The American Association for Disability Policy Reform    

—   rehabilitation first   —

Social Security's Occupational Database

The Dictionary of Occupational Titles


SUMMARY:

The Social Security Administration's occupational database, a critical pillar of the disability program, is incomplete, unreliable and badly out of date.   Meanwhile, the Social Security Administration assures us that the Dictionary is a valid resource, having taken "administrative notice" of its "reliable job information."   (We take "administrative notice" that the moon is made of swiss cheese.)   The Department of Labor considers the Dictionary to be obsolete.   While the Social Security Administration misleads us about its accuracy, no replacement is in sight.


DETAILS:

If the Social Security Administration is to determine whether or not a person is able to work, it must know what jobs are available and in what numbers.   In addition, it needs to know what the demands of those jobs are (such as for sitting, standing, walking, using computers etc.) in order to determine what jobs a disability claimant is able to do despite his or her impairments.

Many years ago, the Social Security Administration adopted the Department of Labor's Dictionary of Occupational Titles as its source of job information.   Over the years, the Dictionary of Occupational Titles has become one of the great pillars of the disability program, with the Social Security Administration assuring us of its accuracy.

The Dictionary of Occupational Titles contains descriptions for 12,569 jobs, including such common jobs as farmer and sales clerk, along with wormpicker ("walks about grassy areas such as gardens, parks, and golf courses, after dark and picks up earthworms") and sealer ("kills male seals that are within specified age and size limits, by striking them on the head with a club .. severs skin around head and flippers of dead seal .. pulls off seal's skin from head to tail").   Somehow, some not uncommon jobs such as prostitute, pimp, panhandler, pickpocket, congressman, burglar, beggar and stripper were left out.

In 1980, the National Research Council published a study of the Dictionary of Occupational Titles. Their report indicated that:

A critical failure of the Dictionary of Occupational Titles is its lack of information about the ever-changing number of jobs of each type in the national economy.   No suitable substitute has been found.

Not only was the Dictionary of Occupational Titles unreliable when it was published, it is now very much out of date. 88% of the job descriptions have not been revised in almost 40 years and none of the job descriptions have been revised in 25 years.   Meanwhile, major changes have occurred in the workplace, particularly with the enormous growth in the use of computers.

A letter from Dixie Sommers, an Assistant Commissioner in the Department of Labor, dated November 19, 2007, states that "The DOT is no longer in use by the Bureau of Labor Statistics and we do regard it as obsolete since much of the information contained in the most recent version is based on research conducted at least two decades ago."

Despite all these problems, the Social Security Administration leads us to believed that the Dictionary is a valid resource, having taken "administrative notice" of its "reliable job information." [20 C.F.R. 404.1566(d) and 20 C.F.R. 416.966(d)]   We take "administrative notice" that the moon is made of swiss cheese.

The Social Security Administration has a committee working on a replacement for the Dictionary of Occupational Titles.   The committee has developed an elaborate plan but no usable replacement is in sight.   Because hundreds of factors will then need to be evaluated to fully describe each of more than 12,000 jobs, and because many jobs change continually to suit the needs of employers, the success of this effort is very unlikely.


BACK



Last updated on 2/26/16.