U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeals and FLSA Programs Philadelphia Oversight Division 600 Arch Street, Room 3400 Philadelphia, PA 19106-1596 Classification Appeal Decision Under section 5112 of title 5, United States Code Appellant: [appellant’s name] Agency classification: Supervisory General Supply Specialist GS-2001-12 Organization: [name] Branch [name] Defense Distribution Center [name] Defense Distribution [name] Defense Logistics Agency [location] OPM decision: Supervisory Distribution Facilities Specialist GS-2030-12 OPM decision number: C-2030-12-01 _____________________________ Robert D. Hendler Classification Appeals Officer July 9, 2002 _____________________________ Date 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 (PCS's), appendix 4, section G (address provided in appendix 4, section H). Since this decision changes the classification 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 (5 CFR 511.702). The servicing personnel office must submit a compliance report containing the corrected position description 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. Decision sent to: PERSONAL [appellant’s name] [appellant’s address] [name] Deputy Personnel Officer Personnel Office Defense Logistics Agency Defense Distribution Center [address] [location] Mr. Jeffrey Neal Executive Director Human Resources Defense Logistics Agency 8725 John J. Kingman Road, Suite 3630 Fort Belvoir, VA 22060-6221 Ms. Janice W. Cooper Chief, Classification Branch Field Advisory Services Division Defense Civilian Personnel Management Service 1400 Key Boulevard, Suite B-200 Arlington, VA 22209-5144 Introduction On January 10, 2002, the Philadelphia Oversight Division of the U.S. Office of Personnel Management (OPM) accepted a classification appeal from [appellant’s name]. The appellant believes his position should be classified at the GS-13 grade level in the GS-1101, GS-2003, or GS-2030 series. We received the complete administrative report on April 12, 2002. The appellant works in the [name] Branch, [name] Division, Defense Distribution Center [name] [acronym]) PA, Defense Distribution [name] ([acronym]), Defense Logistics Agency (DLA), [location]. We accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.). General issues In his July 9, 2001, appeal sent to OPM through his servicing human resources office (HRO), the appellant disagreed with the series, title, and grade of his position (Supervisory Production Controller, GS-1152-12). The HRO reviewed the position and reclassified it as Supervisory General Supply Specialist, GS-2001-12 before forwarding the case. The initial appeal administrative report of December 27, 2001, forwarded with the appeal, shows that the position was reclassified on December 20, 2001, as Supervisory General Supply Specialist, GS-2001-12. The appellant was reassigned to the reclassified position effective January 13, 2002. He believes that his position should be upgraded based on the application of the General Schedule Supervisory Guide (GSSG). In the attachments to his appeal memorandum, the appellant points to the classification of other [acronym] positions and the additional duties that he has assumed for the [name] Program. During the appeal process, he questioned the adequacy of his agency’s review of his position. OPM is required by law to classify positions on the basis of their duties, responsibilities, and qualification requirements by comparison to the criteria specified in the appropriate PCS or guide (5 U.S.C. 5106, 5107, and 5112). The law does not authorize use of other methods or factors of evaluation, such as comparison to other positions that may or may not have been classified correctly. Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding his agency’s classification review process are not germane to this decision. Like OPM, the appellant's agency must classify positions based on comparison to OPM's PCS's and guidelines. Agencies are obligated to review their own classification decisions for identical, similar or related positions to insure consistency with OPM appeal certificates (5 CFR 511.612). The agency has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers the appealed position so similar to others that they warrant the same classification, he may pursue this matter by writing to his agency's human resources management headquarters. 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 the appealed position, or warrant similar application of the controlling PCS's, the agency must correct their classification to be consistent with this appeal decision. Otherwise, the agency should explain to him the differences between the appealed position and the others. The appellant pointed to his fiduciary responsibility, including credit card purchase authority and responsibility for auditing program credit card use, and the consequences of any improper actions. In evaluating positions, only the effect of properly performed work is considered. How well work is or is not performed is covered by the performance management program. He stressed his responsibilities as manager of [acronym]’s [name] Program and his direct reporting relationship to the [acronym] Commander for that program. We will consider this reporting relationship only insofar as it is relevant to properly applying OPM PCS’s to his position. Position information The appellant serves as the Chief, [name] Branch and Program Manager of the [name] function. He is the principal advisor on [name] Program issues to the [acronym] Commander and is responsible for assuring that [acronym] stock condition is known and reported. Program functions include in-service inspection, minor repair, testing, preservation, and the receipt, identification, classification and packaging of material. The appellant manages the [acronym] [name] warehousing function and the [acronym] [name] and [name] Programs. His organization packs and marks material incident to receipt and for the [name] Program (damaged and/or improper packaging). The appellant’s subordinates receive, inspect, and store specialty items, e.g., generators, engines, and axles. As part of the [acronym] custody process, the appellant’s staff services and repairs ground and airborne mechanical systems and components, e.g., generators and engines, support equipment, and/or refrigeration equipment. The branch repairs, sandblasts, and paints automotive and truck body parts. Other branch functions include repairing, packaging, upgrading packaging, and marking materials in storage. As of June 2002, the appellant’s staff consisted of approximately 64 employees, including vacant positions. The staff included one Supervisory Equipment Specialist, GS-1670-11, one Supervisory General Supply Specialist, GS-2001-11, one Equipment Specialist, GS-1670-11, two Quality Assurance Specialists, GS-1910-10, four Equipment Specialists, GS-1670-9, four General Supply Specialists, GS-2001-9, two Production Controllers, GS-1152-9, one Supply Technician, GS-2005-7, and one Supply Technician, GS-2005-5. The Federal Wage System (FWS) staff includes a Heavy Mobile Equipment Mechanic Leader, WL-5803-10, 4 Material Examiner and Identifier Leaders, WL-6912-7, a Welder, WG-3703-10, 5 Heavy Mobile Equipment Repairers, WG-5803-9, a Painter, WG-4102-9, 24 Materials Examiner and Identifiers, WG-6912-7, and 11 Preservation Servicers, WG-7006-7. We conducted an on-site audit with the appellant on June 27, 2002, and a telephone interview with his immediate supervisor, [name], Deputy Division Director, on July 1. The appellant's position description (PD) (#[number]) of record, certified as current and accurate by the appellant’s second level supervisor, furnishes more details about the appellant's duties and responsibilities and how they are performed and is incorporated by reference into this decision. Series, title, and standard determination The GS-2030 Distribution Facilities and Storage Management Series covers work concerned with receiving, handling, storing, maintaining while in storage, issuing, or physically controlling items within. Positions in this series require knowledge of the principles, practices, and techniques of managing the physical receipt, custody, care, and distribution of material, including the selection of appropriate storage sites, material handling equipment, and facilities. The GS-2030 PCS states that “manager” positions in this series involve directing or managing operating storage, warehousing, and related programs. The appellant’s [name] Program entails the full range of work typical of GS-2030 positions. The appellant’s other duties represent maintaining while in storage, custody, and care functions typical of the GS-2030 series, e.g., preservation and packaging. While maintenance and repair functions are not typical of GS-2030 programs, these function occupy less than 15 percent of the branch’s workload and do not control classification of the position. Therefore, we find that the appellant’s position is properly placed in the GS-2030 series. The appellant’s position is excluded from the GS-2003 series. He does not perform or supervise staff work primarily concerned with analyzing, developing, evaluating, or promoting improvements in supply program policies, plans, methods, procedures, systems, or techniques. These functions are assigned to other [acronym] organizations, e.g., [name] Division. He does not manage a supply program that includes a mixture of technical supply functions, e.g., GS-2010 Inventory Management, GS-2030 Distribution Facilities and Management, GS-2032 Packaging, and GS-2050 Supply Cataloging. Instead, he manages a technical supply and trades staff engaged in GS-2030 functions. The GS-2001 series covers positions that involve a combination of two or more two-grade interval series in the GS-2000 Group when no single series is paramount, or other analytical or administrative supply work not specifically covered by another series. Because the appellant’s GS-2030 functions are paramount, his position is excluded from the GS-2001 series. The GS-1101 series covers positions that administer, supervise, or perform a combination of work characteristic of two or more series in the GS-1100 Business and Industry Group where no one type of work is series controlling, or other work in the group for which no other series is provided. While the appellant’s position requires knowledge of business practices, this knowledge is used to supervise work covered by the GS-2000 Supply Group as discussed previously. The purpose of his position is to supervise work in one of seven line operating divisions in a DLA supply depot. Therefore, classification of the appellant’s position to the GS-1101 series is not appropriate. The appellant is engaged in receiving, handling, storing, maintaining while in storage, and physically controlling items within a distribution system. Functioning as a second level supervisor as discussed in the Grade determination section of this decision, the appellant’s position is properly allocated as Supervisory Distribution Facilities Specialist, GS-2030. Grade determination The appellant asked that OPM review all factors in applying the GSSG. The appellant specifically requested that his position be credited with Levels 3-4, 4B-4, and 6-5. The GSSG is a threshold PCS. A defined level must be fully met before it can be credited. Our analysis of the position follows. Factor 1, Program scope and effect This factor addresses the general complexity, breadth, and impact of the program areas and work directed, including the organizational and geographic coverage. It also assesses the impact of the work both within and outside the immediate organization. To credit a particular factor level, the criteria for both scope and effect must be met. The factor levels describe two situations: agency line programs, e.g., providing services to the public; and support programs, e.g., providing administrative services within an agency. The appellant’s position falls under the first situation since his organization performs line [acronym] supply depot functions. a. Scope-This element addresses the general complexity and breadth of (1) the program or program segment directed and (2) the work directed, the products produced, or the services delivered. The geographic and organizational coverage of the program or program segment within the agency structure is to be addressed under Scope. In evaluating the population affected under this factor, we may only consider the total population serviced directly and significantly by a program. We cannot count the total population in the geographic area potentially covered by a program. Scope also considers how the activities directed relate to the agency’s mission and to outside entities, and the complexity and intensity of the services provided. The agency credited Level 1-3 and the appellant agrees. At Level 1-3, the supervisor directs a program segment that performs technical, administrative, protective, investigative, or professional work. The program segment and work directed typically have coverage, which encompasses a major metropolitan area, a State, or a small region of several States; or when most of an area’s taxpayers or businesses are covered, coverage comparable to a small city. Illustrative of this level is furnishing a significant portion of the agency’s line program to a moderate sized client population that is equivalent to a group of citizens and/or businesses in several rural counties, a small city, or a portion of a larger metropolitan area. The appellant provides services to Department of Defense and other [acronym] customers to a moderate sized population that fully meets Level 1-3. While the appellant supervises some administrative work, it is not representative of the primary work of his branch as discussed in Factor 5. The branch’s preponderantly FWS and technician work does not exceed Level 1-2 in intensity. As at Level 1-2, the branch’s inspection, minor repair, testing, preservation, and its receipt, identification, classification and packaging of material functions are equivalent to those of a field office providing services to the public on a case basis, e.g., adjudicating benefit and entitlement claims or auditing individual tax returns. In contrast to [acronym]’s full range of functions as DLA’s [descriptor] supply depot, the branch’s work does not entail furnishing a significant portion of the agency(s line program to its customers. Because this element does not fully meet Level 1-3, it must be credited at Level 1-2. b. Effect-This element addresses the impact of programs, products, or correctly performed work both within and outside the agency. At Level 1-3, activities, functions, or services directly and significantly affect a wide range of agency activities, the work of other agencies, the operations of outside interests, or the general public. As illustrated in the GSSG, positions at this level furnish a significant portion of the agency’s line program to a moderate-sized population of clients equivalent to a group of citizens and/or businesses in several rural counties, a small city, or a portion of a larger metropolitan area. Depending on the complexity and intensity of the service, the serviced population may be concentrated in one geographic area, or involve a significant portion of a multi-state population, or be composed of a comparable group. As at Level 1-3, the appellant’s work directly affects a population equivalent to the citizens of a small city. However, the general complexity of the day-to-day FWS and technical work falls short of this level. In-service inspection, minor repair, testing, preservation, and the receipt, identification, classification and packaging of material do not reflect the direct and significant impact required at Level 1-3. The branch’s more complex maintenance and repair work, i.e., welding, heavy mobile equipment repair, and complex painting, is not representative of the overall work of the branch. As discussed in Factor 5, this work also does not exceed the complexity of work found at Level 1-2, i.e., technical, complex clerical, or comparable in nature. Because this element does not fully meet Level 1-3, it must be credited at Level 1-2. Level 1-2 is credited for both Scope and Effect (350 points). Factor 2, Organizational setting This factor considers the organizational situation of the supervisory position in relation to higher levels of management. If a position reports to two positions, this factor level associated with the position is the one responsible for performance appraisal. While the appellant reports directly to the [acronym] Commander on [name] Program issues, he reports for performance appraisal purposes to the Deputy Division Chief who is a full deputy within the meaning of the GSSG. The Division Chief reports to the [acronym] Commander. The record shows that the [acronym] Commander reports to the first SES equivalent position in the direct reporting chain. We find that the appellant’s position meet Level 2-1 since he reports to a position properly identified two or more reporting levels below the first SES or equivalent position in the direct supervisory chain. Therefore, Level 2-1 (100 points) is assigned. Factor 3, Supervisory and managerial authority exercised This factor covers the delegated supervisory and managerial authorities that are exercised on a recurring basis. To be credited with a level under this factor, a position must meet the authorities and responsibilities to the extent described for the specific level. The agency credited Level 3-2c (450 points). The appellant believes that his position meets Levels 3-4 because he is the Stock Readiness Program Manager. A position must fully meet Levels 3-3a and 3-3b before Level 3-4 may be considered. Level 3-3a involves: (1) exercising delegated managerial authority to set a series of annual, multiyear, or similar types of long-range work plans and schedules for in-service or contracted work; (2) assuring implementation (by lower and subordinate organizational units or others) of the goals and objectives for the program segment(s) or function(s) they oversee; (3) determining goals and objectives that need additional emphasis; (4) determining the best approach or solution for resolving budget shortages; and (5) planning for long range staffing needs, including such matters as whether to contract out work. Positions exercising these authorities are closely involved with high level program officials (or comparable agency level staff personnel) in the development of overall goals and objectives for assigned staff function(s), program(s), or program segment(s). For example, they direct development of data; provide expertise and insights; secure legal opinions; prepare position papers or legislative proposals; and execute comparable activities that support development of goals and objectives related to high levels of program management and development or formulation. The appellant's position is supervisory rather than managerial in nature. He executes staff support programs at the field level. The program has prescribed instructions for the uniform care of supplies, including the inspection and reporting of condition and serviceability of material and the scheduling, controlling and reporting of packaging and other reimbursable actions. In contrast, Level 3-3a covers program management work normally delegated to higher levels in the organization where the position is involved in making decisions related to overall program staffing, budgetary, policy, and regulatory matters. While the appellant provides input to higher levels of management on these issues for the [acronym] [name] Program, they relate to [acronym] resource requirements and working environment. Level 3-3a program decisions are made at higher echelons within DLA. Lower and subordinate organizational units refer to organizations at lower echelons within an agency, e.g., programs carried out at multiple field installations. It does not cover employees directly supervised by the appellant. Therefore, the appellant is not responsible for managing the scale and scope of functions required for crediting Level 3-3a to his position and Level 3-4 may not be considered. To meet Level 3-3b, a position must exercise all or nearly all of the delegated authorities and responsibilities described at Level 3-2c and, in addition, at least 8 of the 15 responsibilities listed in the GSSG. The activity credited the appellant's position with fully meeting Level 3-2c. It did not address the responsibilities listed under Level 3-3b. Responsibilities 1, 3, 5, 6, and 8 are intended to credit only supervisors who direct two or more subordinate supervisors, team leaders or comparable personnel. To support these designations, these subordinate personnel must spend 25 percent or more of their time on supervisory, lead or comparable functions. These responsibilities may only be credited in situations where the subordinate organization is so large and its work so complex that it requires managing through these types of subordinate positions. The appellant’s organization fully meets these criteria. Therefore, these five responsibilities are credited. One of the appellant's major functions is to advise management officials of higher rank on Stock Readiness Program matters concerning [acronym] mission. Therefore, responsibility 2 is met. Responsibility 4 is credited to positions that exercise direct control over a multimillion dollar level of annual resources (in 1993 dollars). Because the appellant does not exercise direct control over major program funds, this responsibility may not be credited. The stock fund amounts cited by the appellant fall below the threshold for this responsibility. Division delegations of authority and records show that appellant selects candidates for all positions in his organization. Therefore, responsibilities 7 and 8 are met. The appellant has the authority to respond to both individual and group grievances. Given the size and complexity of the branch, it is reasonable to conclude that the appellant regularly deals with these issues. Therefore, responsibility 9 is met. His authority to issue letters of reprimand and propose more severe action falls short of the authority to review and approve serious disciplinary actions, e.g., suspensions, required for crediting responsibility 10. Therefore, responsibility 10 is not met. While the appellant has the authority to approve routine training, higher level managers must approve costly or controversial training; e.g., leadership training. The limited workload and preponderantly FWS structure of his organization also cause us to conclude that non-routine and costly training proposals are not regular and recurring functions of his position. Because responsibility 11 is not met fully, it may not be credited. Responsibility 12 applies to supervisory and managerial positions that oversee organizations in which contractors perform a significant amount of line work. The appellant does not oversee a significant contractor staff. Therefore, responsibility 12 is not credited. The appellant exercises within-grade increase and employee travel approval authority credited in responsibility 13. While he budgets for and approves overtime, the workload that he directs does not present the opportunity to grant extensive overtime as intended in this responsibility. Because responsibility 13 is not fully met, it may not be credited. The appellant recommends awards and bonuses for non-supervisory personnel subject to approval by higher level officials. While the appellant may recommend changes in position classification, the record shows that PD’s are certified by the Division head as the immediate supervisor. Because responsibility 14 is not fully met, it may not be credited. Responsibility 15 applies to supervisory and managerial positions that oversee organizations with workloads that are so large and complex as to require attention to team building, or comparable methodological or structural improvements. The appellant does not oversee a workload of this magnitude and complexity. His efforts to improve office operations meet the demands of finding ways to improve production or increase the quality of work directed described at Level 3-2c. Therefore, responsibility 15 is not credited. In summary, we have credited the position with responsibilities 1, 2, 3, 5, 6, 7, 8, 9. Because the position is credited with 8 of the listed responsibilities, it is credited at Level 3-3b (775 points). Subfactor 4A, Nature of contacts The agency has credited Level 4A-3. At that level, frequent contacts are comparable to any of the following: - high ranking military or civilian managers, supervisors, and technical staff at bureau and major organization levels of the agency; with agency headquarters administrative support staff; or with comparable personnel in other Federal agencies; - key staff of public interest groups (usually in formal briefings) with significant political influence or media coverage; - journalists representing influential city or county newspapers or comparable radio or television coverage; - congressional committee and subcommittee staff assistants below staff director or chief counsel levels; - contracting officials and high level technical staff of large industrial firms; and - local officers of regional or national trade associations, public action groups, or professional organizations; and/or State and local government managers doing business with the agency. Contacts include those which take place in meetings and conferences and unplanned contacts for which the employee is designated as a contact point by higher management. They often require extensive preparation of briefing materials or up-to-date technical familiarity with complex subject matter. The appellant’s contacts meet Level 4A-3 for his [name] Program functions. As at that level, he has frequent contacts with high ranking officials at major command and agency level on program issues. The appellant has regular and recurring contacts with [acronym] and DLA technical staff on program development issues that require substantial preparation and up-to-date technical familiarity with complex technical issues, e.g., presenting program improvement briefings at conferences. He routinely deals with high ranking officials at customer agencies, e.g., military service inventory control points on matters requiring similar preparation, e.g., entering into reimbursable agreements. At Level 4A-4, frequent contacts are comparable to any of the following: - influential individuals or organized groups from outside the employing agency, such as executive level contracting and other officials of major defense contractors or national officers of employee organizations; - regional or national officers or comparable representatives of trade associations, public action groups, or professional organizations of national stature; - key staff of congressional committees, and principal assistants to senators and representatives. For example, majority and minority staff directors, chief counsels, and directors of field operations; - elected or appointed representatives of State and local governments; - journalists of major metropolitan, regional, or national newspapers, magazines, television, or radio media; - SES, flag or general officer, or Executive Level heads of bureaus and higher level organizations in other Federal agencies; Contacts may take place in meetings, conferences, briefings, speeches, presentations, or oversight hearings and may require extemporaneous response to unexpected or hostile questioning. Preparation typically includes briefing packages or similar presentation materials, requires extensive analytical input by the employee and subordinates, and/or involves the assistance of a support staff. The appellant does not have regular and recurring contacts with SES, flag or general officer, or Executive Level heads of bureaus and higher level organizations in other Federal agencies, or others representative of this level. Therefore, this subfactor is credited at Level 4A-3 (75 points). Subfactor 4B, Purpose of contacts This subfactor covers the purpose of the personal contacts credited in Subfactor 4A, including the advisory, representational, negotiating, and commitment making responsibilities related to supervision and management. The agency credited Level 4B-3. At that level, the purpose of contacts is to justify, defend, or negotiate in representing the project, program segment(s), or organizational unit(s) directed, in obtaining or committing resources, and in gaining compliance with established policies, regulations, or contracts. Contacts at this level usually involve active participation in conferences, meetings, hearings, or presentations involving problems or issues of considerable consequence or importance to the program or program segment(s) managed. As at Level 4B-3, the appellant’s most demanding [name] Program contacts are for the purpose of representing the [acronym] program in meetings with higher level DLA and customer agencies. These contacts require him to obtain compliance with established policies and regulations, e.g., acceptance of [acronym] condition code decisions, and to obtain resource commitments, e.g., negotiate reimbursable agreements. As at Level 4B-3, he represents the [acronym] Commander on [name] Program conferences and meetings that focus on changes in program methods and procedures. At Level 4B-4, the purpose of contacts is to influence, motivate, or persuade persons or groups to accept opinions or take actions related to advancing the fundamental goals and objectives of the program or segments directed, or involving the commitment or distribution of major resources, when intense opposition or resistance is encountered due to significant organizational or philosophical conflict, competing objectives, major resource limitations or reductions, or comparable issues. At this level, the persons contacted are sufficiently fearful, skeptical, or uncooperative that highly developed communication, negotiation, conflict resolution, leadership, and similar skills must be used to obtain the desired results. The appellant does not regularly deal with the intense opposition on major program issues found at this level. While an inventory control point may not agree with a condition code and release decision, this is a case issue that must be resolved using established policies and regulations. Actions on the fundamental goals and objectives of the program are under the control of higher echelons in the agency. Major resource and other decisions contemplated at this level are vested in higher level positions at [acronym], including the [acronym] Commander. Therefore, this subfactor is credited at Level 4B-3 (100 points). Factor 5, Difficulty of typical work directed This factor measures the difficulty and complexity of the basic work most typical of the organization(s) directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility, either directly or through subordinate supervisors, team leaders, or others. The appellant states that this factor should be credited at the GS-11 grade level because he supervises three GS-11 positions. The GSSG states that the level selected for first level supervisors, and many second level supervisors, is the highest grade which: * best characterizes the nature of the basic (mission oriented) non-supervisory work performed or overseen by the organization directed; and * constitutes 25 percent or more of the workload (not positions or employees) of the organization. This means that 25 percent or more of the non-supervisory duty hours of subordinates and others is expended on work at or above the base level credited, or, where extensive contract work is overseen, that 25 percent or more of the dollars spent on human services is for work at or above that level. It includes the workload of General Schedule (GS) subordinates, FWS employees, assigned military, volunteers, student trainees or non-Federal workers, such as contractor employees, State and local workers, or similar personnel. In determining the highest level of work which constitutes at least 25 percent of workload or duty time, trainee, developmental, or other work engineered to grades below normal full performance levels is credited at full performance levels. Excluded from consideration are the work of lower level positions that primarily support or facilitate the basic work of the unit; any subordinate work that is graded based on criteria in the GSSG (i.e., supervisory duties) or the work leader duties; work that is graded based on an extraordinary degree of independence from supervision, or personal research accomplishments (or adjust the grades of such work for purposes of applying the GSSG to those appropriate for performance under "normal" supervision); and work for which the supervisor or a subordinate does not have the responsibilities defined under Factor 3. Our review of the PD’s of the subordinates revealed that both supervisory positions are classified on the basis of personally performed work. One position spends 50 percent and the other 40 percent of their time on supervisory duties. The record shows that the GS-2001-9 positions function as shift supervisors. They spend approximately 50 percent of their time performing non-supervisory trades work, 25 percent of their time on shift supervision, and 25 percent of their time on administrative work. The GS-1910-10 PD shows that the position spends 55 percent of its time performing FWS work, i.e., manufacturing test gigs and calibrating equipment. The Wage Leader PD’s provided show that the occupants perform leader duties 50 percent of the time. These PD’s, that have been certified as current and accurate, show that approximately 4.5 of the 64 staff years directed by the appellant are excluded because they are supervisory or lead in nature. Excluding the FWS work assigned to the GS positions, we find that the appellant supervises no more than nine staff years of non-supervisory work at or above the GS-9 grade level. This constitutes approximately 15 percent of the branch’s non-supervisory workload. All of the non-supervisory trades positions perform mission essential work and must be included in workload calculations. While it is not possible to make a direct correlation between the two pay systems for GS and FWS positions, the level of work performed by the WG-9 and WG-10 positions does not exceed the level of work performed at the GS-7 grade level. For example, the complexity of work assignments, and the skills and knowledge of Heavy Mobile Equipment Mechanics, WG-5803-10, who install, modify, repair, maintain, troubleshoot, and test the full range of systems on vehicles and equipment, overhaul major equipment systems, or perform comparable work; who use knowledge of electrical, electronic, hydraulic, pneumatic, and other non-mechanical systems which have a functional relationship and effect on the operation of the mechanical systems; who are skilled in tracing and locating defects, analyzing malfunctions, selecting and complying with technical manuals, illustrations, specifications, diagrams, schematics, and similar guides to make repairs and modifications according to specifications and procedures; and who must have the ability to mesh, connect, align, and adjust parts and systems, does not exceed the level of complexity of Engineering Technician, GS-802-7 work. At the GS-7 grade level, engineering technicians perform work which involves planning nonroutine assignments of substantial variety and complexity; selecting guidelines to resolve operational problems not fully covered by precedents; developing revisions to standard work methods; modify parts, instruments, and equipment; and, take actions to or make recommendations based on preliminary interpretation of data or results of analysis. For example, some Engineering Technicians, GS-802-7, review designated portions of plans submitted by contractors for interior electrical wiring of residential or office buildings for light and power; check the accuracy of calculations of loads, illuminations, conductor size, etc., and the adequacy of switches, controls, and other equipment selected by the contractor. They base their review on a practical knowledge of methods and techniques of electrical engineering design, and review drawings, the basis for design, and design analysis for conformance with established engineering standards and criteria set forth in manuals, codes, and other guides, and the specific project requirements. Heavy Mobile Equipment Mechanics, WG-5803-10, work within the bounds of available guides and trade techniques, and are responsible for assuring the selection and application of the appropriate trade practices and techniques to perform their work. Work receives little or no check in progress or upon completion. The work is checked to see that it meets accepted trade standards and is completed timely. Recurring work assignments performed by Engineering Technicians, GS-802-7 are occasionally observed and are subject to only occasional spot checks for technical adequacy. While the Heavy Mobile Equipment Mechanics, WG-5803-10 and Engineering Technicians, GS-802-7 carry out their assignments within comparable degrees of established procedure, the overriding consideration is the level of complexity of the work performed. The preceding comparison of the kind of assignments performed in the two occupations demonstrates that WG-10 mechanical work is not inherently more complex than GS-7 engineering technician work. Thus, without attempting to equate FWS and GS grades, we conclude that the representative FWS work performed within the Division does not provide a basis for crediting a higher level than GS-7 for the 6.5 staff years of non-supervisory WG-9 and higher grade FWS work in the Branch. Therefore, we find that approximately 15.5 staff years work, comprising approximately 26 percent of the branch’s non-supervisory workload, is credited at or above the GS-7 grade level or equivalent. Based on the limited GS-9 and higher graded workload and the substantial freedom from supervision vested in those positions, the record does not support that the appellant devotes 50 percent or more of his time overseeing this work. Therefore, the alternative method of base level analysis is not appropriate. Accordingly, this factor is credited at Level 5-4 (505 points). Factor 6, Other conditions This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities. Conditions affecting work for which the supervisor is responsible, whether performed by Federal employees, assigned military, contractors, volunteers, or others, may be considered if they increase the difficulty of carrying out assigned supervisory or managerial duties and authorities. In order to evaluate Factor 6, two steps are used. First, the highest level that a position meets fully is initially credited. Then, if the level selected is 6-1, 6-2, or 6-3, the Special Situations listed after the factor level definitions are considered. If a position meets three or more of the situations, then a single additional level is added to the level selected in the first step. If the level selected in the first step is 6-4, 6-5, or 6-6, the Special Situations may not be considered in determining whether a higher factor level is creditable. The appellant’s rationale states that his position involves substantial coordinating and integrating of work, citing selected segments of Factor Level 6-5a. The position classification process requires that the full intent of PCS’s be discerned and applied. Level 6-5a pertains to positions that directly supervise a GS-12 base level of work and which also are responsible for the types of major recommendations described at that level. Because our analysis of Factor 5 established that the correct base level of the work directed is GS-7, Level 6-5a is not applicable to the appellant’s position. The numbered paragraphs under Factor 6 are structured to address positions that function as either first level or second and higher level supervisors and managers. The appellant functions as a second level supervisor as discussed in Factors 3 and 5. Based on our evaluation of Factor 5, we find that the position fully meets Level 6-3b because, based on the amount of GS-7 base level of work available, supervising the Division is characterized properly as entailing the direction of subordinate supervisors over positions in grades GS-7 or GS-8 or the equivalent which requires consolidation and coordination similar to that described at Level 6-2a. Level 6-4a is not applicable to the position since the appellant does not directly supervise non-supervisory work which supports a GS-11 base level. Level 6-4b is not applicable since there is not sufficient work at or above GS-9 grade level in the branch to permit the crediting of each subordinate supervisory position with supervising work with a GS-9 or GS-10 base level. Because the position is credited properly at Level 6-3b, we will explore the applicability of Special Situations to the position. Special situations Supervisory and oversight work may be complicated by special situations and/or conditions. The Methodology section at the beginning of this factor explains how to credit the following situations. 1. Variety of work This situation is creditable when: (1) there is more than one kind of work; (2) each kind represents a requirement for a distinctly different additional body of knowledge of the supervisor; (3) both technical and administrative supervision are exercised over the work; and, (4) the grade level of the work cannot be more than one grade below the base level credited in Factor 5. The two-grade interval positions and the wide variety of FWS occupations meeting the grade level restrictions of this situation within the branch warrant the crediting of this situation. 2. Shift Operations This situation is credited when the position supervises an operation carried out on at least two fully staffed shifts. Although the appellant supervises some second and third shifts operations, the record shows that these operations are not carried out on two fully staffed shifts. Therefore, this situation is not credited. 3. Fluctuating Workforce or Constantly Changing Deadlines A fluctuating workforce is creditable when the workforce has large fluctuations in size, e.g., when there are large seasonal variations in staff and these fluctuations impose upon the supervisor a substantially greater responsibility for training, adjusting assignments, or maintaining a smooth flow of work. The appellant’s workforce is relatively stable. Therefore, this situation is not credited. Constantly changing deadlines is creditable when there are frequent, abrupt, and unexpected changes in work assignments, goals, and deadlines that require the supervisor to constantly adjust operations under the pressure of continuing changing and unpredictable conditions. The changes in program demands in the appeal record do not indicate that there are frequent, abrupt, and unexpected changes with the impact of work planning required for the crediting of constantly changing deadlines. Therefore, this situation is not credited. 4. Physical Dispersion This situation is creditable when a substantial portion of the workload for which the supervisor is responsible is regularly carried out at one or more locations which are physically removed from the main unit (at different buildings, or widely dispersed locations in a large warehouse or factory building) under conditions which make day-to-day supervision difficult to administer. The branch mission is performed throughout the base and at two geographically separate sites. The record shows that the appellant’s work planning is directly affected by this circumstance. Therefore, this situation is credited. 5. Special Staffing Situations This situation is creditable when: (1) a substantial portion of the workforce is regularly involved in special employment programs; or in similar situations which require involvement with employee representatives to resolve difficult or complex human resources management issues and problems; (2) requirements for counseling and motivational activities are regular and recurring; and, (3) job assignments, work tasks, working conditions, and/or training must be tailored to fit the special circumstances. Typical of staffing situations is the employment of a substantial number of student-trainee, cooperative education, or similar programs which have intensive training and counseling demands, or the special training, counseling, and motivational demands of physically or mentally challenged employees. The appeal record does not support the crediting of this situation. 6. Impact of Specialized Programs This situation is creditable when supervisors are responsible for a significant technical and administrative workload in grades above the level of work crediting Factor 5, provided the grades of this work are not based upon independence of action, freedom from supervision, or personal impact on the job. Level 5-4 credited to the position covers GS-7 and GS-8 grade level and equivalent work. The appellant supervises a significant workload classified above that level as discussed in Factor 5. This represents a significant technical and administrative workload which warrants crediting this situation. 7. Changing Technology This situation is credited when work processes and procedures vary constantly because of the impact of changing technology, creating a requirement for extensive training and guidance of the subordinate staff. The appeal record does not support the crediting of this situation. 8. Special Hazard and Safety Conditions This situation is credited when the supervisory position is regularly made more difficult by the need to make provision for significant unsafe or hazardous conditions occurring during performance of the work of the organization, e.g., the safety demands inherent in supervising a laboratory using hazardous chemicals and procedures. Based on the types and amount of FWS workload in the branch, the appeal record supports the crediting of this situation. Therefore, we find that the position is creditable with four situations. Thus, the position is evaluated properly at Level 6-4 (1,120 points). Summary In summary, we have credited the position as follows: Factor Level Points 1. Program scope and effect 1-2 350 2. Organizational setting 2-1 100 3. Supervisory and managerial authority 3-3b 775 4A. Nature of contacts 4A-3 75 4B. Purpose of contacts 4B-3 100 5. Difficulty of typical work directed 5-4 505 6. Other conditions 6-4 1,120 Total Points 3,025 A total of 3,025 points falls within the GS-12 grade level point range of 2,755-3150 points on the Grade Conversion Table in the GSSG. Decision The position is properly classified as Supervisory Distribution Facilities Specialist, GS-2030-12.