Rethinking Food Processing Workers, All Other - SOC 51-3099

As part of the 2010 revisions of the Standard Occupational Classification system, the Department of Labor moved some occupations out of production workers, all other (SOC 51-9199) and created food processing workers, all other (SOC 51-3099).  2010 SOC User Guide, vii, x, 4-5  (BLS, Feb. 2010); Crosswalk from the 2000 SOC to the 2010 SOC.  The SOC defines food processing workers, all other as:

All food processing workers not listed separately
Illustrative examples: Olive Pitter , Poultry Hanger , Yeast Maker

Job Browser Pro responded by moving the 61 DOT codes related to food products from production workers, all other to food processing workers, all other.  But Labor continues to count food-production-related jobs in its count of production workers, all other.  With three exceptions, all DOT codes moved over have the first two DOT digits of 52 OCCUPATIONS IN PROCESSING OF FOOD, TOBACCO, AND RELATED PRODUCTS.  The question is whether those 61 occupations belong in food processing workers, all other -- or just the ones exemplified by the three examples provided in the SOC:  olive pitter, poultry hanger, and yeast maker. 

The O*NET OnLine, Alternate Titles provides one additional example:  pasta press operator.  That same list of alternate titles continues to list the 61 DOT codes found on the JBP list as in production workers, all other.  And we know that Labor placed 1,590 DOT codes inside of production workers, all other as part of the 2000 SOC revision.  The Alternate Titles list does not count 1,590 job titles as within the group.  It counts 2,788 alternate titles. 

The economy has changed.  The proposition that food processing workers, all other contains four specific occupations as exemplars that were not contained in the 1991 DOT and that production workers, all other contains an additional 1,200 occupations not envisioned in the DOT provides the best and most reasonable explanation for the data provided in the employment projections for not only food production but the rest of the economy. 

Bakery Worker, Conveyor Line Presents an Enigma -- 414 Jobs

We start with the identification of bakery worker, conveyor line because the ALJ posed a limitation to occasional reaching, handling, or fingering to the vocational expert.  The number if jobs in this DOT code is about 414.  The first five lines of the Occu Collect DOT report:

DOT Code: 524.687-022
DOT Name: BAKERY WORKER, CONVEYOR LINE (bakery products)

SOC Code: 51-3099.00
O*NET URL: https://www.onetonline.org/link/summary/51-3099.00
DOT-O*NET Crosswalk: https://www.onetonline.org/crosswalk/DOT?s=524.687-022&g=GO

The first problem that jumps out is that Occu Collect reports the occupation belongs to SOC code 51-3099 but O*NET reports that the occupation belongs to 51-9199.  In publishing the 2010 SOC system, BLS made changes to the SOC structure.  The crosswalk between the 2000 and 2010 SOC provides the trail for the creation of 51-3099.  Here are the lines that we care about:

2000 SOC code	2000 SOC title	2010 SOC code	2010 SOC title
51-9199	Production Workers, All Other*	51-9199	Production Workers, All Other
51-9199	Production Workers, All Other*	51-3099	Food Processing Workers, All Other

Job Browser Pro moved 61 DOT codes to 51-3099, reducing the glut in 51-9199.  BLS did not.  BLS continues to report jobs in the food subsector as performed by production workers, all other as well as jobs in the food industry subsector as performed by food processing workers, all other.  The occupation-industry matrix, sorted by industry, reports the number of estimated jobs with sectors, subsectors, industry group and a few industries.  The EP for employment in the bakeries and tortilla manufacturing subsetor:

Employment by industry, occupation, and percent distribution, 2016 and projected 2026
311800 Bakeries and tortilla manufacturing
(Employment in thousands) Occupations with fewer than 50 jobs, confidential data, or poor quality data are not displayed
	Occupation		2016
Sort Order	Code	Title	Employment	Percent of industry
1	00-0000	Total, all occupations	304.0	100.0
165	51-3099	Food processing workers, all other	1.5	0.5
188	51-9199	Production workers, all other	1.4	0.5

Bakeries and tortilla manufacturing is the right industry group.  From the NAICS manual, the four digit industry groups within the food manufacturing subsector:

2012 NAICS code	Meaning of 2012 NAICS code
311	Food manufacturing
3111	Animal food manufacturing
3112	Grain and oilseed milling
3113	Sugar and confectionery product manufacturing
3114	Fruit and vegetable preserving and specialty food manufacturing
3115	Dairy product manufacturing
3116	Animal slaughtering and processing
3117	Seafood product preparation and packaging
3118	Bakeries and tortilla manufacturing
3119	Other food manufacturing

Putting together the split of production workers, the continued report of jobs in both occupational groups, any observation that moving the 61 DOT codes, including bakery worker, conveyor line, leaves no DOT codes to perform the production workers jobs, the only reasonable treatment is to continue to treat the 61 DOT codes as existing in 51-9199 and co-existing in 51-3099.  With that conclusion, we can address the 2,900 job estimate in the two SOC codes.  There are seven DOT codes that are classified by the O*NET as 51-3099 and by JBP as 51-9199 that the DOT industry list classifies as in the bakery products industry:

DOT CODE	DOT NAME	SVP	STRENGTH
520.587-010	PRETZEL TWISTER	2	L
524.687-022	BAKERY WORKER, CONVEYOR LINE	2	L
526.682-010	BATTER SCALER	4	L
526.682-022	DOUGHNUT-MACHINE OPERATOR	4	L
526.684-010	DOUGHNUT MAKER	4	M
526.685-034	PAN GREASER, MACHINE	2	L
526.685-038	PIE MAKER, MACHINE	4	M

At this level of analysis, JBP resorts to the equal-distribution method.  Dividing 2,900 by 7 yields 414 jobs per DOT code.  

The 2,900 job estimate representing 1% of industry employment fits with the report of 2016 jobs by County Business Patterns.  A more refined analysis of the industries and the specific industries contained in the subsector could exclude cookie, cracker, and pasta manufacturing as well as tortilla manufacturing but most of the jobs in the subsector exist n the bread and bakery product manufacturing industry.  

2012 NAICS	NAICS Description	Employment
3118	Bakeries and tortilla manufacturing	295,047
31181	Bread and bakery product manufacturing	215,116
311811	Retail bakeries	64,700
311812	Commercial bakeries	127,152
311813	Frozen cakes, pies, and other pastries manufacturing	23,264
31182	Cookie, cracker, and pasta manufacturing	60,558
311821	Cookie and cracker manufacturing	37,602
311824	Dry pasta, dough, and flour mixes manufacturing from purchased flour	22,956
31183	Tortilla manufacturing	19,373
311830	Tortilla manufacturing	19,373

Paid employees for pay period including March 12 (number)

Drilling down that far is not necessary.  It is enough to observe that estimating a job number higher than 414 lacks reliability.  The number is probably lower.  

Unskilled DOT Codes with Two SOC Groups

With about 3,000 unskilled DOT codes collapsing into 173 SOC groups that contain those unskilled DOT codes, the criticism of the O*NET and the SOC structure has centered around the issue of data aggregation: clumping the different DOT codes together.  I found eight DOT codes for which the opposite is true:  the DOT treats as a single occupation that Labor placed into two different SOC groups. 

These occupations require greater care when assessing the number of potential jobs on the occupational employment matrix.  That task would require use of two employment projection matrixes.  The occupations raising these concerns are:

DOT	DOT TITLE	SOC	SOC TITLE
317.684-010	COFFEE MAKER	35-2021	Food Preparation Workers
		35-3022	Counter Attendants, Cafeteria, Food Concession, and Coffee Shop
https://www.onetonline.org/crosswalk/DOT?s=317.684-010&g=Go
379.367-010	SURVEILLANCE-SYSTEM MONITOR	33-9031	Gaming Surveillance Officers and Gaming Investigators
		33-9099	Protective Service Workers, All Other
https://www.onetonline.org/crosswalk/DOT?s=379.367-010&g=Go
411.364-010	BLOOD TESTER, FOWL	19-4011	Agricultural and Food Science Technicians
		19-4021	Biological Technicians
https://www.onetonline.org/crosswalk/DOT?s=411.364-010&g=Go
421.687-010	FARMWORKER, GENERAL II	45-2092	Farmworkers and Laborers, Crop, Nursery, and Greenhouse
		45-2093	Farmworkers, Farm, Ranch, and Aquacultural Animals
https://www.onetonline.org/crosswalk/DOT?s=421.687-010&g=Go
530.665-010	BEATER-ENGINEER HELPER	51-9021	Crushing, Grinding, and Polishing Machine Setters, Operators, and Tenders
		51-9023	Mixing and Blending Machine Setters, Operators, and Tenders
https://www.onetonline.org/crosswalk/DOT?s=530.665-010&g=Go
530.685-014	PULPER	51-9021	Crushing, Grinding, and Polishing Machine Setters, Operators, and Tenders
		51-9023	Mixing and Blending Machine Setters, Operators, and Tenders
https://www.onetonline.org/crosswalk/DOT?s=530.685-014&g=Go
555.685-066	WHEEL-MILL OPERATOR	51-9021	Crushing, Grinding, and Polishing Machine Setters, Operators, and Tenders
		51-9023	Mixing and Blending Machine Setters, Operators, and Tenders
https://www.onetonline.org/crosswalk/DOT?s=555.685-066&g=Go
806.684-010	ASSEMBLER, MOTOR VEHICLE	51-2092	Team Assemblers
		51-9199	Production Workers, All Other
https://www.onetonline.org/crosswalk/DOT?s=806.684-010&g=Go

Surveillance=system monitor exemplifies the dilemma.  Job Browser Pro does not list the existence of this kind of work in the Gaming Surveillance Officers and Gaming Investigators (SOC 33-9031) occupational group.  That leads to a potential undercounting.  Occu Collect reports:

 33-9031 Gaming surveillance officers and gaming investigators

Typical Education Needed	High school diploma or equivalent
Work Experience in a Related Occupation	Less than 5 years
Typical On-The-Job Training Needed to Attain Competency	Moderate-term on-the-job training
2016 Employment	10,700

Occupations within this group require significant experience and are at least semi-skilled if not skilled (counting the experience and training time together).  The only other occupation in the group is Gambling Monitor (DOT 343.367-014).  The plurality of those jobs do exist in government service, the OOH states:

Gaming surveillance officers and gaming investigators held about 10,700 jobs in 2016. The largest employers of gaming surveillance officers and gaming investigators were as follows:

Local government, excluding education and hospitals	47%
Gambling industries (except casino hotels)	25
Casino hotels	19
State government, excluding education and hospitals	4
Spectator sports	2

When wandering outside of the DOT-designated industry, we must remain cognizant that while the industry designation is an integral and inseparable part of the occupational title, the DOT states:

In compiling information for the DOT, analysts were not able to study each occupation in all industries where it occurs. The industry designation, therefore, shows in what industries the occupation was studied but does not mean that it may not be found in others. Therefore, industry designations are to be regarded as indicative of industrial location, but not necessarily restrictive.

That last sentence is the out that vocational experts can use to evade restricting the occupations to the industry designated.