Mitchell v. SHHS

March 25, 1994        [NOT FOR PUBLICATION]

                UNITED STATES COURT OF APPEALS
                    FOR THE FIRST CIRCUIT

                                        

No. 93-1612

                     TIMOTHY B. MITCHELL,

                    Plaintiff, Appellant,

                              v.

           SECRETARY OF HEALTH AND HUMAN SERVICES,

                     Defendant, Appellee.

                                        

         APPEAL FROM THE UNITED STATES DISTRICT COURT

              FOR THE DISTRICT OF MASSACHUSETTS

     [Hon. Frank H. Freedman, Senior U.S. District Judge]
                                                        

                                        

                            Before

                     Breyer, Chief Judge,
                                        
                Selya and Cyr, Circuit Judges.
                                             

                                        

   Timothy B. Mitchell on brief pro se.
                      
   A.  John  Pappalardo,  United  States  Attorney,   Karen  L.
                                                               
Goodwin,  Assistant   United  States  Attorney,  and   Robert  M.
                                                               
Peckrill,  Assistant Regional  Counsel,  Department of  Health  &
      
Human Service, on brief for appellee.

                                        

                                        

          Per  Curiam.     Pro se  claimant Timothy  Mitchell
                                 

appeals a district court judgment that affirmed the denial of

his claim for Supplemental Security Income (SSI) benefits.  A

former competitive  bicyclist, claimant  applied  for SSI  in

June 1989, when he was 24 years old.  He claimed  that he was

disabled due  to chronic pain resulting  from musculoskeletal

inflammation affecting  most of his joints,  particularly his

wrists  and  hands.    Claimant  alleged  that his  pain  was

aggravated by repetitive motions  and hot weather.  In  1987,

claimant secured a bachelors degree in cultural  anthropology

from  the University of Massachusetts.  He held various part-

time  jobs during  and after  college, including  those of  a

dishwasher,  psychiatric  counsellor, prep  cook, psychiatric

aide, stock  person, bus person,  and salesperson.   His last

position  was  as  a  telephone  fundraiser,  which  required

frequent repetitive use of the hands in dialing and writing. 

     After claimant's  application  was denied  upon  initial

review and reconsideration, claimant represented himself at a

hearing before an  administrative law judge  (ALJ).  The  ALJ

reviewed the conflicting medical evidence and determined that

claimant had no exertional limitations and only a "marginally
               

severe somatoform  disorder."1  The ALJ  concluded that while

                    

1.  Somatoform  disorders  are  characterized  by,"[p]hysical
symptoms for which there are no demonstrable organic findings
or known physiological mechanisms."  See 20 C.F.R.  Part 404,
                                        
Subpart P, App. I,  12.07.  This listing may be satisfied if,
inter alia,  the medical evidence documents  either: (1) "[a]
                                                   

                             -2-

the latter condition  moderately impaired claimant's  ability

to maintain persistence and pace, thereby preventing him from

performing his  past work as  a telephone fundraiser,  it did

not prevent the claimant from performing his other past jobs.

Thus, the ALJ  denied claimant's application at  step four of

the  sequential  evaluation  process.     See  Goodermote  v.
                                                         

Secretary of Health and Human Services, 690 F. 2d 5, 6-7 (1st
                                      

Cir. 1982).  The district court affirmed  this conclusion and

claimant  has  taken  a  timely appeal.    Having  thoroughly

reviewed the record, we also affirm for the reasons discussed

below.

                              I.

     We first review the medical and other evidence which  is

essential  to   a   complete  understanding   of   claimant's

allegations.    The record  discloses that  claimant bicycled

16,000 kilometers  (or 10,000 miles) in  various races during

the summer of 1983.  He began having health problems in 1984,

and consulted  Dr. Robert  Leach, an orthopedic  surgeon, for

pain behind his  left knee.   Claimant reported  that he  had

recently  had  surgery  on  his left  thigh  for  compartment

                    

history  of  multiple  physical  symptoms  of  several  years
duration,  beginning  before age  30,  that  have caused  the
individual to take medicine frequently, see a physician often
and alter life  patterns significantly; or" (2)  [p]ersistent
nonorganic  disturbance of ...  [s]ensation (e.g., diminished
or   heightened)"  or  (3)  [u]nrealistic  interpretation  of
physical   signs   or    sensations   associated   with   the
preoccupation or  belief that  one has a  serious disease  or
injury;...." Id.,  12.07(A). 
                

                             -3-

syndrome  and  that  he  had  previously  consulted  numerous

doctors and chiropractors  for various other pains.2   He had

taken Indocin (an anti-inflammatory agent) and Butazolidan (a

rheumatoid arthritis treatment)  without relief and  had also

undergone  a myelogram.   Apart  from an  area of  tenderness

around claimant's  left knee semitendinosis  tendon, physical

exam was completely  normal and Dr. Leach "was impressed with

how  loose [claimant] was."   Dr.  Leach made no diagnosis or

recommendations.  He stated  that he did "not have  any ideas

as to where to go from here" in view of the extensive studies

claimant had already undergone. 

     There  are no  medical records  from 1985,  during which

claimant  was apparently  enrolled in  college and  worked at

various  times  as a  prep  cook  and adolescent  psychiatric

counsellor.  In November 1986 claimant consulted Dr. Jonathan

Kurtis,  another orthopedic surgeon,  for bilateral  arm pain

associated with his job as a dishwasher.  Dr. Kurtis reported

that  his evaluation  was negative  for a severe  problem and

that "it was thought  that he had an  occupational tendonitis

of his  wrist."3   Claimant  graduated  from college  in  May

                    

2.  Compartment  syndrome is  "a  condition caused  by inward
pressure of an artery  reducing blood supply.  It  can result
in  a permanent contraction of  the hand or  foot." See Mosby
                                                             
Medical Encyclopedia, p. 182 (1985).  
                    

3.  Claimant returned to Dr. Kurtis in  January 1987 for left
heel pain cause by his cross-country ski boots.  In reporting
these findings  to the Social  Security Administration (SSA),
Dr. Kurtis  emphasized that  he had  not seen claimant  since

                             -4-

1987.   While claimant's vocational report  does not identify

it,  the medical records suggest that at some point following

his graduation  claimant either  volunteered or worked  in an

administrative  position with the Institute for International

Development and Cooperation.

     In  September  1987   claimant  consulted  Dr.  Lawrence

Schiffman, a rheumatologist,  complaining of bilateral  wrist

pain  while he was working  as a dishwasher  and a carpenter.

He reported  a history of tendonitis in his shoulders, knees,

and elbows  (epicondylitis) while also  complaining of  groin

pain and  lower  back  pain,  although  the  latter  was  not

chronic.     Claimant  denied  morning  stiffness  and  sleep

problems.  Physical examination disclosed that claimant had a

full range of musculoskeletal motion, although he experienced

tenderness at the base of the thumb and Achilles tendon.  Dr.

Schiffman recorded an impression of tendonitis and prescribed

Feldene, an  arthritis medication.   Follow-up lab  tests for

rheumatoid  arthritis were  negative.4   Claimant  apparently

travelled to Africa at some point in 1988 and returned to Dr.

Schiffman in April with complaints of pain at the base of the

thumbs  and groin.   He  again denied  morning stiffness;  no

                    

1987 and had no diagnosis consistent with chronic disability.

4.  In January  1988, Dr. Schiffman advised  claimant that he
had been  unable  to  make  a diagnosis  of  systemic  tissue
connective disease (arthritis) based on his laboratory  tests
and physical examination.   

                             -5-

swelling was present.   Apart  from the  areas of  tenderness

noted, physical exam was essentially normal.  Dr. Schiffman's

again recorded  an impression of tendonitis  and continued to

prescribe  medications.   Follow-up lab tests  for rheumatoid

arthritis, Lyme disease, and HIV were negative.    

     At  some point  during 1988  claimant also  travelled to

Denmark.    There he  sought further evaluation  of his pain.

Claimant returned  to Dr. Schiffman in  July 1988 complaining

of  bilateral  wrist, groin,  and thigh  pain.   He  was then

taking Ibuprofen. Claimant reported that he  was able to swim

but  that this  resulted in  increased  pain.   Physical exam

disclosed  no  swelling nor  other  positive  findings.   Dr.

Schiffman advised  claimant to  stop swimming  and prescribed

ultrasound therapy for his wrists. Between July and September

1988 claimant underwent  weekly ultrasound treatments at  the

Easthampton   Physical   Therapy  Services.      He  reported

experiencing some  improvement from  the pain in  his wrists,

although he did not attribute it to the treatments.5  At  the

conclusion of  the treatments Dr. Schiffman referred claimant

to  Dr.   Allison  Ryan,   a  specialist  in   neurology  and

psychiatry, stating that he had "not been able to establish a

                    

5.  Claimant also consulted an occupational  therapist at the
Communication  Enhancement Clinic of  the Children's Hospital
in Boston, although he  was not referred there by  any health
care  providers identified  in the  record.   Claimant sought
computer  components to  eliminate  the need  for  repetitive
wrist motions.     

                             -6-

diagnosis" although he  felt claimant's  symptoms were  "most

likely   due   to   an   overuse   syndrome,    worsened   by

deconditioning."6  

     In November  1988 claimant  applied for services  at the

Massachusetts  Rehabilitation  Commission  (MRC).     Shortly

thereafter  he   began  working  part-time  as   a  telephone

fundraiser for  the Progressive  Group, Inc.   On January  4,

1989,  claimant  returned  to  Dr. Schiffman,  continuing  to

complain of "tendonitis" in  his wrists and knees.   Physical

exam  again disclosed no swelling and a full range of motion.

Claimant  denied morning stiffness and reportedly was walking

regularly (10-20  minutes).   On the following  day, claimant

was examined  by Dr. Charles Brummer, a  family physician who

evaluated  claimant  for  the  MRC.   Dr.  Brummer  recounted

claimant's extensive  history of complaints  and unsuccessful

treatments for pain in his legs, hips, shoulders, and elbows.

Despite   treatment   with  multiple   medications,  claimant

reported that  he experienced no  relief.  Physical  exam was

normal, with a  full range of  musculoskeletal motion and  no

swelling,  heat, or  redness, although  claimant subjectively

complained of  pain with motion  and palpation.   Dr. Brummer

concluded   that   claimant  suffers   from  a   soft  tissue

                    

6.  We  note  that  following  his hearing  before  the  ALJ,
claimant submitted a letter to the Appeals Council wherein he
alleged  that Dr.  Ryan concluded  that claimant  has chronic
pain syndrome and fibromyalgia, a condition discussed  infra.
                                                            
However, Dr. Ryan's records are not before us.

                             -7-

inflammatory  disease  such as  chronic tendonitis  or, "more

probably  a  fibromyositis  or  fibromyalgia  syndrome" which

often  respond poorly  to  medications.7   He suggested  that

claimant was not  capable of  work and advised  him to  avoid

significant lifting,  climbing, or repetitive motions.  Based

on  Dr.  Brummer's  evaluation,   in  January  1989  the  MRC

determined   that  claimant   was  eligible   for  vocational

rehabilitation   services   as    a   severely    handicapped

individual.8     Claimant   also  began   weekly  acupuncture

treatments   with   Jonathan   Klate,   Ph.D.,   a   licensed

acupuncturist.     Dr.  Klate  continued  to  treat  claimant

throughout the  time his  claim was  pending and  submitted a

                    

7.  Fibromyalgia is  pain  in the  fibrous tissues,  muscles,
tendons,  ligaments,  and  other  white  connective  tissues,
frequently  affecting  the  low  back,  neck,  shoulders  and
thighs.  See The  Merck Manual (16th ed. 1992),  pp. 1369-70.
                              
As Dr.  Brummer's report  suggests, the term  fibromyalgia is
often used interchangeably with fibromyositis, or fibrositis.
See Lisa v. Dept. of Health and Human Services, 940 F.2d  40,
                                              
43  (2nd Cir. 1991).  This condition has only been recognized
over   the   last   several   years.     It   causes   severe
musculoskeletal  pain, stiffness  and  fatigue due  to  sleep
disturbances, although physical  examinations will  generally
be  normal. See  Preston  v. Secretary  of  Health and  Human
                                                             
Services, 854 F.2d  815, 818  (6th Cir. 1988).   The  disease
        
cannot be confirmed by objective tests, rather, the diagnosis
is made  by exclusion  and the elicitation  of tenderness  at
certain "'focal tender points.'" Id.  Fibrositis patients may
                                    
also have psychological disorders; the disease afflicts women
significantly more often than men. Id. 
                                      

8.  It  appears  that the  MRC  simply  assisted claimant  in
securing computer  software and  components that  would allow
him to pursue employment without exacerbating his condition. 

                             -8-

report   to  the   SSA   which  opined   that  claimant   was

significantly disabled.  

     Claimant  resigned  from  his  position  as  a telephone

fundraiser  around  June  29,  1989,  claiming  that  he  was

physically unable to meet the job's requirements due to wrist

and hand pain aggravated  by warmer weather.  He  applied for

SSI  benefits on  the same  day.   Claimant  was subsequently

examined by two internists  on behalf of the SSA,  Dr. Enrico

Petrillo and  Dr. Dwight Robinson.   Dr. Petrillo  reported a

normal  physical   exam  and  concluded   that  claimant  had

musculoskeletal symptoms  of burning and pain  in the muscles

and  tendons  bilaterally.    He did  not  assess  claimant's

residual functional capacity (RFC).   Dr. Robinson found that

claimant  exhibited 20  degree flexion  contractures of  both

elbows,  but  that   claimant's  joint  exam  was   otherwise

unremarkable.    In particular  he  noted that  there  was no

swelling or tenderness and no  muscle atrophy.  Dr.  Robinson

indicated that claimant might  have a variant of fibromyalgia

and that his  functional ability was  clearly limited by  his

symptoms,  although he  did not  assess  claimant's RFC.   He

advised  claimant  to  pursue  gradual  muscle  strengthening

exercises and possibly to try an antidepressant.9

                    

9.  Dr. Robinson also noted that claimant might have an early
form of  scleroderma, a  disease that would  not account  for
claimant's symptoms. 

                             -9-

     Based on the  aforementioned medical  evidence, the  SSA

secured an  assessment of claimant's exertional  RFC from Dr.

Harvey Wald, a non-examining  consultant.  Dr. Wald concluded

that claimant  was limited to light work.   Consequently, the

SSA denied  claimant's initial application and claimant filed

a request  for reconsideration.   Claimant  consulted another

rheumatologist,  Dr.  Robert  Gray,   on  December  7,  1989.

Physical exam again disclosed that both elbows showed a 20-30

degree loss of full  extension, but flexion was full.   There

was  no  synovial  (joint)  swelling,  no  fibrositic trigger

points, and no evidence  of muscle atrophy or weakness.   Dr.

Gray concluded that claimant suffered from arthralgias (joint

pain) and myalgias (muscle pain) of undetermined etiology and

that his symptoms  were atypical of fibrositis  syndrome.  On

December  13,  1989,  claimant  was examined  by  Dr.  Jerome

Siegel,   another  consulting   internist.     Physical  exam

disclosed  that claimant  appeared  well, had  no history  of

sleep disturbance, and again exhibited a full range of motion

with  no synovial  thickening.   No trigger  point tenderness

areas  were palpated.   Shoulder  x-rays  and lab  tests were

normal.   Dr. Siegel  made a  differential diagnosis  of pain

disorder involving the joints with questionable fibromyalgia,

somatization  disorder, and chronic  pain disorder.   Neither

Dr. Gray nor Dr. Siegel assessed claimant's RFC.

                             -10-

     Finally, on January 24, 1990, claimant was evaluated for

the SSA by  Dr. Sanford Bloomberg, a psychiatrist.   Claimant

reported  that he  suffered from  a "painful  condition" that

affected  essentially all  of his  major joints  although his

complaints were  "completely subjective."   Although claimant

reported that his activities had become extremely constricted

as a result, he was then taking graduate courses and applying

to  graduate school at  the University of  Massachusetts.  He

was also the editor of his church newsletter and participated

in  a young adult group.   Despite being  able to shop, cook,

and  participate in  the aforementioned  activities, claimant

professed  that he was in  constant pain.   He denied trouble

sleeping.  Dr. Bloomberg stated that, "[t]he only diagnosis I

would  make would  be  a somatoform  pain  disorder, with  no

related organic pathology, which  so far, can be specifically

identified to  document  the diagnosis  that some  physicians

have  made  for  him,   fibrocytis  or  fibromyalgia."    Dr.

Bloomberg noted  that  where  one  local  expert  (presumably

referring to Dr.  Gray) had concluded  that claimant did  not

have fibrositis,  claimant's complaints of pain  were grossly

in   excess  of  what  one   would  expect  if   he  had  any

pathology.10   While Dr. Bloomberg did  not assess claimant's

                    

10.  Dr.  Bloomberg also  observed  that  claimant's  alleged
incapacity was  not objectively observable and  that claimant
presented as  "vigorous, full of energy,  walking and sitting
down and rising ... with no difficulty apparent."

                             -11-

RFC,  the SSA secured a mental RFC evaluation from Dr. Joseph

Lichtman,  a  psychologist.    Dr.  Lichtman  concluded  that

claimant suffered  from a somatization  disorder which  would

often result in  deficiencies of persistence,  concentration,

and pace resulting in a failure to complete tasks in a timely

manner.   However,  he  found that  claimant's activities  of

daily living and ability  to maintain social functioning were

only slightly limited, and  that claimant never suffered from

episodes of deterioration or  decompensation in work or work-

like settings.  

     The ALJ credited  Dr. Lichtman's functional  findings in

concluding that  claimant was not disabled.   He specifically

found that  claimant does  not have a  medically determinable

physical  impairment that  could  reasonably  be expected  to

result  in  the  degree  of  pain  and  functional loss  that

claimant  has alleged.    The ALJ  then evaluated  claimant's

subjective  pain  complaints  in  accordance  with  Avery  v.
                                                         

Secretary  of Health  and Human  Services, 797 F.2d  19, (1st
                                         

Cir.   1986),  and   concluded  that   claimant's  subjective

allegations  were   not  credible   in  view   of  claimant's

activities as a graduate student  and church member, the fact

that there was no physical basis for claimant's pain, and the

fact that claimant  took no  medications at the  time of  the

                             -12-

hearing.11      The  ALJ   found  that   claimant's  residual

functional   capacity   was   not  significantly   restricted

exertionally and that his somatoform disorder only  prevented

him from  performing his past job as  a telephone fundraiser.

After the  hearing claimant  submitted additional letters  to

the  Appeals Council where he  recounted that he  had begun a

course  of treatment  with amitriptyline,  an anti-depressant

used  to  treat fibromyalgia.  The  Appeals  Council declined

review, thus rendering the ALJ's decision final.

                             II.

     We  are bound to affirm the Secretary if his decision is

supported by substantial  evidence on the record  as a whole.

See,  e.g.,  Rodriguez  v.  Secretary  of  Health  and  Human
                                                             

Services,  647 F.2d 218, 222  (1st Cir. 1981).   Any claimant
        

seeking  disability  benefits  bears  the initial  burden  of

proving that  his condition prevents him  from performing his

former  type of   work, not just  that he cannot  return to a
            

particular job. See Gray  v. Heckler, 760 F.2d 369,  372 (1st
                                    

Cir. 1985).  And, as the Secretary's regulations provide that

even  part  time  work  may  constitute  substantial  gainful

activity, the fact that all of claimant's past positions were

part time jobs does not require a finding of disability.  See
                                                             

Davis v.  Secretary of  Health and  Human Services,  915 F.2d
                                                  

                    

11.  Claimant  had  been  accepted  to  graduate  school  and
expected  to attend classes for two, eight-hour days per week
at the time of the hearing.

                             -13-

186, 189 (6th Cir.  1990); 20 C.F.R.  416.972(a)(work  may be

substantial even if it is done on a part time-basis). 

     On appeal, claimant argues that the evidence establishes

that  he  meets  the  Somatoform  Disorder  Listing  ( 12.07)

because  he   has  repeatedly   suffered  from  episodes   of

deterioration or decompensation at  work, as evidenced by the

fact that he has withdrawn from several of his past jobs  due

to  wrist tendonitis.   Claimant also  contends that  the ALJ

should  have given more weight  to the reports  of his health

care providers  (e.g., Drs. Schiffman,  Brummer, and  Klate),

particularly  where  the  doctors  who   assessed  claimant's

residual  functional  capacity  did  not  even  examine  him.

Claimant  emphasizes that  he  is  unable  to use  his  upper

extremities and, since most  jobs entail this requirement, he

is  unable to perform his past jobs and any other substantial

gainful activity.    Each of these arguments must  fail given

our limited  standard of review and  the conflicting evidence

in the record.

      First,  while  it  is  true  that the  ALJ  found  that

claimant satisfied three of the paragraph A criteria required

to meet the Somatoform Disorder Listing, see n. 1, supra, the
                                                        

record amply supports the ALJ's conclusion that claimant does

not suffer  from the  degree of  functional loss  required to

meet  the  paragraph B  criteria of   12.07.   Thus,  even if

claimant resigned from  his job as a telephone fundraiser due

                             -14-

to  increased  pain, this  alone does  not establish  that he

experienced the  repeated  episodes of  deterioration in  the

work place required to  satisfy  12.07.  Moreover, claimant's

testimony  and  contact  with  the  SSA  supports  the  ALJ's

conclusion  that his  activities of  daily living  and social

functioning  were  not   significantly  impaired.    Claimant

resides with  seven  people,  is able  to  do  some  cooking,

cleaning, writing, and driving, in  addition to participating

in church activities and  attending graduate school while his

SSI  claim was pending.   Even with the restrictions claimant

has  identified, these activities  do not suggest  a level of

impairment consistent  with total disability.   Thus, the ALJ

did  not err in concluding that claimant failed to prove that

he satisfies the Somatoform Disorder Listing.

     With  respect  to claimant's  second  contention,  it is

well-established in this circuit that a  treating physician's

opinion may  be  rejected by  the Secretary,  who may  accord

greater weight to  his own  experts.  See,  e.g., Keating  v.
                                                         

Secretary of Health  and Human  Services, 848  F.2d 271,  272
                                        

(1st  Cir.  1988)(per  curiam); Barrientos  v.  Secretary  of
                                                             

Health  and  Human  Services,  820  F.2d  1,  2-3  (1st  Cir.
                            

1987)(per curiam);  Sitar v. Schweiker, 671 F.2d  19, 21 (1st
                                      

Cir. 1982)(per curiam).  In concluding that claimant suffered

only  from a  somatoform  disorder and  not  from a  physical

impairment (e.g. fibromyalgia), the ALJ credited the opinions

                             -15-

of  Drs.  Siegel and  Bloomberg, both  of whom  suggested the

diagnosis   of  somatoform  disorder,   and  the  opinion  of

claimant's  own rheumatologist,  Dr.  Gray, who  stated  that

claimant's  symptoms  were   inconsistent  with   fibrositis,

particularly noting the absence  of trigger point  tenderness

and complaints of  poor sleep.   There  was no  error in  the

ALJ's  decision not to place  more weight on  the opinions of

claimant's other health care providers.    The ALJ  correctly

observed that the disability opinion expressed  by claimant's

acupuncturist was not  entitled to the  weight that might  be

accorded a  physician since the regulations  do not recognize

acupuncturists as acceptable medical  sources.  See 20 C.F.R.
                                                   

 416.972(a)(acceptable   medical  sources   include  licensed

physicians,  osteopaths,   psychologists,  optometrists,  and

record  custodians).    To   be  sure,  the  record  arguably

supported a finding that claimant does suffer from a physical

impairment   -  fibromyalgia   -     that   does  limit   him

exertionally.   But since conflicts  in the evidence  are for

the  Secretary  to  resolve,   see,  e.g.,  Burgos  Lopez  v.
                                                         

Secretary  of Health and Human Services, 747 F.2d 37, 40 (1st
                                       

Cir.  1984), we  cannot second  guess the  ALJ's decision  to

credit the evidence which undermined this diagnosis.

     The  ALJ  rejected  claimant's  contention  that  he  is

prevented  from  working  because  he cannot  use  his  upper

extremities,  finding that  his complaints of  disabling pain

                             -16-

and functional loss were not credible.   An ALJ's credibility

determinations are owed "considerable deference."   Dupuis v.
                                                          

Secretary of  Health and  Human Services,  869 F.2d  622, 623
                                        

(1st  Cir. 1989).      Nevertheless,  we question  the  ALJ's

conclusion  that   claimant   suffers  from   no   exertional
                                                

limitations.     In   the  first   place,  this   finding  is

contradicted by Dr. Wald, the SSA's consultant who found that

claimant was exertionally limited to  light work.  And  given

the  significant  number  of  physicians  who  reported  that

claimant suffered at least  some loss of function due  to his

subjective  symptoms, we question whether the ALJ as a layman

was  qualified   to  conclude   that  claimant  suffered   no

exertional  limitations  even  if   he  found  the  cause  of

claimant's  condition  to  be  a mental  impairment  (i.e,  a

somatoform  disorder)  as opposed  to a  physical impairment.

See  Walston  v.   Gardner,  381  F.2d  580,  585  (6th  Cir.
                          

1967)(pain may  be  disabling even  if  partly caused  by  an

emotional  problem).    As a  general  rule,  an  ALJ is  not

qualified to assess residual functional capacity on the basis

of  bare  medical findings.    See,  e.g.,  Berrios Lopez  v.
                                                         

Secretary of Health and Human  Services, 951 F.2d 427, 430-31
                                       

(1st Cir.  1991).   However,  the record  supports the  ALJ's

implicit  conclusion that claimant  retained the capacity for

light  work.   In  particular, we  note  that the  duties  of

claimant's past salesperson  job fall within  this exertional

                             -17-

category,  and that  "the type  of work  involved in  a sales

clerk job would not necessarily involve continual use of both

arms  and hands  for  long periods  of time  ...."   Gray  v.
                                                         

Heckler, 760 F.2d at 374.  The same can be said of claimant's
       

past   job  as   a  psychiatric   aide.   Accordingly,  where

substantial  evidence  supports  the  ALJ's  conclusion  that

claimant can do at least some of his past jobs, the  judgment

of the district court is affirmed.     
                                 

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