As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision changes the series and title of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The servicing human resources office must submit a compliance report containing the corrected position description and Standard Form 50s showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action.

Introduction

On March 13, 2015, the U.S. Office of Personnel Management’s (OPM) Philadelphia Agency Compliance and Evaluation accepted a classification appeal from Marcia L. Albert, Crystal D. Claypoole, Georgiann Maitland, and Roger J. Seybert.  The appellants occupy identical additional positions (hereinafter referred to as position) currently classified as Imaging Technician, GS-303-2, which they believe should be classified at the GS-3 or higher grade level.  The appellants work in the Retirement Services and Management Group (Group), Retirement Operations, Retirement Services, OPM, in Boyers, Pennsylvania.  We received the complete agency’s administrative report on May 14, 2015.  Each appellant is assigned to one of the Group’s two imaging teams; however, they perform essentially identical duties and are currently assigned to the same official position description (PD), number 6A38RIS.  Therefore, we have processed this case as a group appeal.  Due to program workload considerations, the appeal was transferred to Dallas Agency Compliance and Evaluation for adjudication.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

Incumbents of the appealed position requested a review of the classification of the position through the agency’s human resources office.  The agency determined the position is appropriately classified as GS-303-2, by application of the Grade Level Guide for Clerical and Assistance Work.  The appellants subsequently filed a classification appeal under 5 U.S.C. 5112 with OPM.

The appellants assert their duties are similar to those performed by higher graded File Clerk, GS-305-4, positions with the U.S. Department of Veterans Affairs and forwarded excerpts of a vacancy announcement for a GS-305-4 position from that agency.  In reviewing the document, we noted the vacancy announcement appears to describe a position with duties (e.g., scanning and uploading documents and preparing records for retention and disposition) similar to the appellants’ position.  The select extract provided by the appellants does not include a description of the complexity or type of filing system required of the medical environment, i.e., the context within which the file clerk scans, assembles, and images records and other documents.  Regardless, since vacancy announcements are not official classification documents, we lack sufficient information to warrant tasking a classification consistency report on the position cited by the appellants.

By law, we must classify positions solely by comparing their duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to the PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellants’ current duties to other positions, which may or may not be classified properly, as the basis for deciding this appeal.

Position information

The Retirement Operations processes and provides customer service for claims of retirement, survivor benefits, and adjustments to retirement and survivor benefit accounts of Federal employees.  The appellants’ position is responsible for imaging incoming documents by following established instructions covering the receipt, review, preparation, and scanning of records for digital imaging to OPM’s Electronic Document Management System.  The appellants are assigned to work the third shift, when all imaging work is performed, and are supervised by a Supervisory Imaging Technician, GS-303-6, position assigned to each of the two imaging teams in the Group which is responsible for providing file, operational support, and other support services.

To save documents to a digital archive, the appellants perform various tasks to include bundling and tagging documents, preparing documents, creating a barcode coversheet, scanning documents, validating the digitized image, and storing records in a box and associating the appropriate barcode to the assigned storage box.  Each stage of the process may involve multiple steps.  For example, the document preparation work requires removing staples, paper clips, and other unnecessary material covering data; fixing tears or rips; properly aligning pages; and counting and recording page numbers.  To create a barcode coversheet, the appellants manually enter into OPM’s retirement portal the name, date of birth, and social security number of the document owners, verifying each document in the record matches the personally identifiable information (PII).  After the barcode coversheet is placed on the top, the record is scanned into a computer program and image viewer.  The appellants validate digitized records for readability, accuracy, and correctness of page count.  The records are boxed and prepared for storage.  We discuss their duties in more detail under the grade determination section of this decision.

The Group’s Support Services Program Manager (the third-level supervisor) certified to the accuracy of the duties described in the appellants’ official PD.  The appellants have not certified to the accuracy of the PD, but they state in the initial appeal request to OPM that “[w]e are not…suggesting adjustments to the current job description.”  We find the appellants’ PD is adequate for classification purposes, and we incorporate it by reference into this decision.

To help decide this appeal, we conducted a telephone audit with the appellants on June 1, 2015, and a telephone interview with the immediate supervisors on June 2, 2015.  In reaching our classification decision, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellants and the agency.

Series, title, and standard determination

The appellants’ position is currently classified to the Miscellaneous Clerk and Assistance Series, GS-303, which covers positions the duties of which are to perform or supervise clerical, assistant, or technician work for which no other series is appropriate.  The work requires knowledge of the procedures and techniques involved in carrying out the work of an organization and involves application of procedures and practices within the framework of established guidelines.

Use of the GS-303 series is reserved for those instances where no single classification series clearly covers the primary and paramount functions of the position.  However, that is not the case here.  The appellants’ position is a match to the definition of file work in the Mail and File Series, GS-305, which covers positions involving the administration, supervision, or performance of clerical work related to the systematic arrangement of records for storage or reference purposes, the scheduled disposition of records, and the performance of related work when duties require the application of file methods and procedures, knowledge of prescribed systems for governing the flow and control of communications, and/or the filing or storage and retrieval of records, and knowledge of the organization and functions of the operating unit or units serviced.  The Occupational Information section of the GS-305 series describes file work, like that performed by the appellants’ position, including the processing operations providing for the establishment, maintenance, control, protection, and disposition of records for efficient reference service and retrieval of information and materials.  Various mechanical devices, such as copying machines and freestanding equipment, are used to facilitate the handling and processing operations.  We conclude the appellants’ position is fully and directly covered by the GS-305 series.

Consistent with our series determination, the proper title for the appellants’ position is File Clerk, which is the prescribed title for nonsupervisory positions in grades GS-1 through GS-5 when file duties are predominant in the position.  The position is properly graded using the GS-305 PCS.

The primary purpose of the appellants’ position is the storage of documents to a digital archive, which involves performing tasks such as retrieving, preparing, scanning, and storing records.  This work involves the operation of equipment, as confirmed by the official PD which identifies the ability to operate scanners, copying machines, and other office equipment as a knowledge required of the position.  Equipment operator work is properly evaluated by application of the grading criteria in the GS-350 Equipment Operator Series, which covers positions involving the operation of copier/duplicating equipment requiring a knowledge of the operating characteristics of the equipment and controls, the skills and knowledge to set up and adjust the equipment and controls to produce acceptable products or services on a timely basis, and the skill to perform normal operator maintenance.

Specifically, the appellants operate a Kodak i1860 high-speed document scanner, calibrating the machine upon its initial use, wiping the inside plate clean when necessary, scanning documents, and monitoring machine for feed and other errors.  According to the immediate supervisors, each appellant operates the scanner up to twice a week for five to six hours.  We applied the GS-350 PCS to the appellants’ applicable work and determined that those duties and responsibilities are graded no higher than the GS-305 work.  Since the equipment operator duties are incidental to and performed in support of the overall document imaging functions and are not grade controlling, we will not discuss them further in this decision.

Grade determination

The GS-305 PCS is written in the Factor Evaluation System (FES) format under which factor levels and accompanying point values are assigned for each of the nine factors.  The total is converted to a grade level by use of the grade conversion table provided in the PCS.  Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level.  If a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited to a lower level unless an equally important aspect that meets a higher level balances the deficiency.  Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level.

 Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information or facts that the worker must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, theories, principles, and concepts) and the nature and extent of the skills needed to apply those knowledges.  To be used as a basis for selecting a level under this factor, a knowledge must be required and applied.

At Level 1-2, file positions require knowledge of the functions and organizational structures of the units serviced, and basic knowledge of subject matter being processed to perform filing tasks typical of the systems characterized as “less complex” in the section on Occupational Information, to distinguish among materials that require different processing, to classify materials by subject matter when the relevant factors are easily determined, or to perform searches for materials when they are misfiled, in use in serviced units, or have been passed on to an action officer other than the one to whom charged out, etc., or similar duties.

At Level 1-3, positions require a thorough knowledge of the functions performed within the units serviced (e.g., the various operations performed within an accounting unit, the functions performed within an administrative services unit, etc.), a thorough knowledge of the subject matter content of the materials being processed, and a thorough knowledge of correspondence procedures and filing systems characterized as “complex” in the Occupational Information section.  File positions at Level 1-3 use this knowledge to classify and cross-reference materials in decimal and alphanumeric systems that may be extensively cross-referenced, or when the subject matter of the materials is overlapping or difficult to discern.  In these instances, proper determinations require study of materials to determine specific categories from among many that may be applicable.  This degree of knowledge is also used in searching for materials when the searching involves several possible locations, several possible file categories or file indices, when the information provided is meager, vague, or misleading, or when the existence of possible records is undetermined.

The knowledge required of the appellants’ position meets Level 1-2.  Consistent with this level, their position requires knowledge of the functions and operations of the units serviced as they relate to filing and maintaining records, and basic knowledge of the subject matter being processed to perform filing tasks.  The supervisors estimate two weeks as the average length of on-the-job training required of new staff to perform the imaging of documents relating to retirement claims, survivor benefit claims, adjustments, court orders, military service credit payments, refund applications, etc.  To perform this work, the appellants apply their knowledge of sorting and arranging materials in chronological and subject matter order when relevant factors are easily discernable as expected at Level 1-2.  According to the supervisors, the contents of a typical retirement claim vary but generally include seven or eight documents such as the retirement application, Standard Form 50s, military documents, and annuity calculations.  To digitize records in the order and manner established by the agency, the appellants’ document preparation work requires organizing documents within an individual record in chronological order, starting with the most recent, and placing supporting documents with the correct form.  This work requires knowledge of the organization’s procedures and instructions relating to standard, optional, military, and other retirement and benefit forms to ensure correct placement of documents in the digitized record (e.g., a DD Form 214, Certificate of Release or Discharge from Active Duty, is placed with the RI 20-97 Estimated Earnings During Military Service).

Also comparable to Level 1-2, the appellants’ position requires knowledge of the imaging processes such as preparing, scanning, and validating (i.e., reviewing digitized records for legibility and completeness) documents.  Their work involves sorting and isolating questionable records for the attention of the Quality Review Technician (QRT), who works the same shift as the appellants and is responsible for any research and action further required of flagged documents.  When multiple names are identified on documents, the appellants initially search for a marriage certificate or other documents to identify the legal name to be used for record identification.  The record is flagged for the QRT’s attention if no such information is provided.  In addition, the appellants apply their imaging process knowledge to inspect each document by ensuring staples are removed, stamps and seals are legible, PII is consistent, bent corners are fixed, tears and rips are repaired, the back page of a double-sided paper is photocopied and placed in the original bundle for scanning, etc.

The appellants’ position does not meet Level 1-3.  Unlike this level, their work does not require a thorough knowledge of the functions performed within the units serviced, the subject matter content, and complex filing systems to classify materials in decimal and alphanumeric systems requiring extensive cross reference.  Since they do not deal with materials where the subject matter either overlaps or is difficult to discern, the appellants’ work does not involve making proper determinations requiring the study of materials to determine specific categories from among many as also described at Level 1-3.  Instead, any such determination is the responsibility of others; for example, the appellants complete an image exception sheet to flag and separate the documents requiring research and further action by the QRT or supervisor.  On exception sheets, they identify the issues or problems with documents including poor quality, multiple social security numbers and names identified, missing or incorrectly placed spousal signature, and significant tears and rips for research, if necessary, and further action by the QRT or supervisor.

Level 1-2 is credited for 200 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.  Controls are exercised by the supervisor in the way assignments are made, instructions are given to the employee, priorities and deadlines are set, and objectives and boundaries are defined.  Responsibility of the employee depends upon the extent to which the employee is expected to develop the sequence and timing of various aspects of the work, to modify or recommend modification of instructions, and to participate in establishing priorities and defining objectives.  The degree of review of completed work depends upon the nature and extent of the review, e.g., close and detailed review of each phase of the assignment; detailed review of the finished assignment; spot-check of finished work for accuracy; or review only for adherence to policy.

At Level 2-2, the clerk receives instructions from the supervisor on non-recurring assignments and changes in procedures.  Most assignments are performed independently according to established procedures and previous experience.  The supervisor is consulted when problems arise for which there are no precedents.  The work is reviewed for accuracy by spot-checking or selective sampling, and may be reviewed occasionally for compliance with regulations.

At Level 2-3, the clerk receives general guidance from a supervisor who may be concerned with other functions and services in addition to mail and file.  The employee independently plans and adjusts mail and file functions to meet the requirements of serviced units.  The serviced units are concerned with new, emerging, or innovative programs (e.g., research and development, engineering or scientific laboratories, etc.) that are subject to relatively constant change.  The employee must therefore independently recognize the need for and take action to adjust or change mail-processing procedures, to establish new file procedures or systems, and to otherwise adapt or change established procedures.  The supervisor is normally consulted only when problems arise for which no guidance or precedents exist.  The work is reviewed in terms of the results achieved and the effect on resources and other administrative matters.

The appellants’ position meets Level 2-2.  Similar to this level, the appellants perform the day-to-day work independently according to established procedures under general supervision.  The QRT, supervisor, or others are available and to be consulted when situations or problems arise such as varying PII on documents, scanner problems, and the digitized image is too light, too dark, or has bent corners.  Also like Level 2-2, the supervisors give instructions relating to missing files, discrepancies between the original and digitized documents, and other non-recurring situations or assignments.  In addition, they give instructions on any needed changes to current processes and procedures; e.g., to address the backlog of documents to be imaged, the supervisors are currently performing most of the bundling of incoming documents while directing the appellants and other staff to perform other steps of the imaging process.  Through occasional spot-checking or select sampling, their work is reviewed for accuracy, timeliness, and compliance with established instructions.  In the initial appeal request to OPM, the appellants describe the supervisory controls over their position as follows:

A “full review” of every employee step is not taken by Supervisors.  A Supervisor does not check every document which is prepared.  They do not check to ensure every staple is removed, tear corrected, nor do they check documents for matching or correct [PII] or whether or not the document is appropriately advanced to a higher level of intervention.

The appellants also state that oversight of their position occurs more from peer-to-peer interaction, as work moves from document preparation to the barcoding and other stages, and “structural processes” such as the scanner flagging double feed or page count errors.  This level of supervision is consistent with the Level 2-2 description of employees independently performing day-to-day work that is checked for accuracy, not by a “full review,” but through spot-checking or selective sampling.

The appellants’ position does not meet Level 2-3, where employees independently plan and adjust file functions to meet the requirements of the serviced units.  Since the functional environment of the retirement staff is stable and not involved in new, emerging, or innovative programs, the appellants are thus not required to make constant changes and adjustments to existing document imaging procedures, or to establish new systems and procedures, as expected at Level 2-3.

Level 2-2 is credited for 125 points.

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment needed to apply them.  Guides used include, for example, desk manuals, established procedures and policies, traditional practices, and reference materials such as dictionaries and style manuals.

At Level 3-1, guidelines may consist of both standing oral instructions and written guides, the majority of which are readily memorized.  The guidelines are complete and specific, permitting little discretion in their application.  Employee works strictly according to the guidelines, referring deviations to the supervisor for decision.

At Level 3-2, guidelines consist of numerous standing oral instructions and written procedural guides that are applicable in differing work situations.  Thus, employees must use judgment and initiative in selecting and applying the proper guide (e.g., in the reading and routing of materials to a number of serviced units when the functions of the units are very similar, in classifying and cross-indexing when the subject matter of the materials may be covered by several possible categories, etc.).  Judgment is also used in selecting alternative means of locating materials missing from files when search information is inadequate or misleading and several locations are possible.

The guidelines available and used by the appellants meet Level 3-1.  In performing the full range of work, they are required to follow specific, clear, and detailed procedures established by the agency.  Specifically, the appellants follow the Imaging Technician Job Aid which describes the workflow process (document preparation, barcoding, scanning, validation, and box management) in specific terms.  Similar to Level 3-1, the instructions governing their work are stable, complete, and their content is easily memorized.

The number of guidelines applicable to the appellants’ work is not so great as to permit crediting the position with Level 3-2.  Furthermore, the job aid applicable to the work is complete (however, they are currently not performing most of the bundling, quality review, and pulling of open files work described by the instructions due to work process changes from the influx of backlogged documents), specific, and does not permit significant deviation.  The appellants must recognize and distinguish between various retirement records, court orders, military service credit payments, and other documents in order to organize them in chronological order within an individual record and place supporting documents with the correct form, but this and other distinctions to be made in the work are easily made as the job aid is clear and complete.  They also apply judgment to identify issues such as when documents are undated, contain different PII, or are of poor quality; however, they fill out an image exception sheet to flag the record for the QRT’s attention.  Since the QRT and other positions are responsible for applying judgment to resolve inadequate or misleading information, the appellants have limited opportunity to make or recommend decisions or vary actions as expected at Level 3-2.

Level 3-1 is credited for 25 points.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

At Level 4-1, positions require performance of clear-cut and repetitive tasks such as sorting mail into a few broad categories (e.g., regular, air mail, special handling mail, etc.); routing mail by placing it in clearly identified slots, boxes, or pouches; sequencing and filing uniform materials in a subject matter or alphabetical filing system; performing a range of file tasks in a security classified or security materials storage area; or similar tasks where the actions and steps to be taken are easily discernable.

At Level 4-2, positions require performance of several related duties involving consideration of choices of appropriate procedures or actions to be taken in a variety of work situations.  There is generally variety in the materials processed and in the activity required (e.g., recognizing a variety of types of printed forms and deciding the appropriate filing or routing actions to be taken with each, proper processing and safeguarding of security classified materials, etc.).  Work of this type also requires a number of steps or processes involving several different types of mail and recognizing that procedures is appropriate for each type (e.g., registered, insured, certified, security classified, etc.); distinguishing among a large number of distribution points when the functions of some serviced units overlap; classifying to appropriate file categories based on subject-matter content of materials; searching for missing materials and locating requested materials when information varies or conflicts; or similar work.

The complexity of the appellants’ position meets Level 4-1.  At the supervisor’s direction, they rotate throughout the shift between document preparation, barcoding, scanning, validating, box management, and other responsibilities.  The document preparation and other stages involve completing a range of repetitive file related tasks where the steps to be taken are easily discernable (e.g., verifying consistency of PII on documents, fixing rips, and aligning pages) as expected at Level 4-1.

The appellants’ position does not meet Level 4-2.  Unlike this level, there is essentially only one sequence of steps established for imaging documents.  Some documents are treated differently during the document preparation stage.  The appellants, when preparing to image court orders, insert start and end pages; examine the court’s raised seal, complete an authenticity certification if acceptable, and insert the completed form behind the start page; review court exhibits to identify potentially misplaced documents; and remove out-of-place documents from the court order when appropriate.  However, regardless of this and other document types requiring different preparation, there is only one authorized way of correctly imaging documents.  The appellants’ work may involve consideration of the action to be taken at each stage but the appropriate decision to be made is normally evident as described at Level 4-1.  Since there is a backlog of records to be imaged, the appellants said they occasionally receive a request to locate a record from the backlog.  Unlike the Level 4-2 description of searching for missing materials and locating requested materials, their work is limited to physically sorting through the boxes of backlogged documents to locate a record.  However, the record to be located is specifically identified by the supervisor and others rather than through the appellants’ identification of the record to be located based on either varying or conflicting information as described at Level 4-2.

Level 4-1 is credited for 25 points.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work, i.e., the purpose, breadth, and depth of the assignment, and the effect of work products or services both within and outside the organization.  Effect measures such things as whether the work output facilitates the work of others, provides timely services of a personal nature, or impacts on the adequacy of research conclusions.

At Level 5-1, positions are concerned with well-established mail and/or file functions.  Performance of these functions on a timely basis facilitates the work performed in the serviced units.

At Level 5-2, positions are concerned with work involving the improvement of methods or procedures affecting the overall efficiency of the mail and file unit; or work that involves determining and selecting appropriate materials to be made available to serviced units for their use.  Performance affects the ability of personnel in the serviced units to perform their duties in an accurate manner, or provide services to others.

The appellants’ position meets Level 5-1.  As at this level, their work involves document imaging functions that are well-established by standard operating procedures.  The prompt and accurate performance of their work supports, but is not substantively relevant to, the functions performed by the units they service.

The appellants’ position does not meet Level 5-2, as their work has no direct bearing on the accuracy of the substantive work performed by the retirement staff.  Rather, consistent with Level 5-1, the work performed by the appellants facilitates the timely accomplishment of the work performed by those units.  Unlike Level 5-2, their position is not responsible for the overall efficiency of the imaging teams (i.e., by improving methods or procedures) nor do they determine or select the records or other materials to be made available to the serviced unit.

Level 5-1 is credited for 25 points.

Factor 6, Personal Contacts

This factor includes face-to-face contacts and telephone and radio dialogue with persons not in the supervisory chain.  Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place (e.g., the degree to which the employee and those contacted recognize their relative roles and authorities).

As at Level 6-1, the appellants’ contacts are primarily with employees in the immediate work unit.

The appellants’ position does not meet Level 6-2, where personal contacts are typically with personnel in serviced units and may also include personnel outside the organization.

Level 6-1 is credited for 10 points.

Factor 7, Purpose of Contacts

The purpose of personal contacts ranges from factual exchanges of information to situations involving significant or controversial issues and differing viewpoints, goals, or objectives.  The personal contacts that serve as the basis for the level selected for this factor must be the same as the contacts that are the basis for the level selected for Factor 6.

As at Level 7-1, the purpose of the appellants’ contacts is to obtain or exchange information regarding the file operation functions of the organization.

The appellants’ position does not meet Level 7-2, where the purpose of contacts is to work with personnel in serviced units in resolving such operating problems as delays in receipt of materials, improperly coded or classified files or materials, and problems of similar difficulty, including inadequacy of existing file categories.  The QRT, supervisors, and other higher-level Group officials are responsible for contacts regarding issues of improperly imaged records, missing documents, and other such operating problems as described at Level 7-2.

Level 7-1 is credited for 20 points.

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.  This includes physical characteristics and abilities (e.g., specific agility and dexterity requirements) and the physical exertion involved in the work (e.g., climbing, lifting, pushing, balancing, stooping, kneeling, crouching, crawling, or reaching).

As at Level 8-1, the appellants’ work is primarily performed while sitting even though their duties require occasional periods of standing, walking, bending, or carrying of file folders and other light objects.

The appellants’ position does not meet Level 8-2, where work requires long periods of standing, walking, bending, etc.; or requires recurring lifting and carrying of packages, pouches, or bags of moderate weight (under 50 pounds) and occasional lifting and carrying of heavier materials.

Level 8-1 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings or the nature of the work assigned and the safety regulations required.

As at Level 9-1, the appellants’ work environment consists of an office setting that is adequately lighted, heated, and ventilated.

The appellants’ position does not meet Level 9-2, where work is performed on loading docks or other areas exposed to the weather, or in areas subject to high noise levels and vibration, and may require the use of protective clothing.

Level 9-1 is credited for 5 points.

A total of 440 points falls within the GS-2 range (255 to 450) on the grade conversion table in the PCS.

Decision

The appellants’ position is properly classified as File Clerk, GS-305-2.