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Medical Expert: Social Security Administration


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A. According to Dr. Anonymous, at the time of the 1998 accident, the Claimant was earning, $21.00 per hour and working 48–56 hours per week for an average of 52 hours per week.


1. 514.662-010 CASTING OPERATOR (nonfer. metal)

a. Controls pouring station in which aluminum and aluminum alloys are cast into ingots: Regulates flow of molten metal from ladle or directly from melting furnace into trough feeding casting molds of casting unit. Regulates flow of metal from trough into molds by adjusting screw valves at bottom of trough. Controls cooling conditions of casting unit by maintaining constant level of metal in molds and regulating series of valves to spray water against molds to produce ingots of uniform crystalline structure. Signals OVERHEAD CRANE OPERATOR (any industry) 921.663-010 to remove ingots.
GOE: 06.02.10 STRENGTH: M GED: R3 M2 L2 SVP: 5 DLU: 77


a. M-Medium Work - Exerting 20 to 50 pounds of force occasionally, and/or 10 to 25 pounds of force frequently, and/or greater than negligible up to 10 pounds of force constantly to move objects. Physical Demand requirements are in excess of those for Light Work.[2]

b. SVP: 5 

i.                     Level 5: Over 6 months up to and including 1 year

3. Molding and casting machine operators tend machines that release the molten steel from the ladle into water-cooled molds at a controlled rate. Molded steel is then cut to desired lengths, as it emerges from the rolls. During this process, operators monitor the flow of raw steel and the supply of water to the mold.

a. Earnings in the steel industry vary by occupation and experience but are higher than average earnings in private industry. Average weekly earnings of nonsupervisory production workers in 1998 were $822 in the steel industry, compared to $563 in all manufacturing and $442 throughout private industry. Weekly earnings in blast furnaces and steel mills, at $907, were significantly higher than those in steel pipes and tubes, at $626. Earnings in selected occupations in steel manufacturing appear in table 2. Union membership, geographic location, and plant size affect earnings and benefits of workers. In some firms, earnings or bonuses are linked to output. Workers receive standard benefits, including health insurance, paid vacation, and pension plans. [3] 


Median hourly earnings of the largest occupations in steel manufacturing in 1997




First line supervisors and managers/supervisors-production and operating workers

$20.05 [4] [5] [6]






C. Average weekly earnings of nonsupervisory production workers in 1998 were $822 in the steel industry...Weekly earnings in blast furnaces and steel mills, at $907 [7], were significantly higher than those in steel pipes and tubes, at $626.

D. There is a clear increase in Claimant’s earnings from 1995 to 1997.



 This shows a 37 percent wage differential.

E. Future Wage Loss

1. To determine a victim’s lost future productivity, we must factor in the following:

a. Education, training, and experience prior to entry into job market and following entry.

b. Influence of age upon earnings the importance of economic productivity and growth: Gross Domestic Product (1%). [10] The impact of inflation, factored in and the average Consumer Price Index (CPI) (index of prices used to measure the change in the cost of basic goods and services in comparison with a fixed base period or cost-of-living index) for 2/98-7/98, or 0.14.[11]. The resultant approximation includes lost Fringe Benefits (22%), the GDP (1%) [12] and the CPI (1.5%).

2. Claimant was 43 (.06) years old at the date of accident.

3. He has 22 years (21.94) of employment until he reaches age 65 years (2020).

4. Based upon wage history, the pre- and post-injury differential average of $37,659

a. Total wage loss by age 65 would be $828,498. An estimate of potential earning capacity would extend to age 65 years without consideration of retirement at age 70.[13]

b. With retirement at 70, the wage deficit would be $1,016,793.[14]

5. Without awareness of the PTSD  or the complexity of continuing medical problems, Dr. Anonymous concludes Claimant is only “partially disabled…and will experience a loss of earning power secondary to the limitations presented by his burn injuries”.  He is unable to return to his former work and will not find wages comparable to those at Acme Technology. 

6. Further refinement of wage analysis and loss by an economist is recommended.


[2] This does not, apparently, incorporate light work as Dr. Anonymous indicates.

[3] Career Guide to Industries, 2000-01 Edition, Dept. of Labor

[4] Claimant states that he would now be making $24 per hour without the injury.

[5] 2000-01 Occupational Outlook Handbook, Dept. of Labor

[6] 1997: $882/week or 22.05/hr.

[7] 1998: OHH rate $22.67: Claimant was earning $22/hr.

[8] W-2 and CPA, Mr. Jones

[9] Sedentary, injury, no overtime.

[10] The Bureau of Economic Analysis: An agency of the Department of Commerce. Part of the Department's Economics and Statistics Administration.

[11] Bureau of Labor Statistics,

[12] In fact, 4 economic periods from 1960-1990 averaged a GDP of 1.5%.

[13] There is no mandatory retirement age in the United States. Presently, institutional, technological, demographic and behavior changes in the economic setting indicate that lifetime labor force participation may increase in time and normal retirement will be beyond age 65 years.

[14] This approximation does not include lost Fringe Benefits (22%), and the Consumer Price Index (CPI) (1.5%).