O*NET Rejection of SkillTRAN Suggestions for SOC 2010
In the fall of 2011, as the Occupational Employment Statistics (OES) program and other labor market programs began a change to using the newer 2010 Standard Occupational Classification (SOC) codes from the older SOC 2000 system. The 2010 standard government crosswalk from SOC 2000 to SOC 2010 was done using a simple "electronic translation process", which relied on simple cross-reference of one old code to approximately or essentially the new code. The presumption was that it would require too many personnel resources on the government side to bother with any deeper study of the crosswalk, particularly since it involved the Dictionary of Occupational Titles (DOT), which was regarded as too old and therefore "not useful".
Recognizing that our customer base depends on getting access to the most reliable labor government market information available at the DOT level, SkillTRAN took on the project as part of its ongoing support of customers to best navigate through these periodically changing government data systems. In the process of studying how the DOT fit with the newest SOC 2010 structure, SkillTRAN discovered a considerable number of DOT occupations that should be mapped to different SOC 2010 codes to best align the DOT with the newest SOC. So here is what happened when we submitted these 83 recommended changes to the O*NET system on October 7, 2011.
Our email to them on 10/7/2011 [From Krin Henderson, SkillTRAN Support]:
I have questions on the following DOT to O*NET crosses:
019.062-010, Geographic Information System Specialist is crossed to 15-1199.00, Computer Occupations, All Other and 15-1199.04. Wouldn’t 15-1199.05, Geographic Information System Technicians, be a better choice than 15-1199.00?
031.132-010, Supervisor, Network Control Operators is crossed to 15-1151.00, Computer User Support Specialists. Wouldn’t 15-1152.00, Computer Network Support Specialists, also be a correct cross?
031.262-014, Network Control Operator, is crossed to 15-1151.00, Computer User Support Specialists. Wouldn’t 15-1152.00, Computer Network Support Specialists, also be a correct cross?
033.167-010, Computer Systems Hardware Analyst, is crossed to 15-1199.00, Computer Occupations, All Other. Wouldn’t 15-1199.02, Computer Systems Engineers/Architects be more appropriate?
076.121-018, Exercise Physiologist, is crossed to 29-1129.00, Therapists, All Other. Shouldn’t that be changed to 29-1128.00, Exercise Physiologists?
076.127-010, Art Therapist, is crossed to 29-1125.00, Recreational Therapists. Shouldn’t that be changed to 29-1125.01, Art Therapists?
076.127-014, Music Therapist is crossed to 29-1125.00, Recreational Therapists. Shouldn’t that be changed to 29-1125.02, Music Therapists?
078.362-058, Special Procedures Technologist, Magnetic Resonance Imaging (MRI), is crossed to 29-2034.00, Radiologic Technologists. Shouldn’t that be crossed to 29-2035.00, Magnetic Resonance Imaging Technologists?
079.364-022, Phlebotomist, crosses to 31-9099.00, Healthcare Support Workers, All Other. Shouldn’t it cross to 31-9097.00, Phlebotomists?
160.207-010, Credit Counselor crosses to 13-2071.01, Loan Counselors. Shouldn’t that cross to 13-2071.00, Credit Counselors?
211.362-010, Cashier I crosses to 43-9199.00, Office and Administrative Support Workers, All Other. Would 43-3099.00, Financial Clerks, All Other, also be appropriate?
211.367-014, Automatic Teller Machine (ATM) Servicer, is crossed to 49-9091.00, Coin, Vending, and Amusement Machine Servicers and Repairers. Wouldn’t 49-2011.00, Computer, Automated Teller, and Office Machine Repairers, be a better match?
217.485-010, Currency Counter, crosses to 43-9199.00, Office and Administrative Support Workers, All Other. Would 43-3099.00, Financial Clerks, All Other, also be appropriate?
217.585-010, Coin-Counter-And-Wrapper, crosses to 43-9199.00, Office and Administrative Support Workers, All Other. Would 43-3099.00, Financial Clerks, All Other, also be appropriate?
293.157-010, Fund Raiser I, crosses to 11-2031.00, Public Relations and Fundraising Managers. Wouldn’t 13-1131.00, Fundraisers, also be appropriate?
299.357-018, Wedding Consultant, crosses to 41-9099.00, Sales and Related Workers, All Other. Would 13-1121.00, Meeting, Convention, and Event Planners, also be appropriate?
313.361-010, Baker, Second, crosses to 35-1011.00, Chefs and Head Cooks. Shouldn’t it also cross to 51-3011.00, Bakers.
The following DOTs cross to 35-1011.00, Chefs and Head Cooks but should cross to 51-3011.00, Bakers: 313.361-038, Pie Maker; 313.381-010, Baker; 313.381-018, Cook Apprentice, Pastry; 313.381-026, Cook, Pastry.
The following DOTs cross to 51-9199.00, Production Workers, All Other but should cross to 51-3099.00, Food Processing Workers, All Other:
520.487-014, Formula-Room Worker; 520.587-010, Pretzel Twister; 520.682-018, Extruder Operator; 520.682-026, Molding-Machine Operator; 520.684-010, Almond-Paste Molder; 520.684-014, Roller I; 520.686-038, Tamale-Machine Feeder; 520.687-018, Candy Molder, Hand; 520.687-034, Food Mixer; 520.687-054, Seasoning Mixer; 520.687-062, Spice Mixer; 521.682-038, Shrimp-Peeling-Machine Operator; 521.685-034, Breaking-Machine Operator; 521.687-050, Filter Changer; 521.687-070, Honeycomb Decapper; 522.684-010, Pickler; 522.685-086, Pickle Pumper; 523.380-010, Cocoa-Bean Roaster II; 524.685-038, Mexican-Food-Machine Tender; 524.687-022, Bakery Worker, Conveyor Line; 525.685-018, Dehairing-Machine Tender; 525.685-026, Poultry-Picking Machine Tender; 525.687-026, Dry Curer; 526.382-018, Converter Operator; 526.485-010, Wort Extractor; 526.682-010, Batter Scaler; 526.682-022, Doughnut-Machine Operator; 526.684-010, Doughnut Maker; 526.684-014, Lumpia Wrapper Maker; 526.685-034, Pan Greaser, Machine; 526.685-038, Pie Maker, Machine; 526.687-014, Starchmaker; 529.382-014, Chocolate-Production-Machine Operator; 529.382-026, Hydrogenation Operator; 529.385-010, Noodle Maker; 529.482-022, Syrup Maker; 529.485-022, Maturity Checker; 529.565-010, Sugar Controller; 529.665-018, Wet-And-Dry-Sugar-Bin Operator; 529.682-018, Depositing-Machine Operator; 529.684-010, Frozen Pie Maker; 529.685-030, Brine-Tank Tender; 529.685-046, Can-Conveyor Feeder; 529.685-070, Colorer, Citrus Fruit; 529.685-086, Decay-Control Operator; 529.685-122, Fish-Cake Maker; 529.685-130, Flavor Room Worker; 529.685-134, Fruit-Bar Maker; 529.685-142, Horseradish Maker; 529.685-202, Rendering-Equipment Tender; 529.685-214, Shellfish-Processing-Machine Tender; 529.685-218, Spice Fumigator; 529.687-034, Casing Tier; 529.687-122, Kiss Setter, Hand; 529.687-158, Melt-House Drag Operator; 920.380-010, Setter, Juice Packaging Machines; 920.680-010, Filling-Machine Set-Up Mechanic.
The following DOTs cross to 51-9199.00, Production Workers, All Other but 51-3099.00, Food Processing Workers, All Other may be more appropriate: 529.684-018, Sieve Maker; 764.687-090, Leak Hunter.
637.261-030, Solar-Energy-System Installer, crosses to 47-4099.02, Solar Thermal Installers and Technicians and 49-9021.01, Heating and Air Conditioning Mechanics and Installers. Is 47-2231.00, Solar Photovoltaic Installers, also appropriate?
973.381-018, Job Printer, crosses to 51-5112.00, Printing Press Operators and 51-5113.00, Print Binding and Finishing Workers. Shouldn’t that cross only to 51-5112.00, Printing Press Operators.
973.381-022, Job-Printer Apprentice, crosses to 51-5112.00, Printing Press Operators and 51-5113.00, Print Binding and Finishing Workers. Shouldn’t that cross only to 51-5112.00, Printing Press Operators.
See the attached summary spreadsheet. Thank you for your consideration.
Dear Krin Henderson:
Thank you for your inquiry and your patience. We have reviewed your request for changes to the DOT to O*NET-SOC crosswalk and consulted with our national office project staff. Because of the age of the DOT information, the large number of occupations involved, and the considerable staff and grantee resources required to maintain an analytical review of the crosswalk, we have decided to continue to maintain the crosswalk using our electronic translation process. Developers are free to develop their own crosswalks using other processes.
Should you have any further questions or comments, please feel free to contact us again.
National Center for O*NET Development
This response from O*NET supports the continued lack of government committment to having anything to do with the DOT. There is an absolute need for correct coding between the older DOT classification system and the newer government occupational coding systems. It is clear that the there was no committment by the O*NET in 2011, and so far no such committment in 2020. SkillTRAN will again offer its newer suggestions for linkage of the DOT to the SOC 2018, with the hope for a better outcome.
There are important legal consequences that are now beginning to occur as a direct result of this inaction by O*NET. The current O*NET onetonline.org has a Crosswalks feature between DOT and O*NET coding. In a recent 11th Circuit case, Goode vs. Colvin, the appeals court remanded the case to the Social Security Administrative Law Judge (ALJ) because the court consulted the onetonline.org cross-reference feature, relying on it as an assumed "authoritative reference" and without understanding the back story cited above. Instead, the inadequate, automated method chosen by O*NET and relied on by an Appeals Court judge essentially continued to use the older SOC 2000 coding to the much larger group of 51-9199 Production Workers, All Other, to which there are nearly 1,600 DOT occupations linked! Even when choosing an O*NET Custom Details report for the new group 51-3099 - Food Processing Workers, All Other - there are NO DOT occupations linked (as SkillTRAN clearly suggested more than 60 DOT codes in 2011) for this SOC 2010 and now SOC 2018 occupation, for which OES labor market data IS available.
A second, troubling aspect of the Circuit court's "initiative" in going to the flawed O*NET to DOT crosswalk for guidance is that the court now appears to be acting contrary to the Kerner v. Flemming, 283 F.2d 916, 921 (2nd Cir. 1960) decision, detailed here: https://www.ssa.gov/history/ssa/lbjoper5.html. The "Kerner criteria" essentially mandates the use of vocational experts in such cross reference activities between occupations and labor market information. While both the ALJ and the Appeals court are called upon to weigh the accuracy of the evidence presented in a specific case, it seems inappropriate for an appellate court to gather yet more evidence and rely on both this additional evidence of a vocational matter and on this flawed crosswalk, which is the domain of vocational experts.