SkillTRAN's Comprehensive List of Sedentary Unskilled Simple Occupations -- And the Number of Jobs

SkillTRAN publishes a list of 127 sedentary unskilled occupations that qualify as simple, repetitive. or routine work (reasoning levels 1 and 2). We have discussed this issue in the past. SkillTRAN estimates these job numbers as of May 3, 2021. That is not the publication date for the article, is the release date of the OES (now OEWS) data on May 3, 2021, for data as of May 2020. 

SkillTRAN estimates that there are 58,000 full-time jobs that are sedentary, unskilled, and SRT using the SkillTRAN methodology for estimating job numbers. Sounds significant, but do all those jobs count according to SkillTRAN?

The most numerous occupation accounting for almost 34,000 jobs is escort-vehicle driver (DOT 919.663-022). SkillTRAN does not describe the DOT as accurate or reliable for escort-vehicle driver as sedentary. 

1. Escort-vehicle driver requires eye-hand coordination level 3 (the average range, inconsistent with unskilled work). 
2. Escort-vehicle driver requires constant exertion of negligible force (inconsistent with frequent exertion of negligible force for sedentary work but consistent with light work). 
3. Escort-vehicle driver could require the rapid application of greater than 20 pounds of force on the brake pedal (inconsistent with sedentary and light work but consistent with medium work). 

If Job Browser Pro or any other SkillTRAN product describes the existence of work, this article addressing escort-vehicle driver in an inconsistent statement. If the vocational witness identifies escort-vehicle driver without using a SkillTRAN product, then careful examination needs to focus on the eye-hand coordination, the constant exertion of negligible force, and the occasional (from seldom to one-third of the day) application of greater than 20 pounds of force. Some vocational witnesses will voluntarily withdraw escort-vehicle driver, and they should. 

The second and third most numerous occupations on the list are addresser (DOT 209.587-010) and tube operator (DOT 239.687-014). These represent less than 2,400 and 2,300 jobs respectively. In a 2015 presentation at an ALJ Training, SkillTRAN laid out the problem with addresser -- it is hard to find. OIDAP calls that obsolete. On the OIDAP list of obsolete occupations, we find tube operator. The second and third most numerous occupations that fit the unskilled sedentary SRT hypothetical are obsolete. The ALJ training also labeled escort-vehicle driver as "not really sedentary." 

**SkillTRAN lists document preparer, election clerk, call-out operator, and surveillance-system monitor on its list of examples of sedentary unskilled occupations. These four occupations require reasoning level 3. SkillTRAN criticizes all six targets of vocational identification as the result of "rehabbers/occupational health." **

The first three occupations should not count. The count stands at fewer than 20,000 jobs. 

The next most numerous occupation is nut sorter (DOT 521.687-086). The 2021 estimate of job numbers comes in at a paltry 1,900 jobs. You may remember that the vocational expert in Biestek v. Berryhill, 139 S.Ct. 1148 (2019) testified under oath that her undisclosed personal labor market survey found 120,000 sorter jobs in the nation. The vocational witness in Biestek was at best unreasonably wrong. No one believes that nut sorter represents 120,000 jobs. This juxtaposition illustrates the depth of the vocational witness problem in Social Security disability cases. 

Ten DOT codes report no jobs. Ten DOT codes report 10 or fewer jobs. Thirty-four DOT codes report between 12 and 20 jobs. Twelve DOT codes report between 21 and 30 jobs.  Twenty-five DOT codes report between 31 and 100 jobs. Twenty-eight DOT codes report between 101 and 1,000 jobs. Six DOT codes, including nut sorter, report more than 1,000 but fewer than 2,000 jobs. 

Every claimant limited to sedentary SRT work at step 5 of the sequential evaluation process should win. There are not a significant number of jobs in the national economy that reliably exist. Adding in the most insignificant additional limitation (occasional contact with others, limiting sitting to six hours) solidifies the conclusion. Don't let vocational witnesses spread the Biestek lie. 

But you had me at sedentary SRT. 

___________________________

Suggested Citation:

Lawrence Rohlfing, SkillTRAN's Comprehensive List of Sedentary Unskilled Simple Occupations -- And the Number of Jobs, California Social Security Attorney (November 14, 2023)

https://californiasocialsecurityattorney.blogspot.com

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

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.