The Dictionary of Occupational Titles, Structure, History, Reliability, and Validity

• Author: David Traver
• Pages: 403-451

14-1

Chapter Fourteen

The Dictionary of Occupational Titles,

Structure, History, Reliability, and

Validity

§1400 Introduction

§1400.1 Where Do I Find the DOT?

§1401 The DOT Is Not All Inclusive

§1402 Parts of the DOT Occupational Definition

§1402.1 Example DOT Definition

§1402.2 The Occupational Code Number

§1402.3 The Occupational Title

§1402.3.1 Master Titles

§1402.3.2 Term Titles

§1402.3.3 Industry Designation

§1402.3.4 Alternate Titles

§1402.3.5 The Body of the Definition

§1402.3.6 Undefined Related Titles

§1402.3.7 Definition Trailer

§1402.3.8 The GOE (Guide for Occupational Exploration) Code

§1402.3.9 The Strength Rating

§1402.3.10 Vocational Experts Versus the DOT Regarding Exertional Classifications

§1402.3.11 The GED Level

§1402.3.12 The SVP Level

§1402.3.13 Sources of Specific Vocational Preparation

§1402.3.14 The Date of Last Update

§1403 Understanding the Dictionary of Occupational Titles — History and Reliability

§1403.1 Summary: Sources of Error in the DOT

§1403.1.1 DOT and OIDAP: Recommendations for the Future

§1403.1.2 SSA’s Disability Adjudication Framework Rests Upon the Research, Theories and

Social Security Disability Advocate’s Handbook 14-402

Publication of the DOT

§1403.1.3 The DOT and “Companion Volumes” Are Used by the SSA in Past-Work Adjudica-

tion

§1403.1.4 The Medical-Vocational Guidelines (Grids) Are Based Upon the Data of the DOT

§1403.1.5 The Grid Tables Were Derived From the DOT, DOT Data, and the DOT’s Underly-

ing Assumptions

§1403.1.6 SSA’s Physical Exertion Requirement Definitions Come From the DOT

§1403.1.7 SSA’s Definitions of Non-Exertional Work Come From the DOT

§1403.1.8 SAA’s Definition and the Alleged Quantity of “Unskilled” Jobs Is Based Upon the

DOT

§1403.2 The Dictionary of Occupational Titles — An Ancient and Abandoned Taxonomy

§1403.2.1 The Revised Fourth Edition of the DOT

§1403.2.2 Who Compiled the DOT?

§1403.3 The Unreliability of the Dictionary of Occupational Titles

§1403.3.1 The DOT Is No Longer Updated or Produced

§1403.3.2 The DOT Is a Dead Letter Because it Is Obsolete

§1403.3.3 The Production of the DOT Was Seriously Under-Documented and Under-Published

§1403.3.4 How the Methodology Used for the Creation of the DOT Was Flawed

§1403.3.5 How Were the Industries Selected for Analysis?

§1403.3.6 The DOT Never Differentiated Between Full-Time and Part-Time Work

§1403.3.7 The Analysis of “Procedures and Processes” Was Haphazard

§1403.3.8 Who Determined What Was a “Job” or “Occupation”?

§1403.3.9 Shortcuts Were Taken in Writing the Job Descriptions and Assigning the DOT Codes

§1403.3.10 Specific Vocational Preparation (SVP) Was Not Accurately Assessed

§1403.3.11 Aptitude Ratings Were Most Ambiguous

§1403.3.12 Environmental Conditions and Physical Demands Were Not Measured

§1403.3.13 Some Jobs in the DOT Were Never Reanalyzed after 1965

§1403.3.14 Definition Writing — the Funneling-Down Problem

§1403.3.15 Sampling Procedure Limitations

§1403.3.16 Source Data Limitations

§1403.4 Ratings of Worker Functions and Worker Traits — Validity and Reliability

§1403.4.1 Ratings of Worker Functions and Worker Traits — Validity

§1403.4.2 Ratings of Worker Functions and Worker Traits — Validity and Reliability

§1403.4.3 Ratings of Worker Functions and Worker Traits — the Factor Structure

§1403.5 Sex Bias in the Rating of Occupations

§1404 The Occupational Information Development Advisory Panel (OIDAP)

§1404.1 Useful Reports From the OIDAP

§1404.2 What Next? Occupational Information System Project

14-403 The Dictionary of Occupational Titles, Structure, History, Reliability, and Validity §1401

§1400 Introduction

We asked the parties at oral argument

what makes a vocational expert an “expert”

(and where the information in the Dictionary

[of Occupational Titles] came from). They

did not know. Maybe both the authors of the

Dictionary and the vocational expert in this

case are talking out of a hat.

Donahue v. Barnhart, 279 F.3d 441, 446 (7th Cir.

2002).

This chapter discusses the structure and con-

tent of the Dictionary of Occupational Titles

(DOT), the history of the DOT, and its lack of reli-

ability and validity.

Understanding the DOT is essential to disability

practice at the Social Security Administration be-

cause use and reliance upon the DOT and its progeny

are firmly embedded in the SSA’s Regulations, Rul-

ings, HALLEX, and POMS. As fate would have it,

the DOT has never been reliable when it was pushed

to its limits by the Social Security Administration’s

adjudication processes. It was a job placement tool

that, at its margins, has masqueraded as reliable vo-

cational evidence.

SSA’s reliance upon the underlying assump-

tions and the data of the DOT and its “companion

volumes” is the keystone in the arch which holds

up the Medical-Vocational Guidelines and the entire

vocational framework at the Social Security Admin-

istration. As a result, the DOT and its underlying

assumptions are fundamental to the determination of

the outcome in millions of disability claims annually.

The Dictionary of Occupational Titles, com-

monly known as the DOT (Pronounced Dee-Oh-Tee,

not “dot.”) was the creation of the U.S. Employment

Service, which used it to match job seekers with

jobs. By 1939, it became clear that a standardized

volume was needed. As computers became more so-

phisticated, the DOT approach was dropped by the

Job Service, the taxonomy of job classification that

had evolved since the 1930s was abandoned after

the Revised Fourth Edition of the DOT, and the Job

Service moved on to a bigger and better thing. That

bigger and better thing is O*NET, which has not

been used by the Social Security Administration.

The DOT is obviously ancient, since much of the

data in the final edition were collected while Lyndon

Johnson was President, at the beginning of the Viet-

nam War. Was it reliable when it was published? How

reliable were the last updates and the final edition? Has

the DOT ever been reliable for the purposes to which

SSA has put it?

§1400.1 Where Do I Find the DOT?

Where page references are given to the DOT,

the reference is to the Revised Fourth Edition of the

Dictionary of Occupational Titles, Volumes I and II,

U.S. Department of Labor Employment and Training

Administration, 1991. Available for purchase at ama-

zon.com. Available online (without page numbers) at

www.oalj.dol.gov/libdot.htm.

The Selected Characteristics of Occupations

Defined in the Revised Dictionary of Occupational

Titles, U. S. Department of Labor Employment and

Training Administration, 1993 (the “SCO”), is the

“companion volume” solicited from the Depart-

ment of Labor by the Social Security Administra-

tion for adjudication purposes. But because it is

otherwise obsolete and as dead as the DOT, it has

been out of print for years.

Links to copies of the DOT and SCO in PDF

format may be found at http://ssaconnect.com/index.

php/basic-vocational-books.

§1401 The DOT Is Not All Inclusive

There are functional demands of occupations

which no vocational resource addresses, including

the DOT. For example, no vocational resource ad-

dresses whether a specific occupation is generally

performed using the “sit/stand option.” None ad-

dress whether an occupation requires bilateral use of

the upper extremities; and none address the mental

demands required to perform specific occupations.

Inasmuch as the Social Security Administration in-

terprets the Act and regulations as requiring claim-

ants to show, at step four, that they cannot perform

past relevant work either “as performed” or “as

generally performed,” this circumstance creates an

obligation on the part of the agency to come forward

with evidence to show how an occupation is “gener-

ally performed.” SSR 82-61 implicitly recognizes

this obligation when it notes as follows: