George Piemonte, NOSSCR Past President

The Router (DOT 222.587-038): A 1977 Job Description in a 2026 Economy

Introduction

I want to thank Frank Williams for pointing out that I made a mistake in last month’s article. In May, I incorrectly stated that Router was in O*Net Zone 3. That was wrong. I apologize for that incorrect statement. In the article below, I discuss the correct way to attack the job Router.

With the issuance of Emergency Message 24027 and growing judicial skepticism toward outdated Dictionary of Occupational Titles (“DOT”) occupations such as Addresser, Document Preparer, and Surveillance-System Monitor, vocational experts have been forced to migrate to a new set of “safe harbor” jobs at Step Five. Among the occupations increasingly cited as replacements is Router, DOT 222.587-038. But Router presents the same fundamental problem as the discredited jobs that came before it: the DOT description is frozen in 1977 and no longer reflects the way routing, shipping, clerical tracking, or package-distribution work is performed in the modern economy.

That does not mean practitioners should misstate the O*NET data. The O*NET does not classify SOC 43-9061.00, Office Clerks, General, as Job Zone 3. It classifies the occupation as Job Zone 1-2, with an SVP range below 6.0. The better and more accurate argument is not that the O*NET Job Zone alone proves that Router is semiskilled. The stronger argument is that the DOT’s 1977 Router description bears little resemblance to the modern occupational data for the SOC group to which Router crosswalks, and that SSR 24-3p requires the vocational expert to identify and explain the sources and methodology supporting any testimony that this 1977 job still exists as described, in significant numbers, at the exertional and skill level stated in the DOT.

The DOT Description: A Snapshot from 1977

The DOT describes Router as follows:

“Stamps, stencils, letters, or tags packages, boxes, or lots of merchandise to indicate delivery routes. Reads addresses on articles and determines route, using standard charts.”

That is the entire job description. The DOT classifies Router as light work, SVP 2, with General Educational Development levels of Reasoning 2, Math 1, and Language 2, and a Date of Last Update of 1977.

The picture painted by the DOT is clear: a worker reads addresses on packages, consults “standard charts,” and physically stamps, stencils, letters, or tags the items to indicate the correct delivery route. The DOT description does not mention computers, scanners, warehouse-management software, transportation-management systems, electronic tracking, barcode scanning, email, customer-facing communication, or database systems. It describes a narrow, manual, paper-based routing function that was last studied nearly fifty years ago.

That matters because the Commissioner bears the burden at Step Five to prove that other work exists in significant numbers in the national economy for the claimant’s actual residual functional capacity, age, education, and work experience. If the VE identifies Router as one of those jobs, the representative should not assume that the 1977 DOT description remains a reliable description of how the job is performed today.

The Modern Occupational Data Does Not Match the DOT’s Router Description

The DOT crosswalks Router to the broader O*NET/SOC occupation 43-9061.00, Office Clerks, General. The O*NET describes that SOC as work involving varied clerical duties requiring knowledge of office systems and procedures, including answering telephones, bookkeeping, typing or word processing, office machine operation, and filing. The O*NET’s listed tasks include operating office machines such as photocopiers, scanners, facsimile machines, voicemail systems, and personal computers; maintaining and updating filing, inventory, mailing, and database systems manually or using a computer; communicating with customers, employees, and others to answer questions and address complaints; computing, recording, and proofreading data; and reviewing files, records, and documents to respond to requests.

O*NET’s work-activity and work-context data further confirm that the modern SOC is not a simple replica of the DOT Router description. O*NET lists “Working with Computers” as a core work activity, defines it as using computer systems to enter data or process information, and reports frequent use of telephone conversations, email, contact with others, face-to-face discussions, attention to accuracy, external customer/public contact, and sitting. O*NET also lists software categories for the occupation, including customer relationship management software, database software, document management software, enterprise resource planning software, medical software, and word processing software.

That data should not be overstated. Because the O*NETclassifies Office Clerks, General as Job Zone 1-2 with an SVP range below 6.0, practitioners should not argue that the O*NET, by Job Zone alone, proves that the occupation is Job Zone 3 or necessarily SVP 6. But the O*NET data remains highly useful for a different reason: it shows that the modern SOC group associated with Router is a broad clerical occupation involving computers, communication systems, databases, office procedures, email, customer contact, and electronic information processing. That is materially different from the DOT’s narrow 1977 description of a worker who stamps or tags packages and determines routes using standard charts.

The Correct O*NET Argument: Not “Job Zone 3,” but “Task and Methodology Mismatch”

The erroneous version of this argument was that Router crosswalks to an O*NEToccupation classified as Job Zone 3, medium preparation, corresponding to SVP 6. That is not correct. The officialO*NET classification for SOC 43-9061.00 is Job Zone 1-2, “Very Little to Some Preparation Needed,” with an SVP range below 6.0.

The corrected argument is more precise and more defensible:

First, the DOT’s Router description is exceptionally narrow and sounds obsolete. It describes manual stamping, stenciling, lettering, or tagging of packages to indicate delivery routes, with route selection performed by reading addresses and using standard charts.

Second, the modern SOC group to which Router crosswalks is not a package-routing job as described in the DOT; it is the broad occupation of Office Clerks, General, involving office systems, personal computers, scanners, database systems, phone and email communication, customer or employee interaction, data computation, proofreading, document review, and electronic recordkeeping.

Third, because the DOT and SOC/O*NET classification systems do not correspond one-to-one, a VE cannot simply cite Router from the DOT and then rely on broad SOC-based data without explaining how the VE moved from the broader SOC group to the specific DOT occupation and how the VE accounted for differences between the 1977 DOT description and the modern data source. SSR 24-3p expressly recognizes that the SOC system aggregates occupations at a higher level than the DOT and explains that, where VEs rely on SOC-based sources for DOT occupations, they may need to explain the general approach used to compare DOT data with SOC-based job-number estimates.

That is the point practitioners should press. The conflict is not that O*NET Job Zone 1-2 is incompatible with unskilled work in every case. The conflict is that the VE often relies on a 1977 DOT title while drawing support from a broad, modern SOC group whose tasks, tools, context, and occupational structure do not match the DOT’s description of Router.

SSR 24-3p Opens the Door, but It Also Requires Precision

A common VE defense when confronted with post-DOT occupational evidence is: “I use the DOT.” SSR 24-3p makes that answer inadequate if the VE’s testimony depends on additional sources, SOC-based job numbers, professional experience, or a modern understanding of how the job is performed.

SSR 24-3p rescinded SSR 00-4p effective January 6, 2025, and explains that SSA continues to recognize the DOT as a valid and reliable source of occupational information, but also acknowledges that the DOT is not the only reliable source. The ruling states that VEs and VSs may use any reliable source of occupational information that is commonly used by vocational professionals and relevant under SSA’s rules, along with their professional knowledge, training, and experience. It also expects VEs and VSs to identify the data sources they use and, where applicable, explain their general approach to estimating job numbers.

That is critical for Router. The DOT itself does not provide job numbers. SSR 24-3p recognizes that VEs may cite DOT occupations but derive job estimates from SOC-based sources such as OEWS or ORS; when they do, the VE should explain the general approach used to compare the DOT occupation to the broader SOC group and derive the occupation-specific estimate. It is therefore not enough for the VE to say “Router, DOT 222.587-038, light, SVP 2” and then provide a job number without explaining the source and methodology.

SSR 24-3p also recognizes that if a VE cites an occupation that is performed differently than identified in the source of data used, the VE should identify and explain that difference. EM-24027 REV reinforces the same practical concern, explaining that DOT descriptions may refer to job materials or processes that have been replaced by more modern materials or processes and that courts have questioned whether some DOT occupations continue to be performed as described. Although Router is not one of the listed EM-24027 occupations, the same evidentiary principle applies: when a Step Five denial rests on an old DOT occupation whose described processes appear outdated, the record should contain a vocational explanation, not an assumption, that the job still exists as described and in significant numbers.

Courts Have Already Questioned Router

Router is not flying under the judicial radar. In Kelly P. v. Saul, No. 5:18-cv-00777-MAA, 2019 U.S. Dist. LEXIS 131903 (C.D. Cal. Aug. 6, 2019), the court considered a Step Five finding involving routing clerk, router, and mail clerk jobs, and the case has been cited by advocates because the court questioned whether router jobs, as described in the DOT, existed in sufficient numbers in the modern national economy.

That does not mean every Router citation is automatically reversible. The point is narrower and stronger: if the VE relies on Router, the representative should develop the record on whether the occupation exists as described in the DOT, whether the VE is actually relying on DOT data or SOC-based data, what source provides the job numbers, how those numbers were derived from the broader SOC group, and whether the VE has accounted for the difference between the DOT’s manual-routing description and modern occupational evidence.

Practical Implications: What Practitioners Should Do

When a VE cites Router at Step Five, practitioners should be prepared to challenge the citation on three related grounds.

First, ask whether the job exists as described in the DOT.

The DOT describes Router as a worker who stamps, stencils, letters, or tags packages, boxes, or lots of merchandise to indicate delivery routes and determines the route by reading addresses and using standard charts. The VE should be asked:

• What source did you rely on to determine that Router, DOT 222.587-038, still exists as described in the DOT?
• Can you identify any current employer or occupational source showing that workers still determine delivery routes by consulting “standard charts” and physically stamping, stenciling, lettering, or tagging packages to indicate routes?
• Did you consult any post-DOT occupational source to determine whether the DOT description reflects how the work is currently performed?
• If the job is now performed with scanners, computers, databases, electronic tracking systems, or other modern tools, did you account for those differences in your testimony?

Second, require the VE to identify the job-number source and methodology.

The DOT does not provide job numbers. SSR 24-3p recognizes that VEs may cite a DOT occupation while deriving job estimates from SOC-based sources, but it expects the VE to identify the sources used and explain the general approach for deriving job numbers from the broader SOC group. The VE should be asked:

• What is the source of your Router job-number estimate?
• Did you use an SOC-based source such as OEWS, ORS, O*NET, a commercial program, or another source?
• What SOC group did you use?
• How many DOT occupations crosswalk to that SOC group?
• What method did you use to isolate Router jobs from the broader SOC group?
• Did you apply any reduction to account for jobs in the SOC group that do not match the DOT’s Router description?
• Did you apply any reduction to account for jobs that are not light, not SVP 2, or not performed as described in the DOT?

Third, use O*NET accurately, as evidence of a mismatch, not as a false Job Zone argument.

Practitioners should not say that the O*NET classifies Office Clerks, General as Job Zone 3. It does not. O*NET classifies SOC 43-9061.00 as Job Zone 1-2, with an SVP range below 6.0.

But practitioners should use the O*NET to show that the modern occupational data for the crosswalked SOC group is materially different from the DOT Router description. The O*NET lists tasks involving personal computers, scanners, database systems, filing and inventory systems, customer and employee communication, data computation, proofreading, document review, email, telephone conversations, and office software. None of those functions appears in the DOT Router description.

The cross-examination point is therefore:

• The O*NET shows that the modern SOC group is a broad, computer-based clerical occupation.
• The DOT Router description is a narrow, manual, chart-based routing occupation from 1977.
• If the VE relies on the DOT title but uses modern SOC-based numbers, SSR 24-3p requires a reasoned explanation of the sources, crosswalk, methodology, and differences.

Sample Cross-Examination Sequence (examples, not an exhaustive list):

1. The DOT description for Router says the worker stamps, stencils, letters, or tags packages, boxes, or lots of merchandise to indicate delivery routes, correct?
2. The DOT also says the worker reads addresses and determines the route using standard charts, correct?
3. The Date of Last Update for Router is 1977, correct?
4. The DOT does not mention computers, scanners, barcode systems, electronic tracking systems, email, databases, routing software, or warehouse-management systems, correct?
5. What source did you use to determine that this occupation still exists as described in the DOT?
6. What source did you use for your job number estimate?
7. Does that source use DOT codes or SOC codes?
8. If it uses SOC codes, what SOC group did you use?
9. The O*NET/SOC occupation associated with Router is Office Clerks, General, SOC 43-9061.00, correct?
10. The O*NET’s current data for Office Clerks, General includes tasks involving personal computers, scanners, database systems, telephone communication, email, customer or employee communication, proofreading, and document review, correct?
11. Those tasks are not included in the DOT description of Router, correct?
12. Your testimony is that the DOT Router occupation still exists as light, SVP 2 work in significant numbers, correct?
13. What specific evidence supports that conclusion?
14. How did you account for the difference between the DOT’s 1977 description and the way the broader modern SOC group is described in the O*NET?
15. How did you isolate the number of Router jobs from the broader SOC group?
16. Did you reduce the job number to exclude jobs in the SOC group that involve modern clerical tasks not described in the DOT Router entry?
17. Did you reduce the job number to exclude jobs that require tools, software, communication, or clerical functions beyond the DOT Router description?
18. If you did not make those adjustments, is it fair to say your job number estimate assumes that the DOT Router description remains valid rather than demonstrating that it remains valid?

Conclusion

Router is vulnerable, but the challenge must be accurate. The correct argument is not that the O*NET classifies SOC 43-9061.00 as Job Zone 3. It does not. The correct argument is that Router’s DOT description is a 1977 manual-routing description, while the modern occupational data associated with its SOC crosswalk describes broad clerical work involving computers, scanners, databases, email, telephone communication, customer contact, document processing, and office systems.

SSR 24-3p gives practitioners the tool they need to expose that problem. The VE must identify the sources used, explain the general methodology for any job-number estimate, account for differences between DOT- and SOC-based sources when necessary, and explain when an occupation is performed differently than identified in the source. EM-24027 REV confirms the broader concern that some DOT descriptions refer to materials or processes that may have been replaced by modern ones.

The bottom line is simple: if the ALJ relies on Router at Step Five, the record should contain evidence, not assumption, that this 1977 DOT occupation still exists as described, at the stated exertional and skill level, and in significant numbers in the national economy. If the VE cannot provide that explanation, Router should not carry the Commissioner’s Step Five burden.

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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.