerical).

GOE: 07.05.04 STRENGTH: L GED: R3 M1 L2 SVP: 2 DLU: 87

DOT-O*NET Crosswalk: https://www.onetonline.org/crosswalk/DOT?s=209.687-026&g=GO

SOC Code: 43-9051.00

There are 14 DOT codes in the group.

DOT Code	DOT Title	SVP	STRENGTH
208.462-010	MAILING-MACHINE OPERATOR	5	M
208.582-010	ADDRESSING-MACHINE OPERATOR	4	L
208.685-014	FOLDING-MACHINE OPERATOR	2	L
208.685-018	INSERTING-MACHINE OPERATOR	2	L
208.685-026	SEALING-AND-CANCELING-MACHINE OPERATOR	2	L
208.685-034	WING-MAILER-MACHINE OPERATOR	2	L
209.587-018	DIRECT-MAIL CLERK	4	L
209.687-026	MAIL CLERK	2	L
222.367-022	EXPRESS CLERK	4	M
222.387-038	PARCEL POST CLERK	3	H
222.567-018	SLOT-TAG INSERTER	2	L
222.587-030	MAILER	3	L
222.587-032	MAILER APPRENTICE	3	L
249.687-010	OFFICE COPY SELECTOR	3	L

Marracco testifies to 489,750 jobs as a mail sorter with a limit of six hours of standing/walking in a day.

43-9051.00 - Mail Clerks and Mail Machine Operators, Except Postal Service

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	95,500

Given the breadth of the occupational base, my confidence level of mail sorter represents more jobs than all 14 mail clerks and mail machine operators is low.  Moving right along to the O*NET OnLine:

43-9051.00 - Mail Clerks and Mail Machine Operators, Except Postal Service

Structural Job Characteristics	%	Response
Duration of Typical Work Week — Number of hours typically worked in one week.	42	More than 40 hours
	40	40 hours
	18	Less than 40 hours

Interesting that of the jobs are part-time and therefore not presumptively substantial gainful activity.  

Exertional	%	Response
Spend Time Sitting — How much does this job require sitting?	24	Continually or almost continually
	20	More than half the time
	16	About half the time
	39	Less than half the time
	1	Never
Exertional	%	Response
Spend Time Standing — How much does this job require standing?	9	Continually or almost continually
	70	More than half the time
	17	About half the time
	4	Less than half the time
	0	Never
Exertional	%	Response
Spend Time Walking and Running — How much does this job require walking and running?	1	Continually or almost continually
	48	More than half the time
	14	About half the time
	22	Less than half the time
	14	Never

Mail clerks run the gamut.  Almost 25% sit all day long; 9% stand all day long; and 1% walk/run all day long.  Now for the Occupational Requirements Survey:

43-9051.00 - Mail Clerks and Mail Machine Operators, Except Postal Service

Series ID: ORUP1000075700000125

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of standing/walking, mean

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of standing/walking, mean

Year	Period	Estimate
2017	Annual	5.87

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000125

Series ID: ORUP1000075700000127

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of standing/walking (25th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of standing/walking (25th percentile)

Year	Period	Estimate
2017	Annual	4

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000127

Series ID: ORUP1000075700000128

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of standing/walking (50th percentile - median)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of standing/walking (50th percentile - median)

Year	Period	Estimate
2017	Annual	6.3

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000128

Series ID: ORUP1000075700000129

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of standing/walking (75th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of standing/walking (75th percentile)

Year	Period	Estimate
2017	Annual	7.2

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000129

Series ID: ORUP1000075700000132

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of sitting, mean

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of sitting, mean

Year	Period	Estimate
2017	Annual	1.77

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000132

Series ID: ORUP1000075700000133

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of sitting (10th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of sitting (10th percentile)

Year	Period	Estimate
2017	Annual	-

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000133

Series ID: ORUP1000075700000137

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; hours of sitting (90th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: hours of sitting (90th percentile)

Year	Period	Estimate
2017	Annual	4.9

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000137

Series ID: ORUP1000075700000139

Not seasonally adjusted

Series Title: % of mail clerks and mail machine operators, except postal service; sitting vs. standing/walking at will is allowed

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: sitting vs. standing/walking at will is allowed

Year	Period	Estimate
2017	Annual	38

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000139

Series ID: ORUP1000075700000140

Not seasonally adjusted

Series Title: % of mail clerks and mail machine operators, except postal service; sitting vs. standing/walking at will is not allowed

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: sitting vs. standing/walking at will is not allowed

Year	Period	Estimate
2017	Annual	62

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000140

Series ID: ORUP1000075700000997

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day sitting is required, mean

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day sitting is required, mean

Year	Period	Estimate
2017	Annual	25.1

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000997

Series ID: ORUP1000075700000998

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day sitting is required (10th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day sitting is required (10th percentile)

Year	Period	Estimate
2017	Annual	-

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000998

Series ID: ORUP1000075700001002

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day sitting is required (90th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day sitting is required (90th percentile)

Year	Period	Estimate
2017	Annual	80

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700001002

Series ID: ORUP1000075700001003

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day standing/walking is required, mean

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day standing/walking is required, mean

Year	Period	Estimate
2017	Annual	74.9

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700001003

Series ID: ORUP1000075700001006

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day standing/walking is required (50th percentile - median)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day standing/walking is required (50th percentile - median)

Year	Period	Estimate
2017	Annual	90

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700001006

Series ID: ORUP1000075700001007

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day standing/walking is required (75th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day standing/walking is required (75th percentile)

Year	Period	Estimate
2017	Annual	98

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700001007

Series ID: ORUP1000075700001008

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; % of day standing/walking is required (90th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: % of day standing/walking is required (90th percentile)

Year	Period	Estimate
2017	Annual	100

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700001008

Given the disparity of sitting, standing, and walking suggested by the O*NET, the average is meaningless.  We need the percentiles.

The hours of standing/walking at the 25th percentile is standing/walking four hours per day.  The demands at the 50th percentile is 6.3 hours per day.  A person limited to six hours of standing/walking in a day can perform more than 25% but less than 50% of the jobs.  Mail Clerks have a sit-stand option in 38% of jobs making that a probable point for demarcation.  The percentages of the day, 90% at the 50th percentile and 74.9% of the day at the mean bolsters that deduction.  

Nor are a plurality much less a majority of these jobs in the light category.  Mail clerks engage in medium or heavy exertion in at least 57.1% of jobs.  Mail clerks engage in heavy exertion in at least 10% of jobs.  

Series ID: ORUP1000075700000241

Not seasonally adjusted

Series Title: % of mail clerks and mail machine operators, except postal service; lifting/carrying > 20 lbs & <= 50 lbs is required, seldom

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: lifting/carrying > 20 lbs & <= 50 lbs is required, seldom

Year	Period	Estimate
2017	Annual	57.1

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000241

Series ID: ORUP1000075700000237

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; pounds maximum weight lifted/carried (75th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: pounds maximum weight lifted/carried (75th percentile)

Year	Period	Estimate
2017	Annual	50

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000237

Series ID: ORUP1000075700000238

Not seasonally adjusted

Series Title: mail clerks and mail machine operators, except postal service; pounds maximum weight lifted/carried (90th percentile)

Requirement: Physical Demands

Occupation: mail clerks and mail machine operators, except postal service

Estimate: pounds maximum weight lifted/carried (90th percentile)

Year	Period	Estimate
2017	Annual	70

https://beta.bls.gov/dataViewer/view/timeseries/ORUP1000075700000238

Most of the jobs are unskilled.  

Series ID: ORUV1000075700000065

Not seasonally adjusted

Series Title: % of mail clerks and mail machine operators, except postal service; svp is beyond short demonstration, up to & including 1 month

Requirement: Education, Training, And Experience

Occupation: mail clerks and mail machine operators, except postal service

Estimate: svp is beyond short demonstration, up to & including 1 month

Year	Period	Estimate
2017	Annual	50.6

https://beta.bls.gov/dataViewer/view/timeseries/ORUV1000075700000065

We summarize the data:

# of Jobs	% Unskilled (ORS)	# Unskilled
95,500	50.60%	48,323
# Unskilled	% Light (ORS)	# Light
48,323	32.90%	15,898
# Light	% Full-Time (O*NET)	# Full-Time
15,898	82.00%	13,037
# Full-Time	% ≤ 6 hour stand/walk (ORS)	# ≤ 6 hour stand/walk
13,037	38.00%	4,954

Unlimited standing/walking in the context of light unskilled work yields 13,037 full-time jobs in the economy.   If limited to six hours of standing/walking in a full-time day, then the person can perform fewer than 5,000 jobs.  .