I have a few questions for you to think about. "If the truck breaks down, don’t they have to open the hood of the truck?”. If there is a problem with the cargo, don’t they have to get on the flatbed and inspect, or to secure the load? Are these sedentary or light duty activities? I do not think so.
Pedro M. Román
Original Message:
Sent: 2/13/2024 9:11:00 PM
From: Michelle Aliff
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
Jeff,
Approximately 90% of the labor market is covered by ORS, it's not half. The fact that after all these years those other SOCs have no reported data tells us a lot. Those SOCs are rare/niche occupations and likely many are obsolete. The workgroup will get started this year on the review of SOCs and potential changes to be made.
And no, I absolutely do not believe they should focus on those SOCs with no reported data at this point. The focus needs to be on the most common SOCs, where unskilled jobs are found, because that is where the DOT is the weakest, I.e it no longer adequately captures the unskilled occupational base, primarily sedentary (DOT is primarily manufacturing at sedentary/unskilled) and light/unskilled has many changes from DOT times. While you and others may desire information on those other SOCs, it's not a priority right now and nor should it be.
I do agree there is some slow walking going on and it will lead to complete chaos if they don't act soon. I do agree with SSA that the policy changes that are necessary are daunting. There are certainly interim steps that can be taken that they have thus far refused to do. They designed their adjudication system on a data set, the DOT. The district court decisions are piling up and it won't be long until some district court says the DOT is not valid and reliable. The rhetoric is increasing about the "defunct" DOT. The fun is just getting started from my point of view.
Michelle Aliff, Ph.D, CRC, CVE
Sent from my iPhone
Original Message:
Sent: 2/13/2024 8:54:00 PM
From: Jeffrey Truthan
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
I disagree. Go back to the source document - The Revised Handbook for Analyzing Jobs - Chapter 12, page 12-3. Medium Work was defined as "Exerting 20 to 50 pounds of force occasionally, or 10-25 pounds of force frequently, or greater than negligible up to 10 pounds of force constantly to move objects. Physical demand requirements are in excess of Light."
There was not a gap to fill. My understanding is that BLS suggested this change to SSA since Negligible to 10 lbs, 11 lbs. to 25 lbs, 26 lbs. to 50 lbs., 51 lbs. to 100 lbs, and >100 lbs. seemed like more consistent/even ranges to capture and report.
Omission of the use of hand or foot controls by SSA in its definition is one thing, but the RHAJ clearly defined for the job analysts what they were to observe, collect, and report in building the DOT. This included the very clear statement that Light work could include "sitting most of the time but entails pushing or pulling of arm or leg controls." As a result, the assignment of every single non-managerial occupation with Work Field 013 Transporting is rated at Light or higher, with exception of their misclassification of Escort Vehicle Drivers as the only Sedentary occupation in this code group involving actual driving. See my thoughts on this misclassification here: https://skilltran.com/index.php/support-area/documentation/266-escort-vehicle-driver
What chafes me the most about this whole, barely half complete ORS project is not only the dollars spent and time elapsed but also the complete lack of transparency on the part of SSA. SSA holds itself out as "building a new Occupational Information System (OIS)". Just where did they gain their insights/experience into how to build an OIS, yet alone collect the data essentially without the continuing guidance from the stellar panel of blue ribbon professionals assembled by Dr. Barros-Bailey in the Occupational Information Development Advisory Panel (OIDAP). The OIDAP panel included phenomenal contributions by its professional representation across a wide range of Industrial-Organizational and Educational Psychologists, Rehabilitation Medicine, Occupational Medicine, Private Rehabilitation Practitioners, Psychologists, Long Term Disability insurance, Disability Compensation, Physical Therapy, Research Psychology/Psychometry, Performance and HR Management, Psychiatry, and even an ALJ! Yet this committee was disbanded (for strictly partisan political reasons) before it completed its critical work on what we now know as the ORS mental-cognitive factors.
SSA engaged the economists from the National Compensation Survey group to see if they could collect and report on the needed factors. Of course they agreed to do the work, proceeded down a sampling path I twice cautioned against in 2014 (see my history of warning comments then and more recently.) After 3 years of First Wave data collection, no mental cognitive data could be reported due to poor wording of their questions in a way that respondents could not reply. So now, five years later, we do have considerably better worded mental cognitive factors that finally have reportable data, but still for barely just half of the SOC groups. And there are no definitions for the tasks performed within each of the reported SOC groups. Why is there no reporting of something as basic as the task statements collected? How about disclosure of the number of respondents used to report these ratings and the industries (3-4 digit NAICS level) covered? This is statistical reporting at its most basic levels. Missing so far.
It continues to concern me that very little independent inspiration, insight and particularly outside oversight has been sought or brought to SSA in this very lengthy and expensive data collection. It feels like SSA is intentionally slow walking this whole process to avoid having to completely abandon their existing cocoon of policy, rules, precedents and regulation. Much is also likely due to the unfortunate habit of not having (until fairly recently) a permanent commissioner.
Nonetheless, fresh data builds new insights into what it takes to perform 477 SOC Groups - about 56% of way through the 848 civilian SOC occupations.
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Jeff Truthan, MS-Rehabilitation Counseling, CVE
President - SkillTRAN LLC - https://skilltran.com
Spokane Valley, WA 99206
(800) 827-2182 (Voice & Fax)
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Original Message:
Sent: 02-13-2024 18:42
From: Michelle Aliff
Subject: Prevalence of True No-Touch Truck Driver jobs
Jeff,
It wasn't specifically SSA's request to change the definition of light work. It was a discussion that occurred with the solution of changing light to 25 lbs. It was the hole that was present in their exertional definitions that led to an increase to 25 lbs. Light work went up to 20 lbs and medium started with 25 lbs, so there was a no man's land between that 20 lbs. and 25 lbs. Sedentary also does have the limit/requirement of lifting 10 lbs. or less. Sedentary and light levels are the only two exertional levels that consider stand/walk and weight lifting.
SSA's definition of light work is not directly from RHAJ or DOT; they omitted the use of foot and hand controls or the use of negligible forces constantly, so it is easy to understand why they didn't consider it in ORS.
The operation of hand and foot controls was again partially due to the inability to measure forces. I do think a conversation that could be had is to say that occupations that require hand or foot controls, i.e. driving, could be labeled as light. But, does the operation of a gas pedal, especially with the advent of cruise control and even adaptive cruise control, really merit saying that occupations that require driving are light? I also worry about adding yet another variable to the calculation of exertional levels, specifically at light and sedentary.
Michelle Aliff Ph.D, CRC, CVE
Vocational Consultant
(503) 516-9863 (phone)
(817) 796-1478 (fax)
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Original Message:
Sent: 2/13/2024 6:14:00 PM
From: Jeffrey Truthan
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
The subtle, yet critical, missing elements in this discussion are changes in the BLS ORS definition of Light Work. ORS increased the upper limit of Light work to 25 lbs. ORS also omits any mention of the involvement of upper or lower extremities in its definition. Sedentary for ORS includes less than or equal to 1/3 of the day Standing.
In the DOT - Revised Handbook for Analyzing Jobs (RHAJ), there are several exceptions in the definition of Physical Demand Light - See https://skilltran.com/rhaj/rhaj12.pdf - page 12-2. Here are the key missing elements missing from consideration in the current ORS definition of Light Work:
"Even though the weight lifted may be only a negligible amount, a job should be rated Light Work:
(1) when it requires walking or standing to a significant degree; or
(2) when it requires sitting most of the time but entails pushing or pulling of arm or leg controls; or
(3) when the job requires working at a production rate pace entailing the constant pushing or pulling of materials even though the weight of those materials is negligible.
NOTE: The constant stress and strain of maintaining a production rate pace, especially in an industrial setting, can be and is physically demanding of a worker even though the amount of force exerted is negligible."
So what we have here is a different definition for Light Work by ORS that ignores (so far) the use of hand or foot controls. It is completely unknown what SSA will choose to do, given that they have not yet even formally recognized the ORS survey as an authoritative source of occupational information.
I would encourage IARP to discuss these operational definition differences with SSA. It was my understanding that SSA allowed the change up to 25 pounds for Light Work at ORS request. But completely unknown is whether the use of hand and/or foot controls should continue to be considered part of the revised ORS definition of Light work. The data has been captured in the ORS, but it is not factored into the published ORS definition of Light work. This missing "pushing or pulling of arm or leg controls" element figures significantly into occupations involving significant amounts of driving a vehicle and even into the production sector where machines require multiple extremities to operate or control.
Of the 477 SOC Groups (of 848 civilian SOCs) found in the Final Second Wave data set, there are 449 SOC Groups in which some degree of use of foot or leg controls is required. So this is a significant variable that should somehow be factored into how SSA chooses to treat this aspect of the ORS definition of Light work.
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Jeff Truthan, MS-Rehabilitation Counseling, CVE
President - SkillTRAN LLC - https://skilltran.com
Spokane Valley, WA 99206
(800) 827-2182 (Voice & Fax)
Original Message:
Sent: 02-13-2024 13:35
From: Michelle Aliff
Subject: Prevalence of True No-Touch Truck Driver jobs
I actually do not think this is a result of gathering data from HR. I often see truck drivers describing their jobs as sedentary as well. Employees do not appreciate or see that the forces they exert are high or require much physical ability. I do think there has been an increase in truck driving positions that do not require loading freight. BUT, that doesn't mean there are truly sedentary truck drivers out there.
A limitation of ORS is the inability to measure forces. This can only be captured in an onsite job analysis. If they were to ask how much force it requires to attach the trailer (hook and drop), the answers are likely to vary wildly, unless a large trucking company has collected that data.
One key suggestion I have been making to SSA and BLS, is the need to augment ORS with some onsite analysis for selected SOCs. The survey method is great for collecting large amounts of data, but there are some occupations that will require onsite analysis to confirm, deny or augment. Another potential avenue to exploring this particular issue is an analysis of job descriptions. I would bet money many have a weight requirement of 50 lbs; however, then we are dealing with some bias as well. Another option is looking at the FMSCA requirements. Another looking at the CDL medical examination requirements.
The truck-driving SOC is certainly one that needs some additional on-site analysis. ORS data requires expert interpretation, its not a punch a couple of buttons and get your answer. It requires critical thinking, reasoning and logic. DOT required reading whatever it said. Now, as vocational experts, we are tasked with looking at multiple sources of data and triangulating that data to come up with an appropriate and defensible opinion.
Michelle Aliff Ph.D, CRC, CVE
Vocational Consultant
(503) 516-9863 (phone)
(817) 796-1478 (fax)
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Original Message:
Sent: 2/13/2024 12:13:00 PM
From: Cindy L. Fisher MA CRC ABVED IPEC PV
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
Hi Scott,
Just saying those are super topics to cover and I really like the in and out of trucks as most of the people are heavier due to driving all the time.
Kudos
-- Cindy L. Fisher, MA., CRC, PVE, IPEC, ABVE/D
Director of Vocational Evaluation Services
Vocational Concepts LLC.
(888) 453-0909 Fax
(813) 362-4078 Direct
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Original Message:
Sent: 2/13/2024 11:14:00 AM
From: Scott T. Stipe
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
Yes, hook and drop. I suspect the ORS thing about 1/3 of drivers being sedentary is an artifact of the data coming from HR as opposed to JA of actual workers, some combination of wishful thinking and ignorance. Some flummoxes can be:
- Climb/pull force of body into/out cab exceeds S (or L)
- Yes, condition of mechanicals/force required can do same
- Companies which do this may do it on contract and contracts change and end and drivers may need to alternately do other driving too
- It can be an "old man' cherry thing held for senior, long-term employees, or employees needing light duty, and may not be available initially to a newcomer
- Geography, climate, prospect of chaining up , adjusting brakes, other mechanical renders it anything but sedentary
Original Message:
Sent: 2/13/2024 9:14:00 AM
From: Jeffrey B. Barrett MEd CAP CRC CCM CVE
Subject: RE: Prevalence of True No-Touch Truck Driver jobs
It is a while since I did work with the trucking industry. I never heard of "no touch" trucking jobs. There was what I recall as "hook and drop". That is, the driver never has anything to do with the trailer load. They simply back the truck to the trailer, connect the hoses from truck to trailer and turn a crank to hook the trailer to the bed of the trailer hitch on the truck. All very easy and less than 10 pounds of force (I had to measure that when doing job analysis), if the equipment was clean and lubricated (not always so easy). At destination, it is the reverse. Disconnect the hoses and turn the crank to release the trailer hitch. The driver had to do this for the same reason a pilot is supposed to inspect their plane before flying; to ensure that it is properly and safely done. I rated these jobs as Light as performed given the climbing in and out the truck, standing to connect the hoses and to turn that crank. Everything else was sedentary – that is driving to and from destinations.
That's what I recall. Would that be the "no touch" being referred to here or are we talking about self-driving trucks and no labor costs for the trucking companies while we drive on our highways with these AI driven monsters around us?
Best regards,
Jeff Barrett, M.Ed., CAP. CRC, CVE, CCM
Options Plus
optionsplusinc.com
954-929-9694
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Original Message:
Sent: 2/12/2024 11:26:00 AM
From: Mike McCord
Subject: Prevalence of True No-Touch Truck Driver jobs
Morning All,
I'd love to hear from someone with familiarity with the trucking industry regarding the availability of true no-touch driving jobs. Based on my research there certainly seems to be some growth in this area, particularly with the larger carriers. I'd welcome any information. Thanks!
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Mike McCord
mike@mccordrehab.com
Atlanta, GA United States
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