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Sometimes a prior job is actually more than one job at the same time. You were both a carpenter and a work site supervisor.  Your were a front desk clerk at a hotel, but also cleaned rooms and sometimes carried guests’ luggage to their room. These are called composite jobs.

In every disability claim, the SSA must determine (at step 4 of the 5-step sequential evaluation process) whether you have the residual functional capacity to perform your past relevant work. This is where the composite job is relevant to a disability claim.

Social Security Ruling 82-61 states “composite jobs have significant elements of two or more occupations and, as such, have no counterpart in the DOT. Such situations will be evaluated according to the particular facts of each individual case.” Social Security must consider all the exertional and nonexertional requirements of a composite job.

There is some good case law on this issue from the Ninth Circuit:

Every occupation consists of a myriad of tasks, each involving different degrees of physical exertion. To classify an applicant’s “past relevant work” according to the least demanding function of the claimant’s past occupations is contrary to the letter and spirit of the Social Security Act. Valencia v. Heckler, 751 F.2d 1082, 1086 (9th Cir. 1985).

See also Carmickle v. Commissioner, 533 F.3d 1155, 1166 (9th Cir. 2008).

This issue can make the difference between losing a case at step 4 or not.

Sometimes this comes up at a hearing, but the judges understand the issue, and usually it can be addressed with a brief discussion at the hearing (better yet: address it in your pre-hearing brief). However, I am seeing DDS get it wrong in Initial and Reconsideration determinations quite often.

I just signed up a new client who was denied at Reconsideration because she could perform her past work as generally performed in national economy. That is a red flag. Whenever you see that language in the denial letter or the Disability Determination Explanation (always request a copy of the DDE), you need to investigate the issue of composite work.