George Piemonte, NOSSCR Past President

Last month, I gave some suggested cross-examination questions for the job Marker. This month, we are going after Document Preparer. Below is a suggested Cross‑Examination of the VE about this job. It is by no means exhaustive.You will not necessarily need to use every question, and you should expect to adapt, add to, or modify them based on the VE’s testimony. These questions are intended as a guide, tools to help you shape a focused and effective cross-examination, not a script to be followed verbatim.

DOT 249.587‑018 – Document Preparer

I. Foundation: Basis of the VE’s Testimony

1. You testified that the DOT job of Document Preparer, Microfilming DOT 249.587‑018, still exists today primarily as a document scanning job, correct?
2. And you testified that, despite technological changes, the job remains sedentary and unskilled, is that right?
3. The DOT description of Document Preparer, Microfilming has not been updated since 1986, correct?
4. So when you testify about how this job is performed in today’s economy, you are relying on sources other than the DOT, such as labor market experience, employer contacts, or job postings?
5. The DOT description of Document Preparer does not mention modern imaging centers, production quotas, scanning equipment, or digital workflow systems, does it?

II. Exertional Demands: Standing, Walking, and Material Handling

6. In your experience, modern document scanning jobs typically involve physically handling paper records, boxes, and files, correct?
7. Employers generally require workers to remove staples, sort documents, organize pages, and prepare physical records for scanning, correct?
8. That work is often done at tables or workstations that require standing, rather than seated work, correct?
9. Many scanning jobs require employees to stand for much of the workday, sometimes for several hours at a time, don’t they?
10. Would you agree that standing for most of the workday is not consistent with sedentary work as defined by Social Security regulations?
11. Are you aware that employers frequently require scanner employees to lift and move boxes of documents?
12. Isn’t it common for these boxes to weigh 40 to 50 pounds?
13. Sedentary jobs, by definition, do not require frequent lifting of that magnitude, correct?
14. So if a modern “document preparer” job requires standing most of the day and lifting boxes of paper records, it would exceed sedentary exertional limits, wouldn’t it?

III. Pace, Production Rates, and Work Pressure

15. Modern scanning positions are typically production‑based, with daily or hourly productivity requirements, correct?
16. Employees are expected to meet speed and accuracy quotas, measured by how many documents or images are processed, right?
17. These quotas are tracked electronically and monitored by supervisors or software systems, aren’t they?
18. If a worker falls behind in productivity, there may be disciplinary consequences, correct?
19. Would you agree that working at a constant production pace, maintaining speed while ensuring accuracy, places greater demands on concentration and stress tolerance?
20. The DOT description for Document Preparer does not describe fast‑paced, quota‑driven production work, does it?

IV. Skill and Cognitive Demands

21. The DOT classifies Document Preparer as unskilled, correct?
22. Unskilled work generally requires only simple duties that can be learned in a short period of time, correct?
23. Modern scanning jobs require workers to review scanned images for quality, clarity, and completeness, don’t they?
24. Workers must identify missing pages, scanning errors, or misfiled documents, correct?
25. Isn’t that a form of quality control and error detection rather than simple repetitive labor?
26. Many scanning jobs also require workers to operate computer systems, imaging software, and document management databases, correct?
27. Would you agree that using multiple computer programs and validating image accuracy goes beyond the mental demands of simple, unskilled work?
28. The DOT’s Document Preparer description does not reference computer‑based imaging systems or electronic quality verification, does it?

V. Environmental and Physical Stressors

29. Modern document scanning is usually performed in production facilities or imaging centers, correct?
30. These environments often involve moderate to high noise levels from scanning machinery, right?
31. Workers are expected to maintain focus and accuracy despite those environmental distractions, correct?
32. Sedentary unskilled jobs in the DOT typically do not involve sustained exposure to production‑floor noise or machinery, do they?

VI. Erosion of the Occupational Base

33. You would agree that jobs evolve over time as technology changes?
34. And when the essential functions of a job materially change, it may no longer match the DOT description, correct?
35. Based on modern employer expectations: standing most of the day, lifting boxes, meeting production quotas, operating scanning equipment, and performing quality checks, would you agree that today’s “document scanning” jobs differ significantly from the DOT’s sedentary Document Preparer description?
36. If those modern requirements exceed sedentary exertion or simple unskilled work, then the DOT occupation would not be a valid representative job for someone limited to sedentary, unskilled work, correct?
37. And if the DOT title no longer accurately reflects how the job is performed, then the job numbers you provided based on that DOT code would be unreliable, wouldn’t they?

VII. Closing Concession

38. So to be clear: if modern document scanning work requires standing most of the day, lifting boxes of paper records, sustaining fast production quotas, and using computer imaging systems, it would not be consistent with a sedentary, unskilled job as defined by Social Security regulations, correct?

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Here are two job descriptions as of April 2026 from two different companies for the scanner job:

1. Iron Mountain:

In this role, you will be responsible for accurately preparing and scanning physical documents into digital formats, playing a vital part in our information conversion objectives. You will be part of a dedicated team focused on transforming hard copy records into high-quality electronic images.

What You’ll Do – In this role, you will:

• Prepare hard copy records for scanning by accurately sorting, removing staples, and ensuring all documents are maintained in the correct order and sequence.
• Operate scanning equipment to convert physical files into high-quality electronic images, ensuring all output meets strict quality standards.
• Follow all production procedures, complete internal tracking documentation, and adhere to Imaging Center guidelines for a clean and secure work environment.

What You’ll Bring – The ideal candidate will have:

• A High School diploma or equivalent.
• The ability to remove staples, sort, file, and box records while maintaining accuracy, combined with basic familiarity with Personal Computers (PC).
• A strong focus on detail and accuracy , with the proven ability to work independently at a sustained pace to meet production rates.
• Proficiency in reading, writing, and communicating in English , the flexibility to work overtime (OT) or weekends as needed, and the physical ability to lift and move boxes up to 40 lbs frequently.

2. Ricoh:

Job Description: Field Representative I, Document Imaging Position Profile

Ensures and maintains customer satisfaction according to company standards of quality and output by preparing, scanning, inspecting, compiling, and assembling documents.

Job Duties and Responsibilities:

• Performs full-performance level work in the conversion of hard copy letters, forms, and other paper documents into an electronic imaging format.
• Prepares documents for scanning by removing staples, paperclips, rubber bands, etc., for the document scanning process.
• Reviews the paper record against the electronic document to verify image quality and identify missing documents.
• Verifies and validates image/document errors and makes necessary changes as needed.
• Maintains productivity and quality levels in accordance with current standards.
• Reviews each scanned record for accuracy and clarity of the scanned product.
• Scans all new documentation received and loose paperwork.
• Meets deadlines in a fast-paced environment while maintaining quality and error-free work.
• Achieves time productivity statistics by meeting established standards.
• Maintains optimal machine performance, including basic maintenance (clearing jams, refilling toner, etc.).
• Completes all paperwork in a timely, accurate, and legible manner.
• Communicates problems effectively and promptly to the manager.
• Prevents assembly errors by maintaining an organized workstation.
• Achieves customer satisfaction by performing error-free jobs per customer specifications using various imaging technologies for Digital Mail and Imaging operations.
• Duties may include shipping and receiving, including handling of USPS materials.
• Additional duties may be assigned as needed.

Qualifications (Education, Experience, and Certifications):

• High school diploma or equivalent.
• Basic PC skills.
• Basic computer data entry experience.
• Basic typing and data entry skills.
• Intermediate computer skills, including but not limited to Microsoft Word, Outlook, and Excel.

Knowledge, Skills, and Abilities:

• Utilizes critical thinking and attention to detail.
• Ability to perform repetitive tasks while maintaining focus.
• Ability to retain information and maintain a high level of accuracy.
• Ability to work effectively in a team environment by maintaining positive, productive relationships with co-workers, management, sales, and production departments.
• Ability to adapt to changing situations and remain flexible.
• Strong organizational skills with the ability to multitask and meet deadlines.
• Ability to interact with EDMS, computer databases, and other computer software.
• Ability to analyze situations, problems, and information and take appropriate action.
• Ability to perform repetitive work by continuously executing different tasks according to set procedures, sequence, or pace while maintaining quality and output standards.

Working Conditions, Mental and Physical Demands:

• Ability to work multiple shifts, including nights, weekends, overtime, and holidays, depending on work volume and customer needs.
• Ability to work in a production facility with moderate to high noise levels.
• Ability to manage moderate stress levels and cope with stressful situations for extended periods of time.
• Position often requires standing for at least eight (8) hours per day.
• May be required to lift and move supplies weighing up to 50 lbs. from floor to waist height, carry them up to 10 feet, and lower them back to the floor.

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The views and opinions expressed in this article are the author’s own and do not necessarily reflect the views of NOSSCR, its leadership, or staff.