If the claimant’s RFC limitations adversely affect his or her (unskilled) occupational
base, but do not substantially erode it, consider the limitations in the borderline
age analysis. Our Social Security Rulings (SSR) provide authoritative information
about the impact of certain RFC limitations on the unskilled occupational base. For
a summary of RFC considerations for borderline age, see the Office of Disability Policy
desk guide for Citing a Social Security Ruling (SSR) at Step 5.
If the occupational base erosion is substantial, be careful to select the correct
medical-vocational rule. Do not use RFC to support the borderline age analysis when
the occupational base erosion is substantial because that is double weighing.
EXAMPLE of double weighing:
A claimant is 54 years, 7 months of age. He has a 12th grade education, with no transferable
skills and is no longer able to do his PRW. He has a medium RFC with occasional crouching.
In this case, we find that a limitation to only occasional crouching significantly
erodes the occupational base of medium work, so we use a light rule as a framework
for the determination. Medical-vocational rule 202.14 (closely approaching advanced
age) results in a finding of “Not disabled,” while medical-vocational rule 202.06
(advanced age) results in a finding of “Disabled.” The claimant is within a few days
to a few months of attaining a higher age category; therefore, consider whether to
use the claimant’s chronological age or the next higher age category. Do not use the
RFC limitations of only occasional crouching to support use of the higher age category
because we considered the effect of occasional crouching on the medium occupational
base when we determined that a light rule applied as a framework for our determination.
If we use the RFC limitations of only occasional crouching in this example to support
use of a higher age category, it is double weighing.
EXAMPLE that is not double weighing:
A claimant is 54 years, 11 months of age. He has a 12th grade education with unskilled
PRW and no direct entry into skilled or semiskilled work. He cannot perform his PRW.
He has a light RFC with restricted overhead reaching. Medical-vocational rule 202.13
(closely approaching advanced age) denies, while medical-vocational rule 202.04 (advanced
age) allows. The claimant is within a few days to a few months of attaining a higher
age category; therefore, consider whether to use the claimant’s chronological age
or the next higher age category. In this case, the additional limitation in overhead
reaching does not significantly erode the light occupational base. The overhead reaching
limitation affects the light occupational base, but it does not significantly erode
the light base so that a sedentary rule applies as a framework. Use this RFC limitation
to support an allowance under the borderline age criteria without double weighing.
Next, look at the impact of the factors.