Counter and Rental Clerks (SOC 41-2021) and the Simple Problem

Labor puts 11 DOT codes in the group of counter and rental clerks (SOC 41-2021).  The DOT classifies seven of those codes as requiring reasoning level 3; four with reasoning level 2.  In the simple versus complex debate, reasoning level 3 is typically enough to remove that level of work from the step 5 analysis.  The other four occupations, indeed all 11, require multiple significant worker functions in data, people, or things, except furniture-rental consultant.  The entire occupational group:

DOTCode	DOTTitle	STRENGTH	DATA	PEOPLE	THINGS	GEDR
249.366-010	COUNTER CLERK	L	3S	6S	6S	2
290.477-010	COUPON-REDEMPTION CLERK	L	4S	7S	7N	3
295.357-018	FURNITURE-RENTAL CONSULTANT	L	3N	5S	7N	3
295.367-014	BABY-STROLLER AND WHEELCHAIR RENTAL CLERK	L	3S	6S	7N	3
295.367-026	STORAGE-FACILITY RENTAL CLERK	L	3S	6S	7S	3
295.467-010	BICYCLE-RENTAL CLERK	L	4S	6S	7N	2
295.467-014	BOAT-RENTAL CLERK	L	4S	6S	7S	3
295.467-018	HOSPITAL-TELEVISION-RENTAL CLERK	L	4S	6S	7N	2
369.477-010	CURB ATTENDANT	M	4S	7S	7N	2
369.677-010	SELF-SERVICE-LAUNDRY-AND-DRY-CLEANING ATTENDANT	M	6N	7S	7S	3

All counter and rental clerks require dealing with people as a significant worker function.  That is the common thread running through group.  The O*NET OnLine describes counter and rental clerks as having constant contact with others in 91% of jobs and frequent contact with others in 9% of jobs.  Dealing with external customers is fairly important in 18% of jobs; important or very important in 1% of jobs, each; and extremely important in 80% of jobs.  Counter and rental clerks face conflict situations in 99% of jobs.  Counter and rental clerks work with a group or team in all jobs.  Counter and rental clerks work part-time in 40% of jobs.  

The O*NET OnLine describes counter and rental clerks as having 30 days or less of training time in less than 14% of jobs.  The Occupational Requirements Survey assigns SVP 2 to 68.7% of jobs.  The O*NET is based primarily on incumbent surveys.  The ORS is based on human resource surveys.  

The ORS reports that counter and rental clerks have their workload controlled by people in 99.5% of jobs and work at a varying pace in 89.8% of jobs.  Counter and rental clerks require basic people skills in 50.4% of jobs and more than basic people skills in 49.6% of jobs.  Counter and rental clerks interact with the public in 100% of jobs and telework is never available.  

The DOT data set confirms that counter and rental clerks are not simple work.  That confirmation is supported by the findings of the O*NET and ORS.  

Of the reasoning level 2 occupations within the group of counter and rental clerks, counter clerk is the most often cited.  Vocational experts cite counter clerk in response to the light exertion; simple work; occasional reaching, handling, and fingering; and intact for contact with the public.  Counter clerk requires significant worker functions in all three data-people-things categories:

Data: 3 - Significant
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.

People: 6 - Significant
Speaking Signaling: Talking with and signaling people to convey or exchange information Includes giving assignments and directions to helpers or assistants.

Things: 6 - Significant
Feeding Off Bearing: Inserting, throwing, dumping, or placing materials in or removing them from machines or equipment which are automatic or tended or operated by other workers.

 The DOT narrative is descriptive of varied duties, broken down:

249.366-010 COUNTER CLERK (photofinishing)
1. Receives film for processing,
2. loads film into equipment that automatically processes film for subsequent photo printing, and
3. collects payment from customers of photofinishing establishment:
4. Answers customer's questions regarding prices and services.
5. Receives film to be processed from customer and
6. enters identification data and printing instructions on service log and customer order envelope.
7. Loads film into equipment that automatically processes film, and routes processed film for subsequent photo printing.
8. Files processed film and photographic prints according to customer's name.
9. Locates processed film and prints for customer.
10. Totals charges, using cash register, collects payment, and returns prints and processed film to customer.
11. Sells photo supplies, such as film, batteries, and flashcubes.

Counter clerk has one temperament: dealing with people beyond receiving work instructions.  

Counter clerk carries two work field designations (use the DOT/SCO summary report from OccuCollect).  The first listed work field:

232 NUMERICAL RECORDING-RECORD KEEPING
Systematizing information on transactions and activities into accounts and numerical records through the application of arithmetic. bookkeeping, statistics, and other quantitative procedures (including paying and receiving money). Distinguish from Verbal Recording-Record Keeping (231), in which the primary activity is the keeping of records without computation.

The second work field:  

202 DEVELOPING-PRINTING
Reproducing records of data and designs by chemical means.

The presence of two work fields, the required temperament for dealing with people, the presence of significant worker functions in the three categories measured, and the list of 11 serial job duties suggest strongly that this is not simple, routine, and repetitive work that viewing reasoning alone would suggest.   

The integrated use of the entire DOT data set is often necessary to understand the nature and requirements of a specific occupation as it is typically performed in the national economy.  

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SUGGESTED CITATION:

Lawrence Rohlfing, Counter and Rental Clerks (SOC 41-2021) and the Simple Problem, California Social Security Attorney (June 30, 2020)

https://californiasocialsecurityattorney.blogspot.com/2020/06/counter-and-rental-clerks-soc-41-2021.html

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.