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Joel Stewart on PERM Labor Certification

PERM Skills Analysis

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An interesting article appeared in the internet regarding transferable skills. An analysis of transferable skills may be used to determine what positions a person may fill if they are seeking a similar position with alternate skills.


The PERM Rule provides that Employers must be prepared to provide some training for workers who seek to fill a new and different job. Applying the Kellogg Rule, workers may qualify for positions by a suitable combination of education, training or experience.


A transferable skills analysis looks at the work activities a person has performed in previous jobs, along with the objects upon which the work activities were performed. Data developed along these lines may then be used to identify a set of occupations that a worker should be able to perform.


Employers are encouraged to make assessment results for reasoning, math and language skills, as well as aptitude tests.


The definition of transferable skills used by the Social Security Administration states that "A person is considered to have skills that can be used in other jobs, when the skilled or semiskilled work activities (that person) did in past work can be used to meet the requirements of skilled or semiskilled work activities of other jobs or kinds of work. This depends largely on the similarity of occupational significant work activities among different jabs.


Ability to transfer skills is documented if the same or lesser degree of skill is required (Specific Vocational Preparation), the same or similar tools and machines are used (Work Fields), and the same or similar raw materials, products, processes or services are involved (Materials, Product, Subject Matter and Services).


In PERM, one might use the transferable skills analysis to determine whether alternative occupations are reasonable, or whether a worker  might be considered qualified to perform the job duties. Variations among jobs are normal and it is possible le that a job applicant can be found qualified with a different set of skills if they are transferable.


One of the criticisms often leveled at Employers in PERM processing is that their assessment of job applicants is too subjective. Employers interviewing job applicants can use a skill transfer analysis as a standard which objective and nob subjective.


The internet is replete with articles on tbe subject of transferable skills analysis including studies and statistics to back up conclusions.


The O*Net includes detailed information about occupations and jobs, including the skills required to perform job functions. This author recommends that evaluations of job applicants be based on the O*Net but that a transferable skills analysis be used to consider whether job applicants are qualified in the PERM recruitment process.

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  1. JR's Avatar
    Is there a link to the article you refer to?
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