Washington, DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Damon B. Ford
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

09/22/2020

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations, 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).

As indicated in this decision, our findings show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E. of the Introduction.  Since PDs must meet the standard of adequacy, the agency must revise the PD to reflect our findings.  The servicing human resources office must submit a compliance report containing the corrected PD and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.

Introduction

The appellant’s position is currently classified as Forestry Technician (Prevention), GS-0462-07.  However, the appellant believes his duties and responsibilities warrant an upgrade to the GS-08 level.  The position is located at the Monterey Ranger District (district), Los Padres National Forest (forest), Pacific Southwest Region 5, U.S Forest Service (FS), U.S. Department of Agriculture, in Carmel Valley, California.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements about the classification review process conducted by his agency and compares his position to similar but higher graded positions within the FS.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position.  By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified properly, as a basis for deciding his appeal.  Because our decision sets aside all previous agency decisions, the classification practices used by the appellant’s agency in classifying his position are not germane to the classification appeal process. 

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers his position so similar to higher graded positions at the forest or other forests that they all warrant the same classification, he may pursue the matter by writing to his headquarters agency human resources office.  In doing so, he should specify the precise organizational location, classification, duties, and responsibilities of the positions in question.  If the positions are found to be basically the same as his, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to him the differences between his position and the others.

In his appeal request to OPM, the appellant cites OPM’s Digest of Significant Classification Decisions and Opinions (“Digest Article”), Number 12-01, which discusses the work performed by Attack Warning Officers, whose primary duty is to disseminate information instantly and decisively on reports of emergencies.  Because the basic reason for the existence of the Attack Warning Officer position is to serve in the event of a national emergency, the training and readiness required for dealing with such emergencies was considered a constant and integral feature of the position’s requirements.  Therefore, OPM considered and credited the work performed by the Attack Warning Officers regardless of it being performed on an “irregular, nonrecurring, emergency basis.”

The appellant seeks to compare and credit his fire suppression duties including time spent in training and readiness activities as emergency work similarly performed by Attack Warning Officers, as described in Digest Article 12-01.  However, OPM’s Digest Articles contain summaries of appeal decisions and interpretive opinions that provide clarifying guidance to ensure consistency of interpretation of classification standards and guides in force at the time.  They do not supersede or supplement classification standards and do not constitute case law.  Care must be exercised in interpreting and applying Digest Articles.  After careful consideration, we found the situation described in Digest Article 12-01 inapplicable to the appellant’s position.  As discussed later in this appeal decision, the appellant does not perform fire suppression work on the “irregular, nonrecurring, emergency basis” described by Digest Article 12-01. 

Instead, we found that the appellant spends 20 percent or less of his overall work time performing fire suppression and not within the context described for Attack Warning Officers in Digest Article 12-01.  Consequently, that work does not constitute a “major duty” as defined in the Introduction and does not impact the classification of the position.  This activity is performed on an irregular and nonrecurring basis mostly involving participating in supporting type 1 through type 4 fires not in a front-line fire suppression capacity.  However, fire prevention work (e.g., fire patrolling, fire inspections, fire safety, and fire education) comprises approximately 70 percent of the appellant’s overall work and is considered the major duty of the position.

This contrasts with firefighter positions whose sole purpose is fighting fires irrespective of the actual time spent on that work.  We found the paramount knowledge of the appellant’s position is to perform the primary duties of a Forestry Technician, GS-0462, position.  Like GS-0462 positions, the appellant applies a practical knowledge of the methods and techniques of forestry and in the scientific management and protection of the forest, including fire prevention.  We thus compared the appellant’s typical fire suppression work to grading criteria applicable to a GS-0462 position rather than to the concept described in Digest Article 12-01.

Position information

The mission of the FS is to sustain the health, diversity, and productivity of the nation’s forests and grasslands for present and future generations.  The appellant’s position is assigned to the Monterey Ranger District, which is one of five ranger districts in the forest.  The forest encompasses approximately 1.75 million acres of central California, including the San Francisco Bay area, the greater Los Angeles metropolitan area, the southern San Joaquin Valley, and Big Sur.  The ecosystems range from semi-desert in interior areas to redwood forests on the coast.  The forest features mountains, streams, rivers, and beaches and recreational opportunities including bicycling, camping, fishing, hiking, and hunting. 

The appellant participates in developing the district’s fire prevention plan.  He posts signage throughout the district including such information as the current fire danger level and whether campfires are allowed.  The appellant attends meetings with such cooperators as the local sheriff and business owners, to explain issues such as why dead trees are being cut down and brush is being burned to eliminate fuel for fires within the district.  He serves as one of the trainers for the Wildfire Origin and Cause Determination course providing instruction in burn pattern analysis, which uses a systematic approach to determine the origin and cause of fires.  The course is taught once or twice a year.  The appellant participates with other technicians in visiting local schools to educate preschool and elementary school children in fire prevention safety.  The program includes explaining/demonstrating fire safety precautions and explaining how a fire engine works.  He may also attend local fairs and parades to promote fire safety and prevention measures.  In the last year, he volunteered to schedule repairs for an old lookout tower making it operational.  From May through November each year, the appellant schedules and trains volunteers from the local Forest Fire Lookout Association to visually search for wildfires and to notify the appropriate personnel of the location of smoke.  He conducts inspections of various sites to include electronic sites (e.g., radio tower), camp sites, and resorts (e.g., Ventana Resort).  If he finds hazardous conditions, he notifies the appropriate personnel of his findings and explains the governing laws and regulations.  The appellant participates in following prescribed burn treatments to reduce the potential of wildfires in the future.  He also participates in implementing the district’s pre-attack plan, which includes maintaining the trees around the radio tower.

The appellant patrols the district for signs of wildland fires and/or is dispatched to such fires.  He performs initial attack to prevent further extension of the fire by laying the fire hose and pumping water and/or constructing a fire line using hand tools (e.g., shovels and pulaskis) and chainsaws to create a zone that the fire cannot jump and keep vegetation from burning.  He is qualified to assume the role of incident commander (IC) for Type 4 fires.  These types of fires are a lower level of complexity fire and are usually suppressed in one day.  They include using local resources, involving one or more firefighting teams, possibly using emergency medical services and/or law enforcement, but no written incident action plan is required.  However, he may relinquish the role of IC if the fire escalates beyond a Type 4.  In that case, an individual qualified to suppress a fire at the level the fire has escalated to would be brought in to relieve the appellant. The appellant participates in suppressing higher level complexity fires (i.e., Type 1 through Type 3) but not in a front-line fire suppression capacity (e.g., wildland fire investigator or investigation team member).  He serves as a fire suppression module leader as needed, overseeing a crew of no less than six technicians.  The appellant receives a briefing from the incident commander and ensures the instructions are carried out and the fire is fought safely and efficiently within established safety standards.  He serves in other positions as qualified and assigned, to include task force leader.  He participates in implementing the forest’s fuel brake strategy by serving as one of the liaisons between the FS and California Fire.  The appellant provides input to the Fuels Officer about where to place fuel brakes based on his knowledge of the district.

As a Forest Protection Officer, the appellant patrols the district for illegal activity (e.g., illegal off highway vehicle use and trespassing) and accidents, conducts spark arrester inspections of equipment (e.g., lawn mowers and chain saws), and issues citations and permits to forest visitors and private entities (e.g., welding and camping).  He requests law enforcement assistance as needed and serves as a Government witness in criminal proceedings as required.  As a qualified Wildland Fire Investigator, the appellant investigates fires on forest land by identifying, collecting, preserving, and examining evidence, such as witness statements, weather conditions, and items of potential physical evidence, to determine their origin and cause.  He also investigates tort claim incidents involving insurance claims (e.g., power lines fall on a visitor’s motor vehicle).  The appellant prepares reports to include case reports and investigation reports such as origin and cause reports.  He also serves as an arson investigation team member as needed.

Both the appellant and his immediate supervisor certified the accuracy of the duties described in his PD number R50077.  However, we found the position no longer manages the day-to-day operation of the district’s fire prevention program in the absence of the position’s supervisor.  Since the current supervisor began, the program is managed by another supervisor in his absence.  Contrary to the PD, mining operations, and gas and oil wells are not located in the district and service contracts and timber sale contracts have not been issued since the current supervisor has been with the district.  The position does not “supervise” the fire detection system but oversees it.  In addition, the discussion of Factor 8, Physical Demands, is overstated.  Therefore, the appellant’s PD does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise the PD to reflect our findings.

In reaching our classification decision, we have carefully reviewed all information provided by the appellant and his agency including his official PD which, although not completely accurate, we have incorporated by reference into this decision.  In addition, to help decide the appeal we conducted separate telephone interviews with the appellant, his immediate supervisor, and his second-level supervisor.

Series, title, and standard determination

The agency classified the appellant’s position in the Forestry Technician Series, GS-0462, using the basic title of Forestry Technician.  The Position Classification Flysheet (flysheet) for Forestry Technician, GS-0462, allows agencies to supplement the basic title by adding a parenthetical suffix title to identify duties and responsibilities that reflect specific knowledge and skills required in the work.  Therefore, the agency added the parenthetical title of “Prevention” to the basic title of the position  The flysheet for the GS-0462 series states the criteria for determining the grade of GS-0462 positions are contained in the Grade Level Guide (GLG) for Aid and Technical Work in the Biological Sciences Series, GS-0400.  The appellant does not disagree with the agency’s title, series and standard determination and we concur.  Addition of a parenthetical title is as the discretion of the agency.  Our evaluation of the grade of the position by application of the grading criteria in the GS-0400 GLG follows. 

Grade determination

The GS-0400 GLG uses the Factor Evaluation System (FES), which employs nine factors.  Under the FES, each factor-level description in the GLG describes the minimum characteristics needed to receive credit for the described level.  Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at 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 respects and still not be credited at a higher level.  Each factor level has a corresponding point value.  The total points assigned are converted to a grade by use of the grade conversion table in the GS-0400 GLG.

The appellant disagrees with his agency’s assignment of Level 3-2 for Factor 3, Guidelines; Level b for Factor 7, Purpose of Contacts; and Level 9-2 for Factor 9, Work Environment.  The appellant agrees with his agency’s assignment of Factor Level 1-5 for Factor 1, Knowledge Required by the Position; Level 2-3 for Factor 2, Supervisory Controls; Level 4-3 for Factor 4, Complexity; Level 5-2 for Factor 5, Scope and Effect; Level 6-2 for Factor 6, Personal Contacts; and Level 8-3 for Factor 8, Physical Demands.  We note that through his representative, the appellant initially disagreed with his agency’s assignment of Level 6-2 believing it warranted Level 6-3.  However, the designated representative subsequently informed OPM that upon further review the appellant agreed that Level 6-2 was appropriate.  While we agree with the agency’s factor level assignments for Factors 1, 2, 4, and 6, we do not concur with the agency’s assignment of Level 5-2 for Factor 5, Scope and Effect, and Level 8-3 for Factor 8, Physical Demands.  Therefore, we have confined our analysis to Factors 3, 5, 7, 8, and 9.

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment needed to apply them.

At Level 3-2, procedures for doing the work have been established and a number of specific guidelines are applicable.  Guides may range from complex, standardized, codified regulations, (such as Federal or agency manuals with agency, regional, or other supplements) to maps, blueprints, standing operating procedures, oral instructions, equipment or instrument manuals, or standard scientific or technical texts.  The employee must use judgment in selecting the appropriate guideline because of the number, similarity, linkage, and overlapping nature of the guides.  The guidelines contain criteria to solve the core question or problem contained in the assignments, though the applicability may not be readily apparent, i.e., the guides often require careful study and cross referencing.

At Level 3-3, the technician works with new requirements or applications for which only general guidelines are available or with assignments where the most applicable guides are limited to general functional statements and/or work samples which are not always directly related to the core problem of the assignments, have gaps in specificity, or are otherwise not completely applicable.  The employee exercises judgment independently in applying the guidelines or extending their applicability to situations not specifically covered; uses guidelines as the basis for making procedural deviations from established administrative and/or technical methods; or otherwise adapts guidelines when judgment is exercised based on an understanding of the intent of the guidelines and reacting accordingly.

Level 3-2 is met.  Like this level, the appellant uses numerous established guidelines, procedures, and techniques including, but not limited to, the Incident Response Pocket Guide, Region 5 Law Enforcement Field Guide, Fire Line Handbook, Land Regulations Plan, Fire Prevention Field Guide, Federal regulations, and forest and district fire prevention plans, which provide clear precedent and are directly applicable to the problems and issues the appellant typically encounters.  Like Level 3-2, the appellant’s guidelines are generally adequate to fit the situation.  He exercises judgment based on knowledge, experience, and training in selecting the appropriate guideline and applying it to a problem or situation.  He may make minor deviations within the confines of existing guidelines to address unique aspects of problems and issues encountered. 

Level 3-3 is not met.  Unlike this level, reference materials, manuals, and standard operating procedures are numerous, easily accessed by the appellant, and directly applicable to the majority of his wildland fire management work.  Like Level 3-2, the guidelines are directly related and more specific to the work performed.  Therefore, the appellant’s guidelines do not meet the description of guidelines described at Level 3-3, which regularly requires the employee to make decisions based on guidance which is not directly applicable.  Although some guidelines associated with the appellant’s work may have gaps in specificity, he is required to consult with a higher-level official or the official in charge of the scene before addressing problems and issues not clearly covered by existing guidelines.  The responsibility for making decisions regarding guidelines with gaps in specificity rests at a higher organizational level.  Unlike Level 3-3, guidelines are available for nearly all areas of the appellant’s work and do not require him to make procedural deviations from established methods or deviate from guidelines typical of Level 3-3. 

This factor is credited at Level 3-2 and 125 points are assigned.

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work, and the effect of the work products or services both within and outside the organization.

At Level 5-2, the work involves execution of specific rules, regulations, or procedures, such as those found in common technical manuals, laboratory handbooks, and administrative manuals.  Typically, completed assignments constitute a complete segment of assignments with broader scope, e.g., on a day-to-day basis runs a visitor’s center or collects data for use by others involved in research, administrative planning, or program/project operations.  Work products affect the accuracy, reliability, or acceptability of further procedures, processes or services, e.g., the ability of the scientist to complete with accuracy a phase of the research process; the ability of the planner to complete significant aspects of an annual work plan or a major project; or the quality of day-to-day operations of a significant program in an ongoing production environment.

At Level 5-3, the work involves applying conventional technical and administrative solutions and practices to a variety of problems.  In research environments a major consideration for performing the work is to be closely involved in almost all phases of the scientist's study and have responsibility for selected phases or to conduct test applications of scientific and technical theories when the methods, techniques, and procedures are clearly outlined.  In other situations, a major consideration for performing the work is to insure that established operations criteria, rules, or methods are adhered to in a production environment.  For example, the employee may have responsibility for the ongoing operation of a field site or for execution of a standardized project or program area cited in an annual or comparable work plan as a performance objective for the organization.  Work products directly affect the design and execution of experiments; the operation of systems, programs, or equipment systems; or the adequacy of such activities as long-range work plans, field investigations, testing operations, or research conclusions.

The appellant’s position exceeds Level 5-2 and meets Level 5-3.  Similar to this level, his work involves adhering to established operations, criteria, rules, and conventional methods and solutions while performing fire prevention activities.  When the appellant serves as a wildland fire origin and cause investigator, he uses established investigation methods and techniques to determine the origin and cause of the fires to which he is assigned.  This process includes collecting data about the fire (e.g., fire behavior conditions, interviewing witnesses, and collecting physical evidence and the results of scientific testing), analyzing the collected data, developing a hypothesis based on the data analysis, testing the hypothesis by comparing it against all the known facts about the fire, and selecting the hypothesis that best explains the known facts surrounding the origin of the fire.  He then follows agency policy in documenting his findings in origin and cause reports before submitting them for review.  The appellant assists with implementing the forest’s fuel brake strategy by removing or reducing flammable materials a fire uses as fuel to intensify and/or spread by following the developed prescription plan.  He also investigates tort claim incidents, serves as a burn pattern analysis trainer, and conducts spark arrester and site inspections in accordance with established methods and procedures.

Similar to Level 5-3, the appellant’s work has an impact on the effectiveness of the forest’s wildland fire management program, goals, and objectives.  He participates in carrying out prescribed burns to thin the forest, which prevents fires and improves the health of the forest.  He also works with State and local agencies and the general public on increasing their awareness of and explaining ways they can participate in preventing fires in the future based on established FS procedures and requirements.

This factor is credited at Level 5-3 and 150 points are assigned.

Factor 7, Purpose of contacts

Levels described under Factor 6, Personal Contacts and Factor 7, Purpose of Contacts 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.  These factors are interdependent.  The appropriate level for personal contacts and the corresponding level for purpose of contacts are determined by applying the point assignment chart for Factors 6 and 7.  Factor 7 is disputed and addressed below.

At Level 7-b, the purpose of personal contacts is to:  plan and coordinate work efforts; explain the need to adhere to laws, rules, contract, or lease provisions; discuss inspected work and contract requirements when monitoring activity of contractors; discuss technical requirements of equipment with manufacturers and resolve problems concerning the work or the peculiar needs of the organization; interpret data obtained and explain its purpose and significance; or reach agreement on operating problems such as recurring submission of inaccurate, untimely, incomplete or irrelevant data.  The persons contacted are usually working toward a common goal and generally are reasonably cooperative.  At this level, some technicians may be required to deliver information, such as how data were obtained and their opinion as to its accuracy, in court.

At Level 7-c, the purpose is to influence, motivate, interrogate, or control persons or groups.  For example, the purpose of the contacts is to:  (1) influence others who are knowledgeable about the work to adopt, within the organization, methods about which there are conflicting opinions among those in the line of work;  (2) persuade others, such as suspicious and reluctant landowners, to participate in projects or organizational objectives when there is no requirement for doing so;  (3) persuade technical and administrative personnel from outside the government to submit the information desired for a study and to persuade these same representatives of the need for additional information when there is no official or legal basis for requiring submission of the information and there are conflicts with the party(s) involved; and/or (4) gaining compliance with established policies and regulations by persuasion or negotiation.  In any case, the persons contacted are characteristically fearful, skeptical, or uncooperative, and skill must be used in the approach made to obtain the desired results.

Level 7-b is met.  Similar to this level, the purpose of the appellant’s contacts is to plan and coordinate with Federal, State, and local groups and individuals to preserve forest resources and the prevention and suppression of fires.  The majority of his contacts are comparable to those described at Level 7-b where the persons contacted are usually working toward a common goal and are reasonably cooperative.  For example, the appellant educates and informs groups and individuals concerning prevention guidelines and procedures; attends meetings with forest cooperators to discuss prevention actions being taken within the district; explains FS rules to members of the public who use the forest’s recreational facilities; and conducts inspections of various forest sites.

Level 7-c is not met.  Unlike this level, the purpose of the appellant’s contacts is not to influence, motivate, interrogate, or control the persons or groups contacted.  His contacts do not require that he persuade or negotiate with others who may be suspicious or uncooperative to follow FS requirements and comply with established policies and regulations.  Our fact-finding disclosed that when the appellant’s contacts are hostile or uncooperative, he is required to immediately contact the local dispatch center which responds by sending law enforcement personnel and/or a fire engine to the scene.  Like Level 7-b, the appellant’s regular and recurring contacts are with groups and individuals who support the goal of preserving forest resources and are generally cooperative.

As stated above, the appellant did not disagree with the agency’s evaluation of Factor 6 at Level 6-2.  Therefore, these combined factors are credited at Level 6-2 and 7-b and 75 points are assigned.

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.

At Level 8-2, the work requires some physical exertion, such as regular and recurring running, walking, or bending; walking or climbing over rocky areas, through plowed fields or other uneven surfaces, through dense vegetation, and in mountainous terrain;  or climbing ladders or scaffolds to observe, collect, or record research data.  In many situations the duration of the activity (such as most of a workday) contributes to the arduous nature of the job.  In other situations, such as in a laboratory, there may be special requirements for agility or dexterity such as exceptional hand/eye coordination.

At Level 8-3. the work requires regular and protracted periods of considerable and strenuous physical exertion such as carrying or lifting heavy objects (over 50 pounds); hacking passages through dense vegetation; or climbing ladders or scaffolds carrying heavy equipment used to install, maintain, or repair research installations.

Level 8-2 is met.  Like this level, the appellant spends the majority of his time performing work requiring regular physical exertion.  For example, he stands and walks over rough terrain during foot patrols; uses hand tools such as shovels, chain saws, and pulaskis to construct fire lines; and lays hoses and pumps water to create a zone that the fire cannot jump to protect vegetation.  On a regular and recurring basis, the appellant’s backpack weighs 45 pounds or less and includes a fire line shelter, first aid kit, water, food, a radio, and his fire safety equipment such as gloves, eye and ear protection, Nomex pants and shirt, and boots.  He also has access to additional supplies, tools and equipment located in his patrol truck for suppressing fires.  The appellant carries what he needs to the site and works with each item in turn.

Level 8-3 is not met.  The record shows the appellant sometimes experiences exposure to hazards, such as high temperatures, smoke and fumes, falling trees, and rocks when participating in suppressing higher level complexity fires (i.e., Type 1 through Type 3).  However, when participating in these fires it is not in a front-line fire suppression capacity.  He has primarily served in the roles of wildland fire investigator or investigation team member, IC for a Type 4 fire, and a low complexity burn pile.  The appellant has also participated as a trainee in learning how to direct assigned resources in fighting a fire in his division’s area and directing the operators of two pieces of heavy equipment on how best to suppress a fire.  Unlike Level 8-3, due to the limitations of his fire-fighting assignments, and the proximity of his patrol truck for storing unused equipment, he does not lift heavy objects weighing over 50 pounds.  Therefore, the physical demands of his work do not regularly require strenuous physical exertion or exposure to the extreme conditions described at Level 8-3. 

This factor is credited at Level 8-2 and 20 points are assigned.

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.

At Level 9-2, the work involves regular and recurring moderate risks or discomforts which require special safety precautions, e.g., working around moving parts, carts, or machines; with contagious diseases or irritant chemicals; in a logging or construction site; or performing routine patrol work.  For other positions the work may, on a regular and recurring basis, require working outdoors, in meat lockers or other such environments with extreme temperatures, and/or exposure to adverse weather conditions.  At this level, employees are required to use protective clothing or gear such as hard hats, masks, gowns, ear plugs, coats, boots, goggles, gloves, or shields to moderate risks, or to follow procedures for minimizing risk.

At Level 9-3. the work environment involves high risks with regular and recurring exposure to potentially dangerous situations or unusual environmental stress where high risk factors exist which cannot be reasonably controlled.  For example, working at great heights under extreme weather conditions, or working closely with toxins or dangerous pests or animals such as poisonous snakes, where safety precautions cannot completely eliminate the danger.

Level 9-2 is met.  Like this level, the majority of the appellant’s work involves regular moderate risks and discomforts requiring special safety precautions.  He spends approximately70 percent of his time performing fire prevention duties and 20 percent suppressing wildland fires, not in a front-line fire suppression capacity, in work environments including high and low temperatures, high winds, rain, snow, dust, fumes and smoke, rocky inclines, and boggy ground.  Similar to this level, the appellant regularly follows special safety precautions detailed in numerous FS guidelines and procedures.  His fire suppression work routinely requires use of personal protective equipment such as Nomex pants and shirts, breathing apparatus, boots, gloves, and eye protection. 

Level 9-3 is not met.  Unlike this level, the appellant’s work environment does not regularly involve situations where high risk factors exist which cannot be reasonably controlled.  Although he experiences extremes in temperatures, rough and uneven terrain, and poor air quality, no more than 20 percent of the appellant’s time is spent performing fire suppression duties.  Also, the fire suppression incidents involve environments not in a front-line suppression capacity.  Comparable to Level 9-2, the record shows the appellant’s safety equipment is sufficient to keep him safe.  Therefore, Level 9-3 is not representative of the appellant’s typical work environment.

This factor is credited at Level 9-2 and 20 points are assigned.

Summary
Factors	Level	Points
1. Knowledge required by the position	1-5	750
2. Supervisory controls	2-3	275
3. Guidelines	3-2	125
4. Complexity	4-3	150
5. Scope and effect	5-3	150
6. & 7. Personal contacts/Purpose of contacts	2b	75
8. Physical demands	8-2	20
9. Work environment	9-2	20
Total		1,565

The total of 1565 points falls within the GS-07 point-range (1355-1600) on the grade conversion table in the GS-0400 GLG.  Therefore, the appellant’s position is properly graded at the GS-07 level.

Decision

The appellant’s position is properly classified as Forestry Technician, GS-0462-07.  Parenthetical title is at agency discretion.

 

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