Accurate Description of Past Work: Real Life Example of Why It Matters

I just reviewed a new case, and find it to be a great example of why it is very important for Texas social security disability claimants to correctly describe the exertional requirements of their prior jobs.  My client's sole past relevant work is that of a "Machinist" and "Custodian" in the Dallas Fort Worth area.    The client is over the age of 55, has had a prior lumbar fusion, and continues to suffer from low back pain.  This means that in order to deny the disability claim based upon this severe back impairment the Social Security Administration must find my client to be able to return to either of these two jobs, or be able to transfer skills from his machinist job to a less physically demanding job.   The latter is quite unlikely, so I am going to focus on the issue of return to work.

In my case, the Disability Determination Services (DDS) in Austin (they are the folks who in Texas make the disability decision at the initial and reconsideration stages) found the claimant to be able to do no better than "light work", which is generally defined as requiring standing and walking for "most of the day" and the ability to lift 20 pounds occasionally and 10 pounds frequently.    In order to find a claimant capable of return to past relevant work, Social Security must find that claimant capable of either returning to past relevant work "as described in the Dictionary of Occupational Titles" (DOT) or as "actually performed by the claimant".

The DOT describes both a position as a "Machinist" and "Custodian" as requiring lifting beyond that of a "light" job.  Therefore, this claimant should have won before he hired me.  Why didn't he?

Turns out, in his description of his jobs he indicated that they did not require lifting beyond 20 pounds occasionally and 10 pounds frequently.  I promptly got him in to the office, and as I suspected, his prior jobs required lifting well beyond that of light work.  He simply completed the "Work History" form incorrectly when he filed.  We will be getting this case turned around, but it is a textbook example of why social security disability claimants must complete the "Work History" form with care and accuracy.