concurring:
I am in agreement with the holdings and reasoning in the Discussion — Part II (“The Residual Functional Capacity Determination”) of the Opinion. Likewise, I concur with the result reached in the Discussion— Part I (“The ALJ’s Failure to Follow SSR 82-41”), ie., that the decision below should be reversed and remanded to the Commissioner for further proceedings. However, I arrive at that conclusion by an entirely different approach. The problem here was not fundamentally due to a failure of the ALJ to make a specific finding regarding *1230transferable skills,1 but to the inconsistent and erroneous findings actually made by the ALJ in his written decision and adopted by the district court.2
I. ADDITIONAL BACKGROUND
At the March 25, 2005 hearing, the VE’s testimony was specifically based in part upon the “Dictionary of Occupational Titles” (“DOT”).3 The VE summarized Bray’s relevant work history as follows:
Her most recent [job] was telemarketing, sedentary exertion level. That is defined in the DOT as an SVP three .... in my opinion vocationally it goes between a two and a three depending on where you work in the telemarketing field.
And her date of employment was March of 2004 for I guess a duration of three weeks. Caregiver, light exertional level, SVP three, semi-skilled, 8 of '02 to some period in 2004. Grocery clerk, meat department, medium exertional level[,] SVP two, unskilled, 8 of '02 to 1 of '03. Medical assistant^] light exertional level, SVP six, skilled, 3 of 1993 to 11 of '01. Underwriter, sedentary exertional lev-elf,] SVP seven, skilled, 8 of '86 through 10 of 1991.[4]
*1231In response to the ALJ’s hypothetical which included Bray’s age at onset of disability, education, work experience, residual functional capacity, and ability to “attend and concentrate on all but the most detailed and complex tasks,” the VE indicated:
That individual could perform the care giving job or what they call companion. This individual would be able to perform telemarketing types of work. I do not believe this person with a limitation on the detail you mentioned could handle the underwriter or the medical assistant. And by the way, medical assistant, that many times is at the medium exertional level....
As to the underwriter and medical assistant jobs, the VE opined that:
There are skills transferable in relationship to office clerical responsibility. In our underwriting job even as a medical assistant, she was exposed to computers, filing, typing, customer service, possibly some data entry, those kinds of skills. [Emphasis added.]
Ultimately, the VE concluded that Bray could work as a general clerk, file clerk or sales clerk, and there was available employment in those fields.5
The ALJ found that Bray “has the residual functional capacity to perform a significant range of light work....” He noted that:
The vocational expert testified that given the claimant’s residual functional capacity, she is incapable of performing her past relevant work as a grocery clerk, medical assistant and insurance underwriter. She would be capable of performing her past work as a telemarketer and caregiver. However, these jobs were not performed at the substantial gainful activity level and thus are not considered past relevant work. The claimant is incapable of returning to her past relevant work.[6]
The ALJ ultimately decided that:
Based on the credible testimony of the vocational expert, the undersigned concludes that considering the claimant’s age, educational background, work experience and residual functional capacity, she is capable of making a successful adjustment to work that exists in significant numbers in the national economy. A finding of “not disabled” is therefore reached within the framework of Medical-Vocational Rule 202.15.[7]
*1232II. DISCUSSION
A. Applicable Law
The concept of transferability of skills is delineated in 20 C.F.R. § 404.1568(d) as follows:
(1).... We [the SSA] consider you[the claimant] to have skills that can be used in other jobs, when the skilled or semi-skilled work activities you did in past work can be used to meet the requirements of skilled or semi-skilled work activities of other jobs or kinds of work. This depends largely on the similarity of occupationally significant work activities among different jobs.
(2).... Transferability is most probable and meaningful among jobs in which-
(i) The same or a lesser degree of skill is required;
(ii) The same or similar tools and machines are used; and
(iii) The same or similar raw materials, products, processes, or services are involved.
(3).... There are degrees of transferability of skills ranging from very close similarities to remote and incidental similarities among jobs. A complete similarity of all three factors is not necessary for transferability.
-!- * * *
(4).... If you are of advanced age (age 55 or older), and you have a severe impairment(s) that limits you to sedentary or light work, we will find that you cannot make an adjustment to other work unless you have skills that you can transfer to other skilled or semiskilled work ... that you can do despite your impairment(s).
SSR 82^41 states that “[w]hen the issue of skills and their transferability must be decided,” the “ALJ is required to make certain findings of fact and include them in the written decision.” 1982 WL 31389 at *7; see also Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir.2005). Also, “[w]hen a finding is made that a claimant has transferable skills, the acquired work skills must be identified, and specific occupations to which the acquired work skills are transferable must be cited in the ... ALJ’s decision.” 1982 WL 31389 at *7. However, SSR 82^41 additionally indicates that:
Transferability of skills is an issue only when an individual’s impairment(s), though severe, does not meet or equal the criteria in the Listing of Impairments in Appendix 1 of the regulations [20 C.F.R. Pt. 404, Subpt. P, App. 1] but does prevent the performance of past *1233relevant work (PRW), and that work has been determined to be skilled or semiskilled. (PRW is defined in regulations sections 404.1565 and 416.965.) When the table rules in Appendix 2 [20 C.F.R. Pt. 404, Subpt. P, App. 2] are applicable to a case, transferability will be decisive in the conclusion of “disabled” or “not disabled” in only a relatively few instances because, even if it is determined that there are no transferable skills, a finding of “not disabled” may be based on the ability to do unskilled work.
Id at *1. Further, SSR 82-41 recognizes that on occasion, in situations involving similar types of jobs, certain skills may be readily transferable.
... where job skills have universal applicability across industry lines, e.g., clerical, professional, administrative, or managerial types of jobs, transferability of skills to industries differing from past work experience can usually be accomplished with very little, if any, vocational adjustment where jobs with similar skills can be identified as being within an individual’s RFC [residual functional capacity].
Id. at *6.8
SSR 00-4p states that the SSA relies “primarily on the DOT (including its companion publication the SCO [the Revised Dictionary of Occupational Titles]) for information about the requirements of work in the national economy. We use these publications at Steps 4 and 5 of the sequential evaluation process.” 2000 WL 1898704 at *2. The occupational evidence provided by a VE should generally be consistent with the occupational information supplied by the DOT. Id. When there is a conflict between the VE evidence and the DOT, it is a duty of the AL J to inquire on the record as to the reason for the inconsistency before relying on the VE’s evidence. Id.
B. Analysis
The VE’s testimony (that Bray’s prior job as a “grocery clerk, meat department” had a physical exertion level of “medium” and an SVP level of “two, unskilled”) is contrary to both the DOT classification and the only evidence on the topic in the administrative record. The DOT lists the strength rating for the occupation of a “sales clerk, food (retail trade)” as “L” or “light” and an SVP level of “3” or “semiskilled.” 9 Dictionary of Occupational Titles § 290.477-018 (4th ed.1991). The DOT notes that the “sales clerk, food (re*1234tail trade)” job classification also covers “grocery clerk (retail trade)” and “meat counter clerk (retail trade).” Id. In the “Work History Report” which she filled out and submitted to the SSA in April of 2003, Bray described her grocery clerk job as requiring her to occasionally lift 20 lbs, to frequently lift 10 lbs and to stand and/or walk up to 8 hours. Her description of that job places it within the “light work” category. See 20 C.F.R. § 404.1567(b).
Because the VE’s testimony as to the requirements of the grocery clerk position was in conflict with the DOT’s specifications, the ALJ had “an affirmative responsibility” to inquire as to the reasons and evidentiary basis for the VE’s deviation. See SSR 00-4p, 2000 WL 1898704 at *2; Tommasetti, 533 F.3d at 1042; Massachi, 486 F.3d at 1153. The ALJ did not make any such inquiry, which constitutes error.
The ALJ in his conclusion stated that “given the claimant’s residual functional capacity, she is incapable of performing her past relevant work as a grocery clerk, medical assistant and insurance underwriter.” First, it is noted that in the beginning of his decision, the ALJ wrote that:
After the date of alleged onset of disability, the claimant worked as a grocery clerk. The work was performed during a temporary period of remissions from symptoms and ended after less than 6 months due to her impairments. This job is considered an unsuccessful work attempt.
It is questionable whether the grocery clerk job, if it had been correctly characterized as an “unsuccessful work attempt,” could later be considered part of Bray’s past relevant work.10 However, assuming arguendo that it can be, the ALJ’s conclusion — that Bray’s residual functional capacity (which the ALJ later found allowed her to do “light work” in the general, file or sales clerk occupations) barred her from performing her past work as a grocery clerk — is based upon the VE’s erroneous testimony that the grocery clerk job requires “medium” physical exertion requirements.11
In addition, the ALJ’s conclusion — that Bray was incapable of performing her past work as a grocery clerk and yet that she could perform work as a sales clerk — is on its face inconsistent. The duties of a grocery clerk/sales clerk, food (retail trade) are described in the Dictionary of Occupational Titles § 290.477-018 (4th ed.1991) as follows:
Obtains or prepares food items requested by customers in retail food store, totals customer bill, receives payment, and makes change: fills customer order, performing duties such as obtaining items from shelves, freezers, coolers, bins, tables, or containers; cleaning poultry; scaling and trimming fish; slicing meat or cheese, using slicing machine; preparing take-out sandwiches and salads; dispensing beverages; and warming food items in oven. Weighs items, such as produce, meat, and poultry to determine price. Lists and totals prices, using paper and pencil, calculator, or cash register. Informs customer of total price of purchases. Receives *1235payment from customer for purchases and makes change. Bags or wraps purchases for customer. Cleans shelves, bins, tables, and coolers. Stamps, marks, or tags price on. merchandise. Sets up displays and stocks shelves, coolers, counter, bins, tables, freezers, containers, or trays with new merchandise. May make deliveries to customer home or place of business.... May write orders, decorate cakes, or describe available specialty products, such as birthday cakes. May order merchandise from warehouse or supplier. May be designated according to type of food sold as Grocery Clerk (retail trade); Meat Counter clerk (retail trade); Produce Clerk (retail trade) I; Sales Clerk, Fish (retail trade).
The duties of a sales clerk (retail trade) are substantially the same as those of a grocery clerk/sales clerk, food (retail trade) and are delineated in Section 290.477-014 as:
Obtains or receives merchandise, totals bill, accepts payment, and makes change for customers in retail store such as tobacco shop, drug store, candy store, or liquor store: Stocks shelves, counters, or tables with merchandise. Sets up advertising displays or arranges merchandise on counters or tables to promote sales. Stamps, marks, or tags price oh merchandise. Obtains merchandise requested by customer or receives merchandise selected by customer. Answers customer’s questions concerning location, price, and use of merchandise. Totals price and tax on merchandise purchase by customer, using paper and pencil, cash register, or calculator, to determine bill. Accepts payment and makes change. Wraps or bags merchandise for customers. Cleans shelves, counters, or tables. Removes and records amount of cash in register at end of shift. May calculate sales discount to determine price. May keep record of sales, prepare inventory of stock, or order merchandise. May be designated according to produce sold or type of store.
A finding (without any explanation or reasoning) that Bray could do the work required of a sales clerk but not the job of a grocery clerk is in error.
Finally, as to the issue of transferability of skills, the ALJ placed Bray in Rule 202.15 of the grids and found her to be “not disabled.” 20 C.F.R. Pt. 404, Subpt. P, App. 2, Table No. 2. Rule 202.15 covers claimants who are “closely approaching advanced age,” 20 C.F.R. § 404.1563(d) (age 50-54), who are at a minimum high school graduates, and who have had past skilled or semi-skilled jobs where their skills are transferable. Under SSR 82-41, by placing Bray in a rule/category of the grids which contains a requirement of transferable skills, the ALJ should have made a finding identifying the work skills involved and the occupations to which they applied. The ALJ did not do so here, which constitutes error. However, that omission was not significant at that time or the source of reversible error. Even if one were to conclude that the ALJ’s failure to identify the transferable skills should be treated as if Bray had no transferrable skills, Bray would then fall within Rule 202.14 of the grids which would still place her in the “not disabled” category. See 20 C.F.R. Pt. 404, Subpt. P, App. 2, Table No. 2. Consequently, the fundamental problem here was not the ALJ’s failure to identify the transferable skills but rather whether placement of Bray into Rule 202.15 (or for that matter into Rules 202.13 or 202.14) was correct.12 This issue concerns wheth*1236er the ALJ properly considered the requirements of 20 C.F.R. § 404.1563(b) and 20 C.F.R. Pt. 404, Subpt. P, App. 2, § 202.00(c) and (d).13 However, in light of footnote 9 of the majority’s opinion, the ALJ’s placement of Bray into Rule 202.15 becomes moot and the issue of transferability of skills is moved from the backbur-ner to the front.14
III. CONCLUSION
For the reasons stated above, I concur that the decision of the district court should be reversed and the case remanded to the Commissioner for further proceedings.
. I concur with the majority in rejecting the holding in Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 549 (6th Cir.2004), that, under SSR 82-41 (1982 WL 31389 at *7), that a finding in regards to a claimant’s transferable skills is only required "when an ALJ relies solely on the grid, in which cases the ALJ must ascertain whether the claimant has transferable skills in order to apply the grid.”
. While the majority finds the ALJ’s failure to specifically identify Bray’s transferable skills to be a sufficient basis for reversing and remanding for further findings, as discussed in this concurrence that failure would not constitute grounds for such reversal but for the ALJ’s underlying erroneous findings which are delineated herein.
. As noted in Massachi v. Astrue, 486 F.3d 1149, 1153 n. 8 (9th Cir.2007), “The Social Security Administration has taken administrative notice of the Dictionary of Occupational Titles, which is published by the Department of Labor and gives detailed physical requirements for a variety of jobs." The DOT can be utilized by the ALJ and/or the VE in determining whether a claimant, given his or her residual functional capacity, can perform his or her past relevant work. 20 C.F.R. § 404.1560(b)(2). Likewise, the Social Security Administration ("SSA”) classifications of the physical exertion requirements of various jobs as being "sedentary, light, medium, heavy, [or] very heavy” have the same meaning as in the DOT. 20 C.F.R. § 404.1567. In designating the skill requirements of particular occupations as being "unskilled, semiskilled, [or] skilled,” the SSA also uses the materials (such as the DOT) published by the Department of Labor. 20 C.F.R. § 404.1568. The DOT "includes information about jobs (classified by their exertional and skill requirements) that exist in the national economy.” 20 C.F.R. § 404.1569. The DOT is considered to be the “best source for how a job is generally performed.” Carmickle v. Comm’r, SSA, 533 F.3d 1155, 1166 (9th Cir.2008) (quoting Pinto v. Massanari, 249 F.3d 840, 845 (9th Cir.2001)). "The DOT creates a re-buttable presumption as to the job classification.” Tommasetti v. Astrue, 533 F.3d 1035, 1042 (9th Cir.2008).
."SVP” refers to the "specific vocational preparation” level which is defined in the DOT as "the amount of lapsed time required by a typical worker to learn the techniques, acquire the information, and develop the facility needed for average performance in a specific job-worker situation.” Dictionary of Occupational Titles, Appendix C, page 1009 (4th ed.1991). SVP 2 means "anything beyond a short demonstration up to and including 1 month;” SVP 3 means "over 1 month up to and including 3 months;” SVP 6 means "over 1 year up to and including 2 years” and SVP 7 means "over 2 years up to and including 4 years.” Id.
As stated in SSR 00-4p, 2000 WL 1898704 at *3:
The DOT lists a specific vocational preparation (SVP) time for each described oc*1231cupation. Using the skill level definitions in 20 C.F.R. 404.1568 and 416.968, unskilled work corresponds to an SVP of 1-2; semi-skilled work corresponds to an SVP of 3-4; and skilled work corresponds to an SVP of 5-9 in the DOT. Although there may be a reason for classifying an occupation's skill level differently than in the DOT, the regulatory definitions of skill levels are controlling.
. At the hearing, Bray testified that in February/March of 2004, she was seeking employment involving "customer service, office work, medical office receptionist, scheduler, phones.”
. Contrary to the ALJ's finding, the VE never expressly stated that Bray was incapable of performing her past relevant work as a gro-eery clerk. The ALJ may have assumed that conclusion because of the VE’s testimony that the grocery clerk job required a "medium” exertional level. However, as discussed below, that testimony was erroneous.
."Medical-Vocational Rule_” is a reference to one of the rules/categories found in the tables in 20 C.F.R. Part 404, Subpart P, Appendix 2, which indicates “whether an individual is or is not disabled” based on the person's age, education, residual functional capacity and previous work experience. 20 C.F.R. Pt. 404, Subpt. P, App. 2, § 200.00. The tables with their concomitant rules/categories are sometimes referenced as "the grids.”
As to the use of the grids, Lounsburry v. Barnhart, 468 F.3d 1111, 1115 (9th Cir.2006), cautions that:
*1232[T]he grids are predicated on a claimant suffering from an impairment which manifests itself by limitations in meeting the strength requirements of jobs ("exertional limitations”); they may not be fully applicable where the nature of a claimant’s impairment does not result in such limitations ("non-exertional limitations”). 20 C.F.R. Part 404, Subpart P, Appx. 2 § 200.00(e) [citation omitted]. The reason for this limitation on the grids’ application is that, despite having the residual functional capacity to perform a full range of unskilled occupations at a given exertional level, a claimant may not be able to adjust to these jobs because of non-exertional limitations. Soc. Sec. Rui. 83-10 (January 1983). In particular, non-exertional impairments — including postural and manipulative limitations such as difficulty reaching, handling, stooping, climbing, crawling, or crouching— may, if sufficiently severe, limit a claimant's functional capacity in ways not contemplated by the grids. 20 C.F.R. § 404.1569 [citation omitted]. Thus, the Tackett court held that ”[t]he grids should be applied only where a claimant’s functional limitations fall into a standardized pattern 'accurately and completely’ described by the grids.” [Tackett v. Apfel, 180 F.3d 1094, 1103 (9th Cir.1999).]
. An example given in SSR 82-41 is:
[A] semiskilled general office clerk (administrative clerk), doing light work, ordinarily is equally proficient in, and spends considerable time doing, typing, filing, tabulating and posting data in record books, preparing invoices and statements, operating adding and calculating machines, etc. These clerical skills may be readily transferable to such semiskilled sedentary occupations as typist, clerk-typist and insurance auditing control clerk.
1982 WL 31389 at *3.
. The Dictionary of Occupational Titles, Appendix C, page 1013 (4th ed.1991), states that "L-Light work” indicates a capacity for:
Exerting up to 20 pounds of force occasionally, and/or up to 10 pounds of force frequently, and/or a negligible amount of force constantly (Constantly: activity or condition exists 2/3 or more of the time) to move objects. Physical demand requirements are in excess of those for Sedentary Work. Even though the weight lifted may be only a negligible amount, a job should be rated Light Work: (1) when it requires walking or standing to a significant degree; or (2) when it requires sitting most of the time but entails pushing and/or pulling of arm or leg controls; and/or (3) when the job requires working at a production rate pace entailing the constant pushing and/or pulling of materials even though the weight of those materials is negligible.
. 20 C.F.R. § 404.1560(b)(1) defines "past relevant work” as "work that you [the claimant] have done within the past 15 years, that was substantial gainful activity, and that lasted long enough for you to learn to do it.”
. If the grocery clerk job is held to be part of Bray's past relevant work and if her residual functional capacity (when correctly evaluated) would allow her to perform that past occupation, then she could be found "not disabled” at step four of the five step evaluation of disability analysis. See 20 C.F.R. § 404.1520(a)(4)(iv).
. In addition, because the VE erroneously categorized Bray’s prior grocery clerk job as *1236being ' unskilled” (which the ALJ accepted), the ALJ could not find that Bray had acquired any transferable skills from that occupation because "[a] person does not gain work skills by doing unskilled jobs.” 20 C.F.R. § 404.1568(a). However, because the DOT classifies the grocery clerk job as being "semiskilled,” Bray could be found to have obtained transferable skills while employed in that occupation. Although the ALJ characterized Bray’s five plus months of grocery clerk employment as an "unsuccessful work attempt,” the DOT treats that position as having an SVP of 3, which means that a typical worker could "learn the techniques ... and develop the facility needed for average performance” in that job after one to three months.
. In the grids, where a claimant is found to have a residual functional capacity which is limited to light work, the treatment of persons who are “closely approaching advanced age” {i.e. 50 to 54) differs greatly from those who are of "advanced age” (i.e. 55 or over). The former will generally not be considered to be disabled when they cannot return to their past relevant work unless they are illiterate and have had only unskilled or no previous work experience. See 20 C.F.R. Pt. 404, Subpt. P, App. 2, Table No. 2, Rules 202.09 through 202.15. Therefore, transferability of skills is not particularly relevant to that category of claimants. However, for individuals who are of advanced age and limited to light work, they will generally be considered to be disabled when they cannot return to their past relevant work unless they have transferable skills or some education which provides for direct entry into skilled work. Id. at Rules 202.01 through 202.08. Thus, the decision as to whether to treat Bray as a person who is closely approaching advanced age rather than a person of advanced age was of paramount importance. 20 C.F.R. § 404.1563(b) provides that the age categories are not to be applied "mechanically in a borderline situation.”
. As noted by the SSA when it amended 20 C.F.R. § 404.1563(b):
The new paragraph explains that, if a person's age category changes during the period for which we are adjudicating a disability claim, we will use each of the age categories that is applicable to the person during the period for which we are deciding if the person is disabled.
65 Fed.Reg. 17994, 17995 (April 6, 2000).