criminology and forensic science. The record shows that prior to coming to the United States petitioner had been employed as a minister of religion from May 1959 to June 1960, as a file clerk for a gas refining firm from August 1963 to September 1965, and as an investigator for a law office from October 1965 to August 1967. Since arrival in the United States, he has been employed variously as a car washer, an inventory clerk, a house-to-house soap-sample distributor, and stock clerk for a hospital. None of his past work experience has been as a criminologist.

The Department of Labor, pursuant to section 212 (a) (14) of the Act, has issued a labor certification for the position of "criminologist" under Schedule C, Group II of 29 CFR 60 with a generic code of 054.088.

Section 203 (a) (3) of the Act provides that visas shall be made available "to qualified immigrants who are members of the professions, or who because of their exceptional ability in the sciences or the arts will substantially benefit prospectively the national economy, cultural interests or welfare of the United States."

Section 101 (a) (32) of the Act, as amended, defines the term "profession" as including but not being limited to architects, engineers, lawyers, physicians, surgeons and teachers in elementary or secondary schools, colleges, academies or seminaries.

In the Matter of Asuncion, 11 I. & N. Dec. 660, it is stated: Examination of the occupations named in section 101 (a) (32) of the Act indicates the following characteristics common to all: (1) recognition as a member of those professions normally requires the successful completion of a specified course of education on the college or university level, culminating in the attainment of a specific type of degree or diploma; and (2) the attainment of such degree of diploma is usually the minimum requirement for entry into those occupations.

The Matter of Pizarro, decided by the Regional Commissioner November 20, 1967, 12 I. & N. Dec. 537, states:

While the acquisition of a baccalaureate degree is a minimum academic requirement for recognition as a member of the professions, the acquisition of such a degree does not automatically and by itself make the holder a member of the professions. Some occupations require a degree above the level of a bacaalaureate degree to qualify as a professional in their field of study. The definition of professional, quoted above, includes doctors and surgeons and it is well established that a baccalaureate degree alone will not qualify a person as a doctor or surgeon and that advanced degrees are a requisite for recognition in the professions of medicine and surgery.

There are various Service Interim Decisions that hold that certain given occupations require academic preparation beyond the undergraduate level for recognition as a member of the profes

sions. These include Matter of Shih, 11 I. & N. Dec. 847, librarian; Matter of Shao, 11 I. & N. Dec. 845, economist; Matter of Roldan, 11 I. & N. Dec. 869, dietician; Matter of Che, 12 I. & N. Dec. 146, social worker; and Matter of Pizarro, 12 I. & N. Dec. 537, psychologist.

Volumes I and II of the Dictionary of Occupational Titles, published by the Department of Labor shows that the occupation of criminologist falls within the professional and kindred occupations in social science and sociology in the initial three digit code group of 054 and defines "criminologist" as "specializes in research on relationship between criminal law and the social order and in causes of crime."

The supplement to the Dictionary of Occupational Titles, also published by the Department of Labor, shows that all occupations listed under the initial three digit code of 054 have the same three digit terminal code of .088. Volume II of the Dictionary in discussing the academic training required for recognition as a profession of those occupations in the code of 054.088 states:

Generally, a Master's degree is the minimum requirement for professional employment in psychology or in any of the social sciences in this group, (including criminologist). For the most part, a Bachelor's degree is not adequate preparation for entrance into professional employment in any of the social sciences or in psychology.

It is further noted that the professional occupations of psychologist and economist, which the Service has already found to require academic preparation beyond the baccalaureate level, also are in the terminal three digit code of .088 the same as the "criminologist."

Furthermore, the Occupational Outlook Handbook, also published by the Department of Labor, states in relation to sociologist, including criminologist: "A Master's degree with a major in sociology is usually the minimum requirement for employment as a sociologist" and that "young people with only a Bachelor's degree in sociology are not recognized by the professions."

Counsel on appeal argued that the petitioner has more than an undergraduate degree in criminology, that the 196 hours leading to his Bachelor's degree was more than required for that degree and argued further that petitioner's degree in theology also should be considered as being supplemental to his baccalaureate degree in criminology. However, we hold that a mere volume of undergraduate credits cannot be equated with graduate courses and that two undergraduate degrees cannot be equated with a graduate degree.

Considering all the factors in this case, we find that the occupation of criminologist, dealing with specialized research and the critical analysis of the relationship of cultural patterns and social organizations to criminal law, maladjustment, and causes of crime, is too complex and sophisticated to give recognition as a member of the professions as a "criminologist" to a person other than one who has a minimum of a Master's degree in that field.

The decision of the District Director was proper. The petitioner, having only an undergraduate degree in criminology, is not qualified for recognition as a member of the professions as a criminologist. The appeal will be dismissed.

ORDER: It is ordered that the appeal be dismissed,

MATTER OF RAJAGOPALAMENON

In Visa Petition Proceedings

A-14972519

Decided by District Director October 22, 1968

Since a Master's degree in anthropology or its equivalent is the minimum requirement for professional classification as an anthropologist within the meaning of section 101 (a) (32) of the Immigration and Nationality Act, as amended, beneficiary, whose educational attainment is not the equivalent of such a degree, does not qualify as a member of the professions in the field of anthropology and he is ineligible for preference classification under section 203 (a) (3) of the Act, as amended, as an anthropologist.

The petition seeks to classify the beneficiary as a preference immigrant under section 203 (a) (3) of the Immigration and Nationality Act, as amended, based upon his qualifications as an anthropologist.

Section 203 (a) (3) of the Act provides for the availability of visas to qualified immigrants who are members of the professions or who because of their exceptional ability in the sciences or the arts will substantially benefit prospectively the national economy, cultural interests, or welfare of the United States.

Section 101 (a) (32) of the Act defines the term "professions" as including but not being limited to architects, engineers, lawyers, physicians, surgeons and teachers in elementary or secondary schools, colleges, academies or seminaries.

Although the occupation of anthropologist is not listed within the definition provided by section 101 (a) (32), it should be noted that it does bear a characteristic common to those occupations. This characteristic is that each of the occupations normally requires completion of a specified course of study on the college or university level, culminating in the attainment of a specific type of degree or diploma which is usually the minimum requirement for entry into that field. (Matter of Asuncion 11 I. & N. Dec. 660).

The beneficiary has submitted documents showing graduation

from the faculty of science, University of Kerala, Trivandrun, India March 1959 and indicates the award of a Bachelor of Science degree and a diploma from the University of Saugar, India showing the awarding of a Master of Science degree in anthropology, November 30, 1962. He additionally has submitted indications of further studies at the University of Madras, Madras, India in the field of anthropology, such courses leading towards a Ph.D. degree although no such degree was awarded. He was in attendance at the Ohio State University, Columbus, Ohio from 1966 to 1967 pursuing courses of study leading to a Master's degree in anthropology and again no degree was awarded.

The documents pertaining to his education were submitted to the comparative research branch, Division of Higher Education Research, Bureau of Research, Office of Education, Department of Health, Education and Welfare, for their advisory interpretation of the level and major field of educational attainment of the beneficiary in terms of education in the United States. That office has advised that in such terms his education is the equivalency of a Bachelor's degree in anthropology.

The Occupational Outlook Handbook, 1966-67 edition, a United States Department of Labor official publication lists anthropologists in the general category of the social sciences and have assigned a code number 055.088 to the profession of anthropology. Such publication states in part "young people who are interested in careers in anthropology should obtain Ph.D. degrees. College graduates with Bachelor's degrees can obtain temporary postitions and assistantships in the graduate department where they are working for advanced degrees. A Master's degree, plus field experience, is sufficient for many beginning professional positions, but promotions to top positions is generally reserved for individuals with the Ph.D. degree. In many colleges and most universities, only anthropologists holding the Ph.D. degree can obtain a permanent teaching appointment." The Dictionary of Occupational Titles, 1965, Volume 2, Occupational Classification, 3rd Edition, also places anthropologists in the general category with social science, psychological, and related research. These professions are under the general numerical classification .088. This publication also an official United States Department of Labor publication states in part, "generally, a Master's degree is the minimum requirement for professional employment in psychology or in any of the social sciences in this group. Those social scientists with this degree qualify for college instructorships in some schools and many nonteaching positions in government and