Washington, DC

U.S. Office of Personnel Management
Job Grading Appeal Decision
Under section 5346 of title 5, United States Code

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Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


07/15/2016

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Date

As provided in section S7-8 of the Operating Manual: Federal Wage System (FWS), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. There is no right of further appeal. This decision is subject to discretionary review only under conditions specified in section 532.705(f) of title 5, Code of Federal Regulations (address provided in the Introduction to the Position Classification Standards, appendix 4, section H).

Since the decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 532.705(d). The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, must be followed in implementing the decision. If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented. The servicing human resources office must submit a compliance report containing the corrected job description (JD) that meets the standard of adequacy described in Federal Wage System-Appropriated Fund Operating Manual, Subchapter S6-6d, reflecting our findings 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 U.S. Office of Personnel Management (OPM) office that adjudicated this appeal.

Introduction

On January 11, 2016, OPM’s Agency Compliance and Evaluation (ACE), Philadelphia office, accepted a job grading appeal from Ms. Frances A. Batchelder. On February 18, 2016, we received the agency’s complete administrative report. The appellant works in the Pipe Shop, Production Resources Department, Portsmouth Naval Shipyard, Department of the Navy, in Portsmouth, New Hampshire. The appellant’s job is currently graded as Tools and Parts Attendant, WG-6904-6. She believes her job should be graded as Toolroom Mechanic,
WG-4840-8. We have accepted and decided this appeal under the provisions of section 5346
of title 5, United States Code (U.S.C.).

General issues

The appellant filed this job grading appeal with OPM because she was dissatisfied with the appeal decision issued by the Department of Defense Civilian Personnel Advisory Service that sustained the agency’s current grading of her job. The appellant believes the decision is erroneous because it did not consider the duties of cleaning and sanitizing respirators requiring the use of power tools as Toolroom Mechanic, WG-4840-8, work, even though the decision states the respirator duties were identified in the appellant’s JD (number 70215) as “maintains tools and equipment in serviceable condition.”

The appellant compares her position to WG-8 Toolroom Mechanic jobs assigned to her unit because she states the duty of cleaning respirators is and has been the responsibility of the Toolroom Mechanics. By law, we must make that decision solely by comparing her current duties and responsibilities to the appropriate job grading standards (JGS) (5 U.S.C. 5346) and have considered the appellant’s statements only insofar as they are relevant to making that comparison. Other jobs that appear superficially similar to a given job may involve work that is more complex or broader in scope that form the basis for the grade, or may be graded incorrectly. Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding her agency’s job grading review process is not germane to this decision.

The appellant’s job grading appeal identifies her JD as an “Employment Agreement with the Portsmouth Naval Shipyard.” Rather, the appellant’s JD is the official description of management’s assignment of major duties, responsibilities, and supervisory relationships of a given job. A JD is not an employment agreement since, by law, it is subject to change at agency management’s discretion. See 5 U.S.C. 302. All JDs include a statement signed by the immediate supervisor certifying to the accuracy of the JD.

The appellant believes she should receive WG-8 pay retroactive to July 2012. However, the U.S. Comptroller General states that an “. . . employee is entitled only to the salary of the position to which he is actually appointed, regardless of the duties performed. When an employee performs the duties of a higher grade level, no entitlement to the salary of the higher grade exists until such time as the individual is actually promoted . . .Consequently, backpay is not available as a remedy for misassignments to higher level duties or improper job classifications” (CG decision B-232695, December 15, 1989). Further, the Back Pay Act prohibits back pay for periods of misclassification. See 5 U.S.C. 5596(b)(3).

Job information

The appellant is responsible for tending tools, parts and equipment in a storage area which she also receives, identifies, and issues. Items include hand tools, electronic tools, pneumatic tools, extension cords, harnesses, respirators, etc. She obtains items from stock using item numbers, stores items within the general storage plan, and uses a locator file to identify where items are placed. The appellant maintains automated records of tools issued to and returned by customers. She searches the automated inventory by item number for items requested by the user that are not available in the storage area to determine if the items can be obtained from other storage areas. For the most part, customers know what item to request; however, if a customer’s request is vague, the appellant will ask the customer questions to narrow down the correct item needed, e.g. questions regarding the length of an extension cord, the type of needle for the pistol needle gun, etc. Once an item is issued to a customer, it is the customer shop’s responsibility to track overdue, missing, lost or stolen items and prepare the necessary paperwork for the appellant to update the automated system. The appellant visually inspects tools for readily identifiable signs of wear or defects to see if items should be sent for repair, e.g., the glass face of a gauge is cracked or if the needle is not on “0.” Additionally, customers advise her of items needing repair upon return or after issuance. An automated calibration report identifies what tools need to be sent for calibration. In addition, if the appellant notices a calibrated sticker is illegible or out of date, she sends the item for calibration.

The appellant cleans and sanitizes approximately five different types of respirators used by painters and sandblasters for reissuance. She performs these duties based on having attended a 3-4 hour on-the-job training course for cleaning and sanitizing respirators, followed up with refresher training every other year. The appellant wears protective clothing when cleaning and sanitizing the respirators. She immerses and cuts the bags of used respirators in a sink of water. She uses a power screw driver to remove the frames from the respirators before dismantling the rest of the respirators. After the respirators are dismantled, she scrubs the face shields and any other soiled pieces in the water. If items are too heavily soiled, she discards them. She then places the respirator pieces in mesh bags and places the mesh bags into a commercial washing machine with a pre-mixed cleaning solution. After the respirator pieces are washed, the appellant puts them on shelves in a dryer. When finished drying, she inspects the pieces in order to replace those that are damaged, e.g. cracked or ripped straps, scratched face shields, etc. She then reassembles the respirators; places the respirators in bags; heat seals the bags; and signs, dates and notates the sizes and model numbers of the respirators on the bags.

In reaching our job grading decision, we have carefully reviewed all information provided by the appellant and her agency, including her official JD and the amendment to the JD, dated December 5, 2013, which addresses her respirator cleaning and sanitizing duties. In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and her immediate supervisor.

Our findings disclosed the appellant’s official JD is not completely accurate. For example, she does not suggest, in the absence of requested items, other items that might fit users’ requirements or keep track of project-assigned items. Although not completely accurate, it covers the major duties and responsibilities she performs and we incorporate by reference into this decision.

Occupation, title, and JGS determination

The 6904 JGS covers work requiring knowledge of the kinds of tools, parts, and equipment in stock and how to locate them, and an ability to identify and issue specific items requested by customers. While she agrees she performs such duties, the appellant believes her work should be classified to the 4840 Tool and Equipment Repairing occupation based on her respirator cleaning and sanitizing duties. However, the appellant’s respirator cleaning and sanitizing duties are excluded from the 4840 occupation because work described in the 4840 occupation is not limited to cleaning and replacing simple parts on protective devices using an electric screwdriver. Rather, the 4840 occupation covers work requiring application of the breadth and depth of knowledge involved in maintaining, adjusting, sharpening, and repairing a variety of tools, safety equipment, and portable power equipment such as pipe wrenches, acetylene cutting torches, pneumatic hammers, hydraulic rivet guns, portable pumps, high-pressure airless spray guns, hand-held electric power tools, grinders, drills, cutters, chisels, picks, axes, shovels, mowing equipment, etc., that are issued from shop tool room and equipment areas to production and maintenance workers.

There are no published grading criteria for respirator cleaning and repair duties. Therefore, it is necessary to cross-reference to grading criteria in published JGSs covering occupations that have similar kinds of work in terms of work processes, functions, knowledge and skills, and entail a similar level of difficulty and responsibility in accordance with section II.B.1 of the Introduction. To evaluate the appellant’s respirator cleaning and repair duties, we have applied the grading criteria in the 3511 Laboratory Working JGS because the JGS covers work requiring ability to clean, prepare for sterilization, sterilize, and assemble laboratory and hospital glassware, instruments, and related items, which are sufficiently similar for cross- occupation comparison purposes. Additionally, the grade levels described in the 3511 JGS include hazards, physical hardships, and working conditions that are a regular and recurring part of the laboratory worker occupation involved in performing such work.

The appellant’s job involves work in two FWS occupations. Guidance in Section III of the Introduction to the FWS Job Grading System (Introduction) states jobs requiring the performance of two or more occupations are coded to the occupation which is most important for recruitment, selection, placement, promotion, or reduction in force purposes. The agency assigned the appellant’s job to the 6904 occupation and we concur, as this work represents the highest skill and knowledge requirements of the job, as discussed later in the decision and was the basis for recruitment and selection for the job.

Grade determination

The grade level of mixed jobs like the appellant’s is determined by identifying duties that (1) involve the highest skill and qualification requirements for the job, and (2) are a regular and recurring part of the job. Determination of the highest skill and qualification requirements is made through comparison of each type of work performed to the occupation's JGS.

JGSs use four factors to determine the grade level of a job: Skill and Knowledge, Responsibility, Physical Effort, and Working Conditions. These factors provide a framework within which the occupation is structured as well as specifically applicable criteria for evaluating the level of work. In order to warrant evaluation to a grade level, the job must meet the level described fully; i.e., it must meet the full intent of the whole job.

Evaluation using the 6904 JGS

Skill and Knowledge

At the grade 5 level, attendants demonstrate skill in verifying short, over, and damaged conditions of incoming stock by such means as opening, counting and visually checking the contents of containers. Grade 5 attendants know the procedures for reporting short, over, and damaged conditions of incoming stock, and make reports on these conditions to the supervisor or other responsible personnel, when required. In addition to placing items in established locations, grade 5 attendants are skilled in selecting and setting up specific locations for items within the framework of the general storage plan. This involves considering such factors as the use, size, shape, weight, and similar nomenclature of items. Grade 5 attendants are skilled in marking and tagging locations, and in making entries on locator records to show the names, quantities, and locations of stock.

Grade 5 attendants obtain items from stock by matching specific item names, models, and stock or part numbers with similar specific information at stock locations. In addition, grade 5 attendants are skilled in identifying specific items from the trade and shop names used by requesters. They usually use such references as locator files, issue and turn-in records, and stock and part number change lists for this purpose. During inventories, grade 5 attendants count stock on hand and give such information to the supervisor or other responsible supply personnel. Additionally, grade 5 attendants are skilled in searching likely locations and taking recounts of items in the tools and parts room to help supply personnel responsible for the inventory to determine the basis for over, short, or misplaced items. The attendants at this grade may also repair tools and equipment requiring skill in the use of pliers, screwdrivers, and other simple hand tools.

At the grade 6 level, attendants apply the same receiving skill and knowledge as that described at grade 5. In addition to the identification and issuing skill and knowledge described at grade 5, grade 6 attendants have sufficient knowledge of the range of items in stock to identify specific items requested by users from descriptions of their intended usage and to suggest, in the absence of requested items, other items that might fit workers’ requirements. Grade 6 attendants are skilled in determining substitute and interchangeable items. For this purpose, they usually use such references as manufacturers’ specifications, stock catalogs, manuals, and bulletins. Grade 6 attendants help supply personnel responsible for the inventory to determine the basis for over, short, or misplaced items by checking such references as out-for-repair and issue and turn-in records maintained in the tools and parts storage area, in addition to using the inventory methods described at grade 5. Grade 6 attendants have skill in determining from these records such errors as improper item issue and turn-in credit, and the failure of records to show that items have been sent out for repair.

Grade 6 attendants are skilled in determining when tools and equipment should be sent to test, repair, and calibration shops, in addition to making minor repairs to tools and equipment as described at grade 5. They make these determinations by performing visual and operating checks, making measurements with such devices as calipers, and receiving reports from workers on the nature and extent of damage to tools and equipment. In contrast to grade 5 attendants who note and report obviously damaged and inoperative items to the supervisor, grade 6 attendants are able to determine when many damaged and inoperative items appear beyond or too costly to repair. Whenever required, they make these determinations and provide their evaluations to stock disposal personnel to aid them in determining whether or not items should be salvaged, repaired, and returned to stock.

Grade 6 attendants are able to provide information on the status of stock useful to the supervisor or responsible supply personnel for determining and keeping adequate numbers and types of items on hand. Whenever required, grade 6 attendants watch and report, for example, items that are in short supply because of unusual breakage or because they are frequently out for repair. In many tools and parts rooms, grade 6 attendants pass on to the supervisor requests for items not kept in stock but which users indicate are needed for their work. Grade 6 attendants are able to keep track of project-assigned items when required. For example, based on information from the supervisor about incoming, project-assigned items and in-process or planned projects to which they are assigned, grade 6 attendants are skilled in identifying and insuring that project-assigned items are separated from regular items when they arrive. They have skill in setting up special storage locations for such items and in keeping them separated from regularly stocked items during their storage. They are also skilled in selecting and issuing proper items for the project, and in marking issue records to show projects against which these items are charged. They usually report to the supervisor any project-assigned items that are left over when projects are completed.

The appellant’s job meets the grade 5 level. Like this level, the appellant visually checks the incoming stock and verifies the short, over and damaged condition of incoming stock. She sets up storage locations considering such factors as the use, size, shape and nomenclature of items. The appellant also applies knowledge in determining the location, availability, and identification of specific items by referring to different sources. In contrast to the grade 6 level, the appellant is directed to only provide items specifically identified by the customer and, therefore, the appellant does not determine substitute and interchangeable items when requested items are unavailable. The appellant does not determine when tools or equipment should be sent to repair or calibration shops in the manner or intent described by the JGS. The appellant reports easily recognized damaged tools and relies on the customer to advise when tools or equipment are damaged upon return or upon receipt of the items. She does not perform operating checks, making measurements with such devices as calipers on returned items, determine when tools and equipment should be sent to test, repair, and calibration shops based on those measurements, or make the nature and extent of repair or disposal recommendations made by grade 6 attendants. Instead, the appellant sends tools or equipment to the calibration shop based on the items identified in the automated calibration report or when the calibration sticker is illegible or outdated. Additionally, because the storage area operates using a storage plan, the appellant is not required to set up or shift locations within the storage area considering such factors as space available, turnover, and convenience of handling items as described at the grade 6.

Therefore, this factor is evaluated at the grade 5 level.

Responsibility

At the grade 5 level, the attendant’s supervisor assigns work through oral and written instructions that indicate the work to be done and the requirements of the general storage plan. Grade 5 attendants complete their work by accepted stockroom methods, techniques, and procedures, and within the framework of the general storage plan. Although in-process work is usually not reviewed at this grade, grade 5 attendants are expected to bring to the attention of the supervisor any unusual problems encountered during the work. The supervisor may check to see that the work has been completed by accepted methods and procedures. Grade 5 attendants independently determine the sequences, methods, techniques, and procedures appropriate for accomplishing their assignments, and carry their work through to completion with little advice from the supervisor.

Grade 6 level work is assigned in a similar fashion to the grade 5 level, but such work as setting up and maintaining storage locations, identifying users’ tools, parts, and equipment requirements, recommending possible substitute or interchangeable items, and insuring that tools and equipment are maintained in good condition involve a wider and more complex range of work processes than the work described at grade 5. This requires more difficult decisions and judgments in the determination and selection of work sequences, methods, procedures, and techniques than at grade 5. The supervisor judges the quantity and quality of the overall work at this grade on the basis of reports from customers.

The nature of the appellant’s work and degree of responsibility meets the grade 5 level. The appellant receives general instructions on work procedures and the general storage plan from her supervisor. She completes work independently based on experience and accepted methods and procedures, referring unusual problems to her supervisor. The appellant’s level of responsibility does not meet the grade 6 level based on the nature of the work she performs. Unlike the grade 6 level, the appellant’s work does not require her to make more complex decisions and judgments such as identifying users’ tools, parts, and equipment requirements, recommending possible substitute or interchangeable items, and keeping track of project-assigned items when required.

This factor is evaluated at the grade 5 level

Physical Effort

At the grade 4, 5 and 6 levels described in the JGS, attendants perform work on hard surfaces and in work areas that require them to stand, stoop, bend, and work in tiring and uncomfortable positions. They frequently lift and carry tools, parts, supplies, and equipment that weigh up to 5 kilograms (10 pounds). The attendants may occasionally handle items that weigh up to 18 kilograms (40 pounds). Hand trucks, dollies, and other works are available for assistance with heavier items.

The appellant’s job meets but does not exceed the level described for all grade in the JGS. The appellant’s work requires standing for prolonged periods of time and frequent pushing, pulling, kneeling and bending. The appellant is required to lift up to 40 pounds. Therefore, this factor is not grade-determining and will not be discussed further.

Working Conditions

At the grade 4, 5 and 6 levels described in the JGS, the work is generally done in areas that are well lighted, heated, and ventilated. The attendants may occasionally work inside in areas that are drafty. The work is sometimes dirty, dusty, and greasy. The attendants are frequently exposed to the possibility of cuts, scrapes, and bruises.

The appellant’s job meets but does not exceed the level described for all grades in the JGS. The majority of work is performed in a storage area that is well lighted and heated, but occasionally drafty and noisy. The appellant is frequently exposed to the possibility of cuts, scrapes, and bruises. Therefore, this factor is not grade-controlling and will not be discussed further.

In summary, the appellant’s Tools and Parts Attendant duties equate to the grade 5 level.

Evaluation of Respirator Cleaning and Repair duties using the 3511 JGS

Skill and Knowledge

At the grade 2 level, workers complete routine tasks that have a sequence of work steps such as handwashing items through a series of consecutive cleaning steps and operating washing machines by inserting baskets, adding the specified amount of detergent and other cleaning solutions, and routinely setting timers to start the wash cycle. Grade 2 workers routinely prepare one or a few types of fragile or hard-to-handle items such as putting syringes together by matching the numbers of syringe plungers to those of syringe barrels. They visually check washed items for obvious chips, burrs, waste residues, stains, detergent films, and other imperfections resulting from the cleaning process. They also prepare solutions, such as acid cleaning, glucose, and saline mixtures which do not require exact measuring, and count, date, and label items to be sterilized or placed in storage.

At the grade 3 level, workers apply a knowledge of different work procedures in doing their work. For example, in preparing a variety of types of glassware, they cover certain items with tinfoil or fabric; plug others with cotton, corks, or rubber caps; and wrap some items individually and others in groups. When loading and operating sterilization equipment, they consider whether the items will withstand high temperatures or need to be sterilized by another method. Grade 3 workers apply a knowledge of the techniques for placing and spacing items in the sterilizer and for adjusting dials of the sterilizer to regulate pressure, temperature, and time periods.

The appellant’s job meets the grade 2 level. Like this level, the appellant follows a sequence of steps to clean and repair approximately five different types of used respirators for reissuance. The appellant follows prescribed steps in dismantling, cleaning, repairing and packaging the respirators which consist of a limited number of easily recognizable parts, only a few of which can be replaced if damaged as discussed previously in this decision. The appellant’s work does not meet the grade 3 level which requires the worker to apply different work procedures to a variety of work assignments which require knowledge and application of techniques specific to the type of glassware handled and may require following specialized instructions for items that are not routinely processed for sterilization.

Therefore, this factor is evaluated at grade 2.

Responsibility

At the grade 2 level, workers receive initial oral and written instructions and do their work routinely according to established procedures. They use greater care than at the grade 1 level to avoid breakage of fragile or hard-to-handle items. Their work is periodically checked by the supervisor to see that work procedures are followed and that production standards are met.

At the grade 3 level, Laboratory Workers receive initial oral and written instructions that indicate the work to be done. They frequently must select from established work procedures the proper way to do each task. Their work is periodically checked by the supervisor to see that the correct work procedures are used and that production standards are met.

The nature of the appellant’s work and degree of responsibility meet the grade 2 level because it is routine in nature and covered by established procedures. Similar to the grade 2, the appellant knows what steps or sequence of steps to take in dismantling, cleaning and repairing approximately five different types of respirators using established procedures. Like at the grade 2 level, the appellant’s work is checked for adherence to work procedures and that production schedules are met. The grade 3 level is not met because the appellant is not required to select from established procedures the proper way to do each task such as deciding which items should be sterilized by dry heat and which items must be sterilized by gas or steam.

Therefore, this factor is evaluated at grade 2.

Physical Effort

At the grades 1, 2, and 3 levels described in the JGS, workers frequently carry and lift objects weighing from 5 kilograms to 14 kilograms (10 to 30 pounds), such as pans filled with glassware, and push and pull carts requiring similar effort. They occasionally handle moderately heavy objects weighing up to 18 kilograms (40 pounds) such as large containers of supplies. The work requires continuous walking, standing and considerable arm and hand movements to operate equipment and to do preparation work.

The appellant’s cleaning and repair work meets but does not exceed the level described in the JGS. Like this level, the appellant’s work requires continuous walking, standing and considerable arm and hand movements to do preparation work and operate equipment. The appellant is frequently required to lift up to 30 pounds. Therefore, this factor is not grade-determining and will not be discussed further.

Working Conditions

At the grades 1, 2 and 3, levels described in the JGS, workers work in areas that are hot, humid and generally noisy due to the operation of equipment such as washing machines, autoclaves, and air compressors. There is frequent chance of minor injuries such as cuts, scrapes, and burns, and the possibility of exposure to contaminated materials. The laboratory workers are normally provided with protective clothing such as masks, gloves, and gowns.

The appellant’s cleaning and repair work meets but does not exceed the level described in the JGS. The respirator cleaning and repair duties require the appellant to work in a generally noisy area due to the operation of washing and drying machines. The appellant uses protective clothing, such as a mask, gown and gloves to clean and repair respirators and is exposed to the possibility of cuts, scrapes and burns. Therefore, this factor is not grade-determining and will not be discussed further.

In summary, the appellant’s respirator cleaning and repair duties equate to the grade 2 level.

Summary

The appellant’s job involves performing duties in two occupations. Her tools and parts attendant duties are evaluated at grade 5 and her respirator cleaning and repair duties at grade 2. We find the highest level of regular and recurring work performed by the appellant is grade 5.

Decision

The appellant’s job is properly graded as Tools and Parts Attendant, WG-6904-5.

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