U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeal and FLSA Programs Chicago Oversight Division 230 S. Dearborn Street, DPN 30-6 Chicago, IL 60604-1687 Job Grading Appeal Decision Under section 5346 of title 5, United States Code Appellant: [appellant] Agency classification: Motor Vehicle Operator WG-5703-06 Organization: [activity] Administrative Support Service Line Medical Center Department of Veterans Affairs [location] OPM decision: Motor Vehicle Operator WG-5703-06 OPM decision number: C-5703-06-04 _____________________________ Ricardo Sims Operations Supervisor July 17, 2002 _____________________________ Date As provided in section S7-8 of the Operating Manual: Federal Wage System, 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 and time limits 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). Decision sent to: Appellant: [appellant's name and address] 6499 Agency: [appellant's human resources office] Ms. Ventris C. Gibson Deputy Assistant Secretary for Human Resources Management (05) Department of Veterans Affairs 810 Vermont Avenue, NW, Room 206 Washington, DC 20420 Introduction On March 12, 2002, the Chicago Oversight Division of the U.S. Office of Personnel Management (OPM) accepted a job grading appeal from [the appellant] who is employed at the Department of Veterans Affairs Medical Center (VAMC) in [location]. The appellant is employed as a Motor Vehicle Operator, WG-5703-6, in the [activity] of the Administrative Support Service Line. He believes that his job should be graded as Motor Vehicle Operator, WG-5703-7 or 8. As required by statute, [the appellant] initially appealed the grading of his job to his agency, which sustained the grading as WG-5703-6. We received the agency’s administrative report on April 18, 2002. We accepted and decided his appeal under section 5346 of title 5, United States Code (U.S.C.). During our fact-finding, we interviewed [the appellant]; the Acting Maintenance and Operations Supervisor, and the Administrative Support Service Line Chief. We reviewed and considered all of the material submitted by the appellant and his agency. General issues Based on the types of vehicles the appellant is required to operate within [a specific] State, he is required to obtain and retain a [State] commercial driver’s license (CDL). He cited a definition prescribed by the Department of Transportation for a commercial motor vehicle as “a motor vehicle which carries 16 or more passengers,” requiring a CDL. The appellant’s current CDL class is “C” for the transportation of passengers and contains an endorsement and a restriction. The endorsement is for Passenger (P), vehicles designed to transport 16 or more passengers including the driver, which includes a required road skills test. The restriction is (L), which limits the driver to vehicles not equipped with air brakes. Trades and labor jobs are graded considering the actual skill, knowledge, and other requirements of the work performed. The requirement that employees be licensed or certified to perform work, or that they certify with their signatures that standards of quality and safety have been met in performing work, does not in itself affect the grades of their jobs. Therefore, the requirement that the appellant have a commercial driver's license is not relevant in determining the grade of his work. The appellant provided a copy of the title of one of the vehicles he operates, which lists the body type as “bus.” He also provided a copy of the purchase order for another vehicle that describes it as a “transit bus” with a rear-lift for the wheelchair unit. The appellant believes that the documents he provided containing the word “bus” proves his contention that the passenger vehicles he regularly operates meet the definition and description of a “bus” at the WG-7 level of the Job Grading Standard for Motor Vehicle Operator, WG-5703. Additionally, he cited a definition of “bus” from section 571.3 of title 49, Code of Federal Regulations (CFR), as “a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.” The label that other organizations use to refer to the vehicle is not relevant to the grading of this job. In adjudicating his appeal, our only concern is to make an independent decision on the proper grading of the job. By law, we must make that decision solely by comparing the appellant’s current duties and responsibilities to appropriate OPM job grading standards and guidelines (5 U.S.C. 5346). Therefore, we have considered the above references only insofar as they are relevant to making that comparison. The appellant believes that if his appeal is upheld, he will be entitled to back pay including overtime retroactive to April 15, 1999. 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, back pay is not available as a remedy for misassignments to higher level duties or improper classifications” (CG decision B-232695, December 15, 1989). Job information The appellant’s primary duty is to transport patients between two VAMCs. He operates a variety of vehicles with different passenger capacities to accommodate the number of patients from [a VAMC] being transported to and from [a VAMC]. The number of patients being transported each way varies and is not typically the same. For example, eight patients may be transported to [another VAMC] in the morning and that afternoon there may be more or fewer than eight patients being transported back to [the appellant's VAMC], depending on the type of surgery these individuals undergo. [The appellant's VAMC] does not perform major surgeries such as hip or knee replacement, eye surgery, and vascular surgery (for example, heart transplants, stints). The one-way trip between [two VAMCs] is approximately 255 miles, or five hours of travel time. The appellant stated the total round trip mileage is 525 miles. The Service Line Chief does not dispute the number of hours or miles driven by the appellant on the [two VAMC] route. The round trip is scheduled daily, Monday through Friday, departing the [the appellant's VAMC] at approximately 7:00 a.m. and returning 10 to 11 hours later. The Service Line Chief and the appellant agreed to a work schedule change for the appellant from Monday through Friday, to four 10-hour days, Monday through Thursday, to accommodate both the installation and the appellant. Another Motor Vehicle Operator makes the round trip one day a week and in the absence of the appellant. The appellant believes the distance driven between these two VAMCs should be considered as long-distance driving which results in fatigue and stress. The appellant operates a variety of vehicles to include, but not limited to, a Ford Explorer 4x4, a Dodge Caravan minivan with oxygen holder (hereafter referred to as Dodge Caravan), a GMC Vandura 15-passenger bus with oxygen holder (hereafter referred to as GMC Vandura), and a Dodge 3500 15-passenger bus with wheelchair lift (hereafter referred to as Dodge 3500). According to the Service Line Chief, the Dodge 3500 is approximately 5,000 pounds gross vehicle weight (GVW). To determine how often the appellant drives these vehicles, we asked for copies of motor vehicle trip tickets for a typical month. The appellant provided trip tickets for February 2001 and March 2002. The apparent differences between the two months (Tables 1 and 2 below) are that the Ford 20-passenger bus (hereafter referred to as Ford Bus) with oxygen holder and wheelchair lift (approximately 17,000 pounds GVW) was the vehicle used most frequently in February 2001. After February 2001, the Ford Bus broke down on several occasions and the agency decided to discontinue its use for trips to [another VAMC] because of diminishing reliability and dependability and the costly repairs. Therefore, we will not consider the Ford Bus in our evaluation of the appellant’s duties since he is not currently required to drive it. In March 2002, the GMC Vandura vehicle was used most frequently. Table 1 February 2001 (Appellant’s work schedule 8 hours per day, Monday through Friday) Vehicle Number of Times Used Percentage of Time Occurrences Attendant Present Ford Bus 9 53% 1 Dodge Caravan 7 41% 2 Dodge 3500 1 6% 0 Table 2 March 2002 (Appellant’s work schedule 10 hours per day, Monday through Thursday) Vehicle Number of Times Used Percentage of Time Occurrences Attendant Present Ford Bus 1 6% 1 Dodge Caravan 4 23.5% 0 Dodge 3500 4 23.5% 1 Ford Explorer 1 6% 0 GMC Vandura 7 41% 4 There is no specified percentage-of-time requirement for grade controlling duties, though low percentages warrant examination to ensure the duties are repetitively performed on a continuing basis (regular and recurring), require the full range of work and qualifications characteristic of the grade, and are performed under normal supervision. Occupation, title, and standard determination The primary purpose of the appellant’s job is to operate a variety of vehicles to transport patients between the [two VAMCs], and to perform other trips as assigned. This work is covered by the FWS Job Grading Standard (JGS) for Motor Vehicle Operator, 5703, dated April 1991, which includes jobs involved in the operation of gasoline and diesel powered wheeled vehicles to haul cargo and transport passengers. The designated title for nonsupervisory jobs in this occupation is Motor Vehicle Operator. The appellant does not disagree with the assigned occupational code or title of his job. Grade determination The WG-5703 JGS contains job grading criteria expressed in the form of four factors: (1) skill and knowledge, (2) responsibility, (3) physical effort, and (4) working conditions. A job is graded as a whole against the level of demands found at differing grades. No single factor is considered by itself, but only in relation to its impact on the other factors. A job is classified to the grade that best represents the overall demands of the work. The WG-5703 JGS contains several notes to users. One states that indicators such as GVW, load capacity, number of forward speeds, number of driving (powered) wheels, and passenger capacity have been routinely used as the primary criteria for determining grade levels of motor vehicle operator jobs. These indicators are insufficient for determining the grade of the total job since they do not give consideration to all features of the job which affect the four grade determining factors of skill and knowledge, responsibility, physical effort, and working conditions involved in performing the work. However, GVW provides a frame of reference from which to conduct a complete analysis and evaluation of a job. Therefore, GVW is being retained as a means of establishing a framework in grade analysis for straight-in-line vehicles, i.e., vehicles that are unitized with the axles, power source or cab portion of the vehicle, and load carrying body all on the same chassis. This indicator does not directly apply to passenger buses, passenger ambulance buses, or motor coaches. The final grade level for all motor vehicle operator jobs is based on a thorough consideration of the four grading factors of the total job. The route the appellant drives typically exceeds 10 hours. For exposures to conditions of an unusual nature, employees are compensated by means of environmental pay differentials rather than job grading. The Operating Manual for the Federal Wage System (FWS), Subchapter S8-7 and Appendix J, are used to determine whether hazards, physical hardships, or working conditions are of an unusual nature. However, if such a determination is made that a condition exists, and it is regular and recurring, any related skill and knowledge and responsibility should be taken into account in grading the job. This may or may not result in a change in the basic grade of the job as shown by the applicable standard. Skill and knowledge The appellant states he was hired to operate the Ford Bus on the [two VAMC] route on a daily basis. As previously mentioned in the Job information section of this decision, the Ford Bus is no longer used for this route and is not considered in our analysis of the duties of the appellant’s job. The appellant operates a variety of vehicles of varying lengths, widths, and heights to transport patients and accompanying medical personnel. The smallest of the vehicles, for example, is 16 feet 4 inches long, 7 feet 4 inches wide, and 5 feet 8 inches in height. The largest of the vehicles is 19 feet long, 8 feet wide, and 7 feet 9 inches in height. According to the appellant, both the Dodge 3500 and GMC Vandura have modifications that add to their height and weight. The Dodge 3500 is the largest and heaviest vehicle the appellant operates. The height of this vehicle was increased by 12 inches to accommodate the rear wheelchair lift, which also added weight to the rear of the vehicle. In the absence of the primary and back-up drivers, the appellant operates the laundry truck, 24,500 pounds GVW, which is 30 feet 2 inches long, 9 feet 2 inches wide, and 11 feet 5 inches in height and includes dual wheels on the rear axle, manual transmission, and air brakes. FWS work is graded based on the regular and recurring duties of the job that involve the highest skill and qualification requirements, even though the duties may not be performed most of the time. Duties performed only in the absence of another employee, to meet emergency workloads, or for development are not considered regular and recurring. Therefore, the appellant’s driving of the laundry truck only in the absence of the primary and back-up drivers will not be considered further in this decision. The WG-5703 JGS explains that an underlying premise of the standard is that the vehicles described at each grade level are operated on Government installations and on public roads in a full range of traffic conditions, or in installation environments that exhibit the same driving characteristics as public roads, on a regular and recurring basis. The JGS defines those public road characteristics. They include widely dispersed urban and rural roadway systems, two-lane and four-lane highways, various weight limits and vehicle prohibitions on certain roads or bridges, a range of driving speeds as well as highway speed limits on some roads; various traffic signals and multiple types of intersections, frequently heavy traffic congestion, and sharp curves and blind or steep hills. The standard further states that in those instances where drivers do not use their vehicles on public roads (or the equivalent), a lower grade level than the one depicted in this standard for the type of vehicle operated is appropriate. To support his belief that duties of his job exceed the WG-6 level and equal that of the WG-7 or 8 level, the appellant cites various factors. They include the operation of vehicles with capacities over 15 passengers, a requirement to possess a CDL with an endorsement and restriction, medical personnel who infrequently accompany patients on trips, and possession of a cardiopulmonary resuscitation (CPR) card (although not required by the appellant’s installation). The appellant submitted copies of numerous reports, articles, regulations, and advisories with his appeal, including traffic and accident rate statistics over interstates, hours of service to improve commercial motor vehicle safety, and a 15-passenger van safety advisory. Additionally, he submitted detailed information about the various interstates and road and weather conditions encountered on the trip to [another VAMC] and the return trip to [the appellant's VAMC]. The route utilized by the appellant uses two of the busiest interstates in the Southeast, 64 and 81, and also Interstates 77 and 95. The route stretches through rural and urban areas, including [a city] which has a population of 800,000. The appellant encounters valleys and several mountain ranges, bridges, four-lane and six-lane expressways with maximum speeds of 70 miles per hour, and a grade of 7% for five miles through the Sandstone Mountain (equates to 7 feet descent per 100 feet of roadway for a total descent of 1,850 feet). Other variables that affect driving this route include crosswinds, adverse weather conditions (rain, snow, sleet, and ice), and dense fog. The appellant provided photographs and information about electrical fog lights along parts of Interstate 64 and truck pull-offs. The appellant checks the vehicles’ fluid levels, tire pressure, and gasoline level prior to loading the passengers and departing the VAMC. Although trips typically originate and end at the [appellant's VAMC], the appellant states that there are occasions when he collects and delivers patients at their residences so they do not have to drive to the [appellant's VAMC]. He assists patients and any accompanying medical personnel in and out of the vehicle, operates the wheelchair lift (depending on the vehicle) in a safe manner, ensures all passengers are safely secured, and ensures straps for wheelchairs and oxygen holders are safely secured. The appellant stated that many patients use a manual or electric wheelchair, oxygen, walker, cane, or crutches which require him to provide extra assistance. He also assists patients off and on the vehicle for the four to six stops during each round trip for rest breaks, restroom breaks, self-medication breaks, and gasoline fill-ups. The Dodge 3500 has a wheelchair lift that requires hydraulics, safety guards, and the vehicle to be in the “park” position with the emergency brake engaged. The Dodge 3500 does not have a power takeoff device for transferring engine power to special-purpose accessory equipment, such as the wheelchair lift. Motor Vehicle Operators at the WG-6 level operate and perform operator maintenance on one or more motor vehicles including platform trucks, van trucks, stake trucks, dump trucks, ambulances or patient transport vehicles, passenger shuttle vans, and cargo vans which typically have an approximate GVW of more than 10,000 pounds and up to 26,000 pounds. Some of these vehicles may be equipped with air brakes. Vehicles are driven over public roads (or the equivalent) at highway speeds under the same types of traffic and driving conditions as described at the WG-5 level, that is, adjusting driving methods to the practices of surrounding traffic to avoid accidents and operate safely according to State and local safety regulations and rules and the rules of surrounding jurisdictions (for example, surrounding States). The vehicles operated may be equipped with a power takeoff device for transferring engine power to special-purpose accessory equipment, such as winches, power lifts, plows, and spreaders. Drivers at the WG-6 level drive ambulances or patient transport vehicles to pick up and transport patients under nonemergency conditions from one location to another such as from an airport to a hospital or from one hospital to another. They drive on public roads at controlled speeds to ensure the patient’s comfort. The drivers assist the accompanying medical personnel in loading, unloading, and securing litter patients. Some drivers at the WG-6 level drive passenger shuttle vans over predetermined routes and arrive at and depart from pick up and discharge points at scheduled times. They also may drive shuttle vans on special runs for meetings and other activities. The drivers check authorized passes on all passengers. They adhere to all State, local, and installation traffic laws and ordinances. The drivers have skill in maneuvering and braking the vehicle to avoid jostling the passengers. They have the ability to deal effectively with people in a hospitable manner. Also, they have skill in selecting alternate routes to avoid heavy traffic or other delaying conditions, and they have skills in map reading in order to reach unfamiliar locations. Drivers of ambulance or patient transport vehicles may be required to know basic first aid and CPR techniques to assist medical technicians in treating patients when requested. They are familiar with the medical equipment in the vehicle and can quickly locate such equipment for the medical technicians. They have skill in driving the vehicle in various road conditions to transport patients to their destinations, and they know how to properly load and secure litter patients in the vehicle. At the WG-6 level, drivers of vehicles equipped with special-purpose accessory equipment know how to use the power takeoff device to transfer engine power to the equipment, and they have skill in manipulating a variety of controls and understanding equipment gauges. For example, the driver may operate a winch on a flatbed truck or a snow auger or plow with a salt or sand spreader on a dump truck. At the WG-6 level vehicles operated are typically higher, wider, longer, and heavier than those described at the WG-5 level. The driver has knowledge to make more difficult judgments relative to the vehicle concerning loading and arranging cargo, overhead and side clearances, the turning radius, braking distance, and distance to be maintained from other vehicles. Drivers must be selective in determining which routes to take because of the size and weight of the vehicle and the laws restricting the use of some roads by the types or size of vehicles driven. In contrast, drivers at the WG-7 level operate one or more motor vehicles including platform trucks, van trucks, fuel trucks, stake trucks, dump trucks, and trash removal trucks which typically have an approximate GVW of more than 26,000 pounds and up to 32,000 pounds. Also at this grade level, drivers may operate passenger buses or passenger ambulance buses regardless of GVW. All of these vehicles are usually equipped with air brakes. They are operated over public roads (or the equivalent) at highway speeds to transport passengers, patients, supplies, materials, or equipment and tools throughout rural or urban areas. Drivers perform operator maintenance on all vehicles operated (e.g., monitoring fluid levels, replacing air filters and interior lights, checking tire pressure and hose connections, and washing the vehicle). Some drivers at the WG-7 level operate a variety of passenger buses on scheduled or special runs from one location to another. Scheduled runs include work runs and shuttle runs. The drivers are required to maneuver the bus around sharp corners and through narrow streets and roadways. Drivers at this grade level may also operate passenger ambulance buses which are equipped with litter facilities and other medical support equipment. These vehicles are driven with the same medical mission and driving conditions and requirements as described for ambulance or patient transport vehicle drivers at the WG-6 level, except that these drivers operate larger and longer vehicles and transport patients and their family members and medical personnel. At the WG-7 level, drivers know how to operate vehicles that are larger and longer than those driven by lower grade levels, have heavier loads to secure, have air brakes, and are more susceptible to sliding and tipping. The vehicles are difficult to maneuver, particularly when turning and backing. Drivers have skill and knowledge to operate these vehicles over a variety of roads including interstate highways, narrow country roads, and steep winding grades. Also, because of the size and weight of these vehicles, drivers are knowledgeable about which routes may be legally driven and the overpass clearances and other restrictions on such routes. Drivers of passenger buses at the WG-7 level have knowledge of safe braking distances because of the weight and size of the bus and the added weight of the passengers. They also know when mechanical or operational problems indicate that the bus is unsafe to drive and should be recovered by a tow vehicle. The drivers of vehicles equipped with special-purpose accessory equipment know how to operate power takeoff controls of equipment with more complex functions than the equipment at the WG-6 level. Also, this equipment has more intricate operating characteristics than equipment at the lower levels which makes its manipulation and control more difficult. For example, the driver may operate a large snow blower or very large snow plows such as rollover or v-blades for removing deep snow. Consequently, considerable judgment and experience are used to perform supplemental operations. The appellant's job fully meets the intent of the skill and knowledge requirements for the WG-6 level. As at this level, the appellant has skill in driving vehicles in various road conditions to transport patients to and from [another VAMC]. He also has skill in braking and maneuvering the vehicle to avoid jostling the passengers and in selecting alternate routes to avoid heavy traffic. To meet the WG-7 level, an operator must apply the full range of skill and knowledge described at that level. At the WG-7 level, most of the vehicles driven are equipped with air brakes. None of the vehicles the appellant drives on a regular and recurring basis are equipped with air brakes. Further, the appellant does not drive vehicles that require operating power takeoff controls, and he does not operate the vehicles under the full range of driving conditions intrinsic at the WG-7 level. Therefore, the skill and knowledge required by the appellant's job does not exceed the WG-6 level. The appellant’s job does not meet the aspects of the WG-8 level, which requires even greater knowledge and skill in the operation of vehicles since the vehicles driven have limited maneuverability; have more than one body and two braking systems; or are oversized and carry large groups of people on trips where long periods of day and night driving are involved. Drivers at this level use greater skill and knowledge in turning the vehicles, in evaluating the condition and load limits of bridges, in scheduling weigh points, and in assessing traffic conditions and hazards locally and over long-distance routes in unfamiliar geographic areas. For example, drivers at the WG-8 level operate truck tractors with semi-trailers or full trailers, and motor coaches where they maneuver oversize vehicles within close tolerances in narrow or congested areas or between buildings or loading docks. Responsibility The appellant maintains use of expert judgment when operating any of the vehicles he uses to transport patients; determines alternate routes in the event accidents, long delays, or adverse weather conditions are encountered; and possesses two Government-issued credit cards for gasoline, parts, and supplies for motor vehicles. The appellant receives instructions from his supervisor both orally and in writing in the form of posted motor vehicle trip tickets. The appellant verifies the number of patients with the Admissions Department and gathers any medical records, x-rays, or similar documents that must accompany a patient. After unloading patients at [one VAMC], the appellant repeats the process of verifying the number of patients and materials for the return trip back to [the appellant's VAMC]. On average, he transports 30 patients to and from [a VAMC] over the course of the four days he drives the route. The Service Line Chief and the Acting Maintenance and Operations Team Supervisor stated that they review and evaluate the appellant’s work based on completed motor vehicle trip tickets and complaints reported by passengers to the Customer Service/Travel Section. The Service Line Chief added that reliability and dependability are important factors when assessing the appellant’s work. Drivers at the WG-6 level receive instructions from the supervisor as to the type of vehicle to be operated, destination, cargo, passengers or patients to be transported, deadlines to be met, and any special information important to the mission. Their work is assessed in terms of the safe and expeditious completion of the assigned job. They are responsible for selecting routes and obeying all traffic laws and safety regulations, as well as the safe loading and unloading of the vehicle. Performance of preventive maintenance and preparation of trip tickets are reviewed for adequacy and compliance with instructions. WG-7 level drivers receive instructions similar to those described at the WG-6 level. Additionally, some drivers determine the route to be followed, taking into consideration such factors as the clearance of underpasses, overhead power lines, weight limitations, highway restrictions, and alternate bypass routes. Other drivers who are assigned prescribed routes for such trips as work runs, shuttle runs, or medical transportation runs are responsible for knowing acceptable alternative routes for use in emergency situations which will legally accommodate the size and length of the vehicle being driven. Drivers at the WG-7 level accomplish their assignments with considerable independence. Work is evaluated in terms of timeliness and driving competence. The manner in which the appellant's assignments are received and his work is reviewed is similar to the WG-6 level. As at the WG-6 level, the appellant decides which route to take based on prior experience driving the variety of vehicles. Further, the appellant is responsible for preventive maintenance tasks and preparation of trip tickets as described at the WG-6 level. While the appellant determines the route to be followed, overhead power lines, weight limitations, clearance of underpasses, and highway restrictions are not significant concerns as required at the WG-7 level. In addition, the appellant does not operate at the level of independence described at the WG-7 level. At the WG-8 level, responsibility is greater than described at the grade 7 because the size and type of the vehicle increase the tendency of the trailer to sway and the driver to lose control of the vehicle. At this level, motor coach drivers are responsible for operating oversize vehicles on extended trips and carry a larger number of passengers than are transported by conventional buses at the grade 7 level. The appellant's round-trip drives do not meet the intent for long-distance, extended trips as described at the WG-8 level. We credit the WG-6 level for this factor. Physical effort The appellant operates a variety of vehicles that accommodate up to 15 passengers; patients are typically 50-80 years old and require assistance because they use manual or electric wheelchairs, crutches, canes, walkers, or oxygen tanks; and the trip requires more than one stop for gasoline and rest and restroom breaks which entails the appellant unloading and reloading the patients. When a medical attendant accompanies a patient, it is usually because that individual requires additional assistance. The appellant contends that his job requires more physical effort than described at the WG-6 level. At the WG-6 level, drivers use greater physical effort than at lower levels in order to maneuver the longer and heavier vehicles, especially when backing these vehicles. Patient transport vehicle drivers may be required to assist patients into and out of the vehicle, and this involves physical exertion and frequent stooping and bending. In addition to the physical effort described at the WG-6 level, drivers at the WG-7 level exert moderate physical effort in operating, turning, backing, and controlling the vehicle which carries larger numbers of people than the vehicles credited at the grade 6 level. The appellant's job fully meets the requirements of the WG-6 level. The appellant does not operate vehicles that require him to exert the extra physical effort described at the WG-7 level. Unlike drivers at the WG-8 level, the appellant is not required to exert moderate to heavy physical effort in operating, turning, backing, and controlling vehicles which carry heavier loads or larger numbers of people than vehicles at the grade 6 level. This factor meets the WG-6 level. Working conditions At the WG-4 level, drivers are exposed to dirt and fumes and to the possibility of cuts, bruises, and broken bones as a result of accidents while driving or from falling objects when loading or unloading the vehicle. In addition to the working conditions described at the grade 4 level, drivers at the grade 5 level operate vehicles in all types of traffic and weather on public roads (or the equivalent) and are exposed to the danger of serious accidents. They drive in heavy traffic and at highway speeds over complicated road and interchange systems. The working conditions are the same at grade levels 5 and above. In view of the skill and knowledge required and the responsibility exercised, the appellant’s job equates to the WG-6 level. Summary The JGS instructs that the final grade is to be based on a consideration of the four grading factors as applied to the total job. The appellant’s work equates to the WG-6 level for all four factors. Decision The appellant’s job is properly graded as Motor Vehicle Operator, WG-5703-6.