WHAT ARE DOT CODES?
"At my hearing, the vocational expert talked about DOT codes. What are they and how are they used by Social Security?"
DOT sands for the "Dictionary of Occupational Titles," a publication that first appeared during the Great Depression. It was a government publication intended to describe the types of jobs that were available by occupation. The DOT assigns a 9-digit code to each job and provides a job description, a specific vocational preparation number (SVP) and exertion level to each job. This was originally intended to aid unemployed workers in the Great Depression to find employment. The DOT has not been updated since 1993 and is considered obsolete by everyone except the Social Security Administration. The DOT is still used by Social Security as the definitive guide to jobs that are performed in the United States.
Social Security uses information from the DOT in several ways:
1) The DOT is used to classify a claimant's past relevant work. Each full-time job that the claimant has performed within the 15 year period prior to filing for disability is classified with a DOT number, an exertion level (ranging from sedentary to very heavy) and the amount of vocational preparation required to master the job. It also states the skill level of the job: skilled, semi-skilled or unskilled.
2) A vocational expert will use the jobs in the DOT to answer hypothetical questions from the administrative law judge, explaining what type of jobs an individual meeting a certain profile could perform and how many of those jobs are being performed in the national economy. For example: "This individual could perform the work of a product marker, DOT number 920.687-126. This is light exertion work, unskilled with an SVP of 2. There are over 500,000 of these jobs in the US economy."
For most claimants, the ability to perform ANY work that exists in significant numbers in the US economy will result in a denial of benefits. Therefore, if the judge considers the claimant's age, education, past work experience and residual function capacity and finds that the claimant can perform one of the jobs described by the vocational expert, the claim will be denied.
Here are my chief concerns with the DOT as a whole (and I have many concerns).
A. It is outdated, obsolete and clearly not a reliable guide to employment in the 21st Century. The DOT still lists jobs such as Wagon Driver, Bucket Chucker and Animal Impersonator. It does not mention any job from the computer age. It references microfilm processors but says nothing about computers which have virtually eliminated microfilm technology over a quarter of a century ago. The DOT was last updated 34 years ago and should be retired and replaced.
B. The US Department of Labor has repeatedly stated that there is no way to accurately estimate how many jobs exist in the US economy according to a specific DOT code.
C. Vocational experts, when questioned, admit that the number of jobs they provide for the judge are NOT based on one particular DOT code but are based on a much broader grouping of jobs (within SOC or census codes) which may contain hundreds of different DOT codes.
D. Most vocational experts do not have the training, education or expertise to estimate how many jobs exist in the US economy based on DOT codes. They rely on unknown and little understood statistics from proprietary companies who provide these "estimates" without any real accountability for their accuracy--and without any rational explanation for how the numbers are arrived at.
E. Social Security places far too much confidence in the DOT when it tries to prove that there are significant numbers of jobs in the US economy at Step 5 in the decision making process. Claimants can be denied benefits based on jobs that haven't existed in significant numbers for the last quarter of a century!