Washington, DC

U.S. Office of Personnel Management
Pay Category Appeal Decision
Under section 5103 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


10/29/2020

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which 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 job description (JD) does not meet the standard of adequacy described in Federal Wage System-Appropriated Fund Operating Manual, Subchapter S6-6.d. Since JDs must meet the standard of adequacy, the agency must revise the appellant’s JD to reflect our findings. The servicing human resources office must submit the corrected JD within 30 days of the date of this decision to the U.S. Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.

Introduction

The appellant’s job is currently graded in the Federal Wage System (FWS) as an Electronics Mechanic Training Leader, WL 2604-11, but the appellant believes it should be classified in the General Schedule (GS) to the Training Instruction Series, GS-1712, at the GS-11 level. The appellant is assigned to the Avionics/Escape and Safety Branch, Industrial Execution Department, Production Trades Division, Fleet Readiness Center Southeast (FRCSE), Naval Air Station (NAS) – Jacksonville, U.S. Department of the Navy (Navy) in Jacksonville, Florida. We have accepted and decided this appeal under section 5103 of title 5, United States Code (U.S.C.).

General Issues

The appellant believes his job is appropriate for inclusion in the GS because his primary duty is to conduct training principally for civilian personnel (both FWS and GS) students in a classroom and not to artisans in a production shop. Further, he states he does not provide informal or on-the-job training and his position does not require knowledge of electronics, but rather knowledge of the methods and techniques of instruction and the subject matter being taught like positions classified in the Training Instruction Series, GS-1712. In support of this argument, he compares his job to GS-1712-11 positions at another command within his organization, stating the incumbents of those positions provide the same type of training as his job. In adjudicating this appeal, our only concern is to make our own independent decision on the proper pay category of the appellant’s job. By law, we must determine the proper pay category by comparing the appellant’s duties and responsibilities to OPM standards and guidelines (5 U.S.C. 5103, 5106, 5107). Since comparison to OPM standards and guidelines is the exclusive method for classifying jobs/positions, we cannot compare the appellant’s job to others that may or may not have been placed in the proper pay category as a basis for deciding his appeal. Therefore, we have considered the appellant’s statements only insofar as they are relevant to making that comparison.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines. However, the agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers his job so similar to others that they all warrant the same classification, he may pursue the matter by writing to his agency’s human resources headquarters 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 job and the others.

The appellant believes his JD number 12484 is inaccurate because it describes duties he does not perform and knowledges he does not use when conducting training. Specifically, he states he does not provide “informal” or “on-the-job training” and that his job does not require “knowledge of an Electronics Mechanic” to perform his work as stated in his JD. However, the appellant’s supervisor at the time of the appeal certified to the accuracy of the JD. In addition, his current supervisor agreed with the accuracy of the JD, with the exception that the appellant is not currently involved in scheduling courses and does not design course curriculum materials. A JD is the official record of the major duties and responsibilities assigned to a job by an official with the authority to assign work. A job is the work made up of the duties and responsibilities performed by an employee. Pay category appeal regulations permit OPM to investigate or audit a job and decide an appeal on the basis of the actual duties and responsibilities assigned by management and performed by the employee. An OPM appeal decision classifies a real operating job and not simply the JD. Therefore, our decision is based on the actual work assigned to and performed by the appellant.

The appellant states that his responsibility for providing training in Electrostatic Discharge (ESD) was removed from his JD in 2016 (i.e., pen and ink deletion on JD). Nevertheless, he asserts that in 2019 he continued to conduct the training but this is not reflected in his JD. The ESD course is a half-day course covering measures to be taken by all personnel who handle, package, transport, inspect, repair, test, operate, and otherwise maintain items susceptible to damage from ESD. Trainees in this course can include those in both WG and GS occupations including supervisory positions (e.g., GS or WG supervisors, quality assurance specialists, supply, electronic and engineering technicians). Our fact-finding shows, as confirmed by management, that the appellant is no longer assigned, scheduled or has responsibility to conduct the half-day course in ESD. ESD program functions were transferred to a different division. However, training in ESD is also incorporated in the Miniature/Microminiature (2M) courses taught by the appellant.

Our review disclosed that the appellant’s JD is not completely accurate. Specifically, the appellant is not assigned to the Instrument Electronics and Electro-Optics Branch of the Avionics Division, and he does not “work under the administrative direction of the Instrument Electronics and Electro-Optics Branch Head,” as stated in his JD. The appellant is not responsible for “establishing course prerequisite criteria insuring proper placement of trainees.” This responsibility is vested to program training coordinators. While the appellant notifies the Quality Assurance Department on the certification levels of employees who satisfactorily complete his courses, he is not responsible to “ensure a viable certification program.” While the appellant may create specific operating procedures for processes used in repair and maintenance, this does not involve designing, redesigning, evaluating and perfecting “new internal training processes and equipment for repairing of electronic equipment assemblies and components.” While the appellant customizes lesson plans by drawing from his knowledge and experience in electronics, he does not “develop outlines, lesson plans, written tests, grading criteria, and construction of visual aids such as slides, overhead transparencies, and cut away models of sample hardware.” Furthermore, while he may be asked for and/or recommend updates or changes and submit photos for implementation into course curriculum, he is not responsible to “develop, modify and update the design of courses…” All course curricula and evaluation materials including modifications to curriculum are designed and provided to him by training program personnel at the Naval Surface Warfare Center in Crane, Indiana (NSWC Crane Division).

Furthermore, as stated by the appellant and confirmed during supervisory interviews, the appellant does not “train personnel in the repair of electronic modules.” Our fact-finding shows that repair of electronic modules is taught in a different course (i.e., Module Test and Repair Equipment Operator Course A-100-0076), not taught by the appellant. Therefore, the JD does not meet the standard of adequacy described in Federal Wage System-Appropriated Fund Operating Manual, Subchapter S6-6.d., and the agency must revise the JD to reflect our findings.

Job information

The Navy’s Fleet Readiness Centers (FRCs), with locations in the U.S. east and west coasts and in Japan, conduct maintenance, repair, and overhaul of U.S. Navy aircraft, engines, components and support equipment. The FRCSE is the largest tenant command aboard the NAS in Jacksonville, Florida, with several offsite locations. Its overall workload includes the rework of engines, components and ground support equipment, plus other support functions vital to the Fleet. The Production Trades Division of the FRCSE is responsible for the leadership and management of all production trades personnel arranged in a competency structure. It is responsible for personnel, processes, and training necessary to accomplish the mission and enable its personnel in various trades to accomplish their work. The record shows the appellant is assigned to the Avionics/Escape and Safety Branch of the Production Trades Division, which is responsible for the development, training, discipline, awards, mentoring, career-path development, and brokering to Integrated Product Teams all Avionics and other Escape and Safety systems mechanics. The branch also manages and coordinates with the trade capability across the FRC enterprise and is responsible for all trade specific processes used by the artisans in applying their skill.

The appellant provides training for the 2M Module Test and Repair (MTR) Program headed by the NAVSEA 2M/MTR Program Manager. The 2M/MTR Program is a formal training program that supports testing and repair of circuit card assemblies (CCAs) and electronic modules (EM) at the Fleet. The program covers all phases of miniature and microminiature repair divided into two distinct capability levels: Miniature Electronic Repair and Microminiature Electronic Repair. Miniature component repair involves discrete components (e.g., semiconductors, resistors, capacitors) and single-and double-sided printed circuit boards, including removal and installation of integrated circuit components. Microminiature component repair consists of repairs to complex multilayer printed circuit boards, including flex print conductor removal and replacement and other repair procedures.

The appellant provides regular and recurring training in the following courses: Miniature Electronics Repair, A-100-0072 (four-week course); Microminiature Electronics Repair, A-100-0073 (two-week course); 2M Technician Recertifier A-100-0058 (one-week course); and a Basic Solder (an FRCSE three-day course). As needed and scheduled, he may also provide 2M Technician Recertifier Requalification (five-day course) A-100-0144; 2M Instructor Initial Skills A-100-0135 (two-week course); 2M Instructor Certification/ Recertification A-012-0077 (one-week course). Trainees primarily include civilian electrical and electronics mechanics, but may also include other trades mechanics (e.g. aircraft and instrument mechanics), electronic or engineering technicians, and occasionally active duty military whose duties require soldering skills. The ratio in the 2M courses is four trainees to one trainer with generally eight trainees with two trainers in each session. The Basic Solder FRCSE three-day course is generally given to electricians who perform repairs and need to learn how to solder. The class also has a ratio of four trainees to one trainer. To be certified as a 2M Instructor, the appellant must complete the following courses: Instructor Pipeline Course, Instructor Training, and the Miniature Electronics Repair and Micro-miniature Electronic Repairs courses and maintain certifications to conduct 2M training. Additionally, he is evaluated by a 2M Inspector and must satisfactorily instruct each lesson topic and demonstration in either the Miniature Electronics Repair Course or the Microminiature Electronics Repair Course to keep his instructor certification. The appellant conducts training in a classroom located in Hangar 1000 within the NAS. The classroom is equipped with workstations with proper ESD protection installed and includes specialized electrical and mechanical units such as 2M power units which provide electrical and mechanical power for operating various handpieces such as soldering irons and solder extractors. Other equipment and tools used to perform the training work includes but is not limited to pulse heated devices, resistance tweezers, thermal strippers, lap flow tools, fiber optic light sources with attaching light pipes, chisels, clamps, stereo zoom microscopes, and consumable materials such as isopropyl alcohol, epoxy, flux and others.

The appellant provides training through lectures and gives hands-on step-by-step demonstrations for all practical exercises assigned to the trainees and performed in the classroom. A significant portion of the training is concurrent with the trainees working individually on different aspects of an electronics assembly repair procedure with the appellant monitoring and checking their mandatory progress (i.e., completing a number of “graded steps” by the end of each week of training). The trainees are required to perform repair procedures individually to demonstrate their capabilities to perform quality repairs in accordance with the Naval Air Systems Command workmanship standards and maintenance practices for 2M electronic assembly repair. All course curricula are designed and provided to the appellant by training program headquarters personnel at NSWC Crane Division. The appellant administers quizzes and performance tests and evaluates progress of trainees by observing and checking completed procedures and reviewing test results. He is also responsible for establishing and maintaining tools, equipment, consumable inventory and maintenance of classroom equipment. Further, as requested the appellant coordinates with production supervisors to solve electronic technical repair problems encountered, and checks equipment and tools in production shops to ensure appropriate tools are available and operating properly.

In reaching our pay category decision, we carefully considered all information provided by the appellant and his agency including his official JD which, although not completely accurate, contains the major duties and responsibilities assigned to and performed by the appellant and is adequate for classification purposes. Thus, we incorporate it by reference into this decision. In addition, to help decide the appeal, we conducted separate telephone interviews with the appellant and his current and former supervisors (Electronics Mechanics Supervisors I, WS-2604-11).

Pay category determination

Section 5102(c)(7) of title 5, U.S.C., exempts from the GS employees in recognized trades or crafts, or other skilled mechanical crafts, or unskilled, semiskilled, or skilled manual labor occupations, and other employees in positions having trade, craft, or laboring experience and knowledge as the paramount requirement. The Introduction defines paramount requirement as the essential, prerequisite knowledge, skills, and abilities needed to perform the primary duty or responsibility for which the position has been established. Whether a position is in a trades, craft, or manual labor occupation within the meaning of title 5 depends primarily on the duties, responsibilities, and qualification requirements, i.e., the most important, or chief, requirement for the performance of a primary duty or responsibility for which the position exists. If a position clearly requires trades, craft, or laboring experience and knowledge as a requirement for performance of its primary duty, and this requirement is paramount, the position is under the FWS regardless of its organizational location or the nature of the activity in which it exists. However, a position is subject to the GS, even if it requires physical work, if its primary duty requires knowledge or experience of an administrative, clerical, scientific, artistic, or technical nature not related to trades, craft, or manual-labor work.

The appellant’s primary duties and paramount trades and crafts knowledge flow from the mission, function, and services provided by the organization in which he works; the occupational makeup and purpose of the organization, and management’s intent in establishing the job. The record shows the nature, purpose, and composition of the appellant’s organization is to provide trades and crafts training and services in electronics repair and measurement. His unit provides training in electronic component repair techniques and assembly procedures and is solely staffed with jobs coded to the Electronic Equipment Installation and Maintenance Family, 2600, particularly Electronics Mechanic, 2604. Moreover, based on review of the appellant’s organization it is clearly management’s intent to establish only trades and crafts jobs. As stated in the appellant’s JD (and confirmed by the appellant and his current and former supervisors), the appellant’s duties involve training and certifying primarily electrical and electronics mechanics required to solder for making repairs at three levels: Level “D” involving basic soldering for terminals and wires; Level 2M miniature electronic repair involving discrete components, integrated circuits, printed circuit board conductor and laminate repair; and Level 2M micro-miniature electronic repair involving plastic lighted panel repair, welded lead component repair, pin grid array repair, surface mounted component repair, multi-layer conducted printed circuit board and flexible laminate conductor repairs. The performance of such repairs to keep electronic assemblies, components, equipment and/or systems in reliable operation are characteristically trade functions requiring paramount knowledge of a trades occupation. Our fact-finding shows the appellant primarily provides electronic repair training to employees engaged in trades or crafts, but also provides training to GS technicians (e.g., electrical or engineering technicians) if their positions require learning the trade skill of soldering.

To perform the training work, the appellant must have knowledge of operating electronic principles and practices to be able to recognize types and sizes of resistors, capacitors, wiring and circuits, locate malfunctioning components (e.g., conductor damage may be located by point-to-point continuity testing) and verify operability of the CCA (e.g., using a multimeter or oscilloscope when applicable) once the removal and replacement of the component and soldering has been completed. He must have the skill to apply a variety of technical information such as specifications and standards found in technical and manufacturer manuals for repair of electronic assemblies, components and/or equipment. He must have skills in the use of specialized handpieces and tools such as microchine rotary drills, wrenches, soldering irons, micro soldering units, thermal strippers to remove and replace circuit parts where accurate positioning, appearance, mechanical strength and electrical and heat effects are important. For example, a procedure described by the appellant involves the repair of an electrical component such as a resistor, requiring him to demonstrate how to: clean the component using appropriate chemicals; orient/position the component; form the component by bending it to a certain degree and using special forming tools; mount the component before soldering; grading the procedure and conducting visual inspection and/or using a multimeter to ensure the component is repaired to prescribed operating standards and tolerances. Other electronic component related repair procedures include removal of conformal coating before soldering; applying component lead tinning procedures involving the identification of defective and target conditions needing repair; and laminate repair, surface patch procedures.

Based on the preceding discussion, certain aspects of the appellant’s work (i.e., specific methods for repair of electronic components) are similar to jobs coded to the Electronics Mechanic, 2604, occupational series. Such jobs involve work in fabrication, overhauling, modifying, installing, troubleshooting, repairing, and maintaining ground, airborne, and marine electronic equipment, such as: radio, radar, sonar, microwave, micro-computers and peripherals, and marine, aeronautical, and space navigation aids. Similar to the appellant’s job, the work requires knowledge of electronics principles; the ability to recognize what repair procedures must be applied and determine the best method to correct the defect; and the skill to disassemble, assemble, and use specialized electrical or mechanical tools and handpieces.

We find that the paramount knowledge and qualification requirements necessary to perform the work of the appellant’s job is not solely a combination of practical knowledge of the methods and techniques of instruction and practical knowledge of the subject-matter being taught as described in the Position Classification Flysheet for the Training Instruction Series, GS-1712, but rather skill and knowledge similar to that associated with Electronics Mechanic, 2604 jobs. Moreover, like the appellant’s job the FWS Job Grading Standard (JGS) for Leader WL/NL, Part II, recognizes and evaluates jobs engaged in trades and crafts who are assigned to act as Training Leaders typically conducting training sessions designed to update, improve, or upgrade the knowledge and skill of others engaged in the occupation for which the training is presented. As noted in the WL JGS, Training Leaders also must have, as a second requirement, practical knowledge of the methods and techniques of instruction which, as in the appellant’s case can be learned after placement in the job.

The appellant believes that because he presents training to employees in a classroom rather than in their production shops, he is not providing on-the-job training or bench related work and thus his job should be placed in the GS. However, the work of Training Leaders may include both on-the-job and classroom training. Moreover, our fact-finding disclosed that when training the appellant provides step-by-step demonstrations and instructions to trainees on various electronic assembly repair procedures at 2M workstations in the classroom specifically set up for the task presented, e.g., single and double-sided CCA soldering procedures. Therefore, while the appellant does not present training in production shops the work demonstrations simulate typical bench work provided by journey-level trades and crafts employees who train lower graded employees. Nevertheless, pay category determinations are not decided on whether the work is performed in a classroom or production shop, but rather on the paramount knowledge, skills, and abilities required to perform the primary duties of the position.

In order for the appellant’s job to be covered under the GS, the paramount knowledge to perform the primary duties of the position must be of an administrative, clerical, scientific, artistic, or technical nature. However, we find that the appellant’s work clearly requires trades and crafts knowledge and ability (i.e., similar to Electronics Mechanic, 2604) as a requirement for performance of its primary duty, and this requirement is paramount. Therefore, the appellant’s job is covered by the FWS.

Decision

The appellant’s job is properly covered by the FWS.

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