U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeals and FLSA Programs Atlanta Oversight Division 75 Spring Street, SW., Suite 972 Atlanta, GA 30303-3109 Classification Appeal Decision Under section 5112 of title 5, United States Code Appellant: [Appellant] Agency classification: Packaging Specialist GS-2032-11 Organization: [Installation] [District] Defense Contract Management Agency [Location] OPM decision: Packaging Specialist GS-2032-11 OPM decision number: C-2032-11-02 /s/ _____________________________ Timothy P. Heath Classification Appeals Officer 5/10/01 _____________________________ Date As provided in section 511.612 of title 5, Code of Federal Regulations, this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards, appendix 4, section G (address provided in appendix 4, section H). Decision sent to: [Appellant] Director Human Resources Defense Contract Management Agency Defense Contract Management District East 495 Summers Street Boston, MA 02210-2184 Executive Director for Human Resources Defense Contract Management Agency Attn: DCMA-HRC 6350 Walker Lane, Suite 300 Alexandria, VA 22310-3240 Chief, Classification Appeals Adjudication Section Department of Defense Civilian Personnel Management Service 1400 Key Boulevard, Suite B-200 Arlington, VA 22209-5144 Introduction On January 8, 2001, the Atlanta Oversight Division of the U.S. Office of Personnel Management (OPM) accepted a classification appeal for the position of Packaging Specialist, GS-2032-11, [Installation], [District], Defense Contract Management Agency (DCMA), [Location]. The appellant is requesting that his position be classified as Packaging Specialist, GS-2032-12. This appeal has been accepted and processed under section 5112(b) of title 5, United States Code (U.S.C.). This is the final administrative decision on the classification of the position subject to discretionary review only under the limited conditions and time outlined in part 511, subpart F, of title 5, Code of Federal Regulations (CFR). General issues The appellant occupies one of three Packaging Specialist positions within [District] that were downgraded from GS-2032-12 to GS-2032-11 by DCMA. The downgrade action was based on the results of a consistency review, directed by the Department of Defense (DoD) Civilian Personnel Management Service, of all GS-2032-12 positions within DCMA. The appellant believes that the agency's action was incorrect and that not all factors relevant to his position were properly considered during the consistency review process. He also identifies what he believes are shortcomings in the OPM Grade Evaluation Guide for Supply Positions used to evaluate Packaging Specialist positions. He contends that, as the guide is not written specifically for packaging functions, not all of its terminology is applicable to Packaging Specialist work. 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 Position Classification Standard (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. Our decision sets aside all previous agency decisions regarding the classification of this particular position. The adequacy of grade level criteria in OPM PCS's and guides is not appealable (5 CFR 511.607). Position information The appellant is assigned to position description number [Number]. Neither the appellant nor his immediate supervisor certified the accuracy of the position description. OPM considers a position description adequate for classification purposes when the major duties and responsibilities of the position are listed, and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization's structure, mission, and procedures. We find the current position description contains the major duties and responsibilities and is adequate for classification. The appellant functions as a Packaging Specialist at [Installation]. He is responsible for implementing and monitoring the DCMA Packaging Management Program (PMP) at this facility. The PMP is intended to ensure that cost-effective optimum packaging is used wherever possible to provide proper protection during movement through the logistics pipeline. The appellant provides technical guidance to technical specialists and private contractors on proper accomplishment of the packaging function to meet contractual requirements. He performs surveys to assess contractor capability to meet performance requirements; develops surveillance plans to monitor contractor packaging programs; reviews all contracts to determine packaging requirements; identifies contractor deficiencies and issues deficiency reports; conducts post- award orientation conferences for new/inexperienced contractors to resolve misunderstandings regarding contracts; and reviews all contracts and solicitations from new contractors. The appellant is also responsible for providing training to contractors on matters pertaining to the packaging and preservation program and the handling and transporting of hazardous materials and wastes. He is also the primary provider of advice and interpretation of policies, specifications, standards and other matters and issues related to packaging. The appellant works under the supervision of the Contracts Technical Assessment Supervisor who provides very broad and general supervision. The appellant is the sole Packaging Specialist on the Corporate Support Team, and is responsible for independently planning and carrying out his work and making decisions regarding actions that are to be taken. His responsibilities include resolving any conflicts that arise, integrating and coordinating the work of others as needed, and interpreting policies within a framework of established objectives. The supervisor is advised of progress on assignments and matters or issues which could become controversial or have far reaching implications. Completed work is reviewed in terms of effectiveness in meeting objectives and achieving expected results. Series and title determination The appellant does not contest the series or title determination. The agency determined that the appellant’s position is best covered by the Packaging Series, GS-2032, and titled Packaging Specialist. Based on our audit and review of the record, we concur. Standard determination Packaging Series, GS-2032, July 1992. Grade Evaluation Guide for Supply Positions, July 1992. Grade determination The Packaging Series, GS-2032, standard does not contain grade level criteria. The standard indicates that non-supervisory positions in this series are classified according to the criteria contained in the Grade Evaluation Guide for Supply Positions (Guide). The Guide is written in the Factor Evaluation System (FES) format. Under the FES, positions are placed in grades on the basis of their duties, responsibilities, and the qualifications required as evaluated in terms of nine factors common to non-supervisory General Schedule positions. A point value is assigned to each factor based on a comparison of the position's duties with the factor-level descriptions in the standard. The factor point values mark the lower end of the ranges for the indicated factor levels. For a position factor to warrant a given point value, it must be fully equivalent to the overall intent of the selected factor-level description. If the position fails in any significant aspect to meet a particular factor-level description in the standard, the point value for the next lower factor level must be assigned, unless the deficiency is balanced by an equally important aspect, which meets a higher level. The total points assigned are converted to a grade by use of the grade conversion table in the Guide. The appellant disagrees with the agency's evaluation of Factors 3, 4, 5, and 7. We have reviewed the agency's evaluation of factors 1, 2, 6, 8, and 9 and concur with their findings. Therefore, only those factors contested by the appellant will be addressed in this decision. Factor 3, Guidelines: This factor covers the nature of guidelines and the judgment needed to apply them. Guides available for use in General Schedule occupations include desk manuals, established procedures and policies, traditional practices, and reference materials (e.g., dictionaries, style manuals, engineering handbooks, and the pharmacopoeia). Individual jobs vary in the specificity, applicability, and availability of the guidelines for performance of assignments. Consequently, the constraints and judgmental demands placed upon employees also vary. For example, the existence of specific instructions, procedures, and policies may limit the employee's opportunity to make or recommend decisions or actions. However, lacking procedures or under broadly stated objectives, employees may use considerable judgment in researching literature and developing new methods. The agency credited Level 3-3 for this factor. The appellant states that the guidance and regulations governing his activities are broad and general in nature, and only define basic policies and establish basic processes, responsibilities and mission goals. He further states that it is not possible for guidelines to be written in enough detail to cover the myriad of situations that he regularly encounters in providing technical assistance and support to contractors. He believes that Level 3-4 is correct for this factor. At Level 3-3, guidelines available and regularly used in the work are in the form of agency policies and implementing directives, manuals, handbooks, supply regulations, and locally developed supplements to guides, such as detailed work procedures and directives that supplement agency decisions. The guidelines are not always applicable to specific conditions or there are gaps in specificity when applying them to specific supply requirements. The employee uses judgment in interpreting, adapting, and applying guidelines where there is some overlap or conflict in the levels of support required, or other conditions requiring the employee to analyze and adapt procedures within the intent of the available guidelines. The employee independently resolves gaps in specificity or conflicts in guidelines, consistent with stated supply program objectives. Level 3-3 is met. Guidelines available and regularly used by the appellant consist of a wide variety of policies, regulations, directives, manuals, handbooks, instructions, and supplements developed by his agency and other agencies (e.g., DoD, National Aeronautics and Space Administration, Defense Logistics Agency, General Services Administration, Department of Transportation, and the military services). Typical of work at this level, the appellant is required to use judgment to interpret, adapt, and apply a wide range of specific regulations and procedural requirements which may conflict with each other. The appellant must analyze situations and resolve conflicts, overlaps, or gaps in specificity to develop procedures which conform to the intent of the guidelines and meet program objectives. Similar to Level 3-3, he provides advice and interpretations regarding packaging policies and recommends changes to promote program efficiency and effectiveness. At Level 3-4, guidelines provide a general outline of the concepts, methods, and goals of supply programs. The guidelines regularly applied at this level consist of broad supply guidance such as directives issued by national headquarters, general agency policy statements and objectives, interagency supply program policy proposals requiring refinement and coordination, or other guides that are not specific on how they are to be defined, implemented, and monitored at the employee's level. Guidelines at this level are purposely left open to allow local interpretation to accommodate local variations and remote environmental conditions that affect the nature of supply operations within overall policy direction. The employee exercises a great deal of personal judgment and discretion with broad latitude for interpreting and applying guidelines across the entire organization. Included at this level is the interpretation and application of guidelines originating from more than one Federal agency or department which apply to supply programs and organizations involving joint operations. The employee: ? Uses initiative and resourcefulness in researching and implementing new and improved supply methods and procedures within the employing organization; and/or ? Establishes criteria to identify and analyze trends in supply programs and requirements. In situations where guidelines for performing the work are scarce or of limited use, the employee develops guides to be followed by supply specialists at the same or lower levels in the organization. Level 3-4 is not met. The guidelines used by the appellant do not consist of general outlines of concepts, broad directives, general agency policy statements, interagency policy proposals requiring refinement or coordination, or other guides requiring significant interpretation to implement. Although the guidelines with which he works are not always totally applicable to specific circumstances and conditions which are encountered, they are not of such a broad or general nature that they are insufficient to accomplish specific program operations or objectives. The appellant functions as the installation's primary contact and technical authority and advisor for all packaging related issues. In this capacity, he exercises a significant degree of personal judgment and discretion and has broad latitude in the interpretation of guidelines. However, this does not typically result in researching and implementing new and improved supply methods and procedures within the organization, or establishing criteria to identify and analyze trends in supply programs and requirements as envisioned at this level. The packaging operations guidance provided to installation personnel and contractors by the appellant is not equivalent to developing guides to be followed by supply specialists at the same and lower levels in the organization as described at Level 3-4. Level 3-3 is credited for 275 points. Factor 4, Complexity: This factor covers the nature, number, variety and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty involved in identifying what needs to be done; and the difficulty and originality involved in performing the work. The agency credited Level 4-4 for this factor. The appellant states that policy guidance available to him is limited, outdated, in need of revision, or non-existent. For these reasons, he has developed new techniques, procedures and plans which satisfied policy objectives. He also cites a number of occasions where his headquarters requested his comments on draft policy documents and his membership in the installation’s Technical Assessment Group as evidence of influencing overall agency policies. He believes that Level 4-5 is correct for this factor. At Level 4-4, employees perform assignments consisting of a variety of supply duties involving many different and unrelated processes and methods in well-established areas of supply planning and administration. Typically, the work requires analysis and testing of a variety of established techniques and methods to evaluate alternatives and arrive at decisions, conclusions, or recommendations. Programs and projects may be funded by, or under the cognizance of, different organizations with differing supply requirements or variations in ability to fund acquisitions or system implementation. Requirements to follow established supply policies, practices, procedures, and techniques may have to be varied for a number of locations or situations to assure compatibility with existing systems and demands on available resources. In deciding what must be done, the employee typically assesses situations complicated by conflicting or insufficient data. Information must be analyzed to determine the applicability of established methods, the need to digress from normal methods and techniques, the need to waive prescribed standards, and whether specific kinds of waivers can be justified. Level 4-4 is met. The appellant’s work involves packaging management activities, including administration of contractual provisions related to the preservation, packaging, marking, handling, and transportation of all commodities procured by both DoD and non-DoD activities. The appellant's primary responsibility is to survey, monitor, and review contractor performed packaging work. He makes recommendations to ensure conformance with requirements and arrival of commodities at their destinations in a timely, damage-free and economical manner. The work requires analyzing and testing a variety of well-established packaging techniques and methods and approving or denying requests for deviations from established procedures. The appellant identifies and resolves problems and delays in packaging, shipping and storage processes; identifies and recommends acceptable alternative methods; develops specifications or modifies existing techniques to accommodate special packaging needs; and recommends changes to promote packaging program efficiency and effectiveness. At Level 4-5, employees perform assignments involving various projects, studies, or evaluations requiring the application of many different and unrelated processes, differing regulatory criteria and procedures, and significant departures from established practices. Employees make decisions or develop and implement new methods and techniques that satisfy broad policy and technical requirements. Employees at this level make recommendations for changes in basic policy issuances and implementing instructions covering established supply techniques, practices, and methods based on personal analysis of very general policy directives and objectives. Examples of work at this level are: ? Interpreting and implementing new directives for subordinate organizations and field units. The work originates from additions to, or changes in, national or agency policies and programs or identification of deficiencies in established programs. ? Evaluating the efficiency of supply programs involving customer services covering a wide span of supply and acquisition processes and procedures. The work involves studying and evaluating relationships between customer requirements, acquisitions lead times, storage, inventory, issuance, and delivery by the most efficient and economical means possible. The employee evaluates current methods and processes, identifies areas that can be improved, considers customer missions relative to budget and stock levels, and recommends methods and techniques for improving supply operations. ? Analyzing and evaluating the adequacy of automated supply systems to identify needs for system improvements in the input, output, and uses of data used in supply management programs in a centralized supply record and information support activity. The employee identifies new computer support requirements based on program and policy changes, additions, and deletions. The employee performs steps necessary to define the flow of information and source material in the existing supply system. The employee identifies the kinds of data bases required, the variety of programs needed to make a complete system, and production requirements. Level 4-5 is not met. The appellant's work does not typically involve projects, studies, or evaluations requiring the application of many different and unrelated processes, differing regulatory criteria and procedures, and significant departures from established practices. The appellant makes decisions and recommendations that are variations of established supply policies, practices, procedures, and techniques. However, this does not involve originating new packaging techniques, establishing packaging criteria, or developing and interpreting broad supply policies and regulations, which is typical of Level 4-5. Level 4-4 is credited for 225 points. Factor 5, Scope and Effect: This factor covers the relationship between the nature of the work (i.e., the purpose, breadth, and depth of the assignment) and the effect of work products or services both within and outside the organization. Effect measures such things as whether the work output facilitates the work of others, provides timely services of a personal nature, or affects the adequacy of research conclusions. The concept of Effect alone does not provide sufficient information to properly understand and evaluate the position. The Scope of the work completes the picture allowing consistent evaluations. The agency credited Level 5-3 for this factor. The appellant states that his reviews and analyses of packaging requirements and his recommendations have resulted in technical changes in customer databases. He believes that these changes have impacted the packaging activities of the military services and will affect the supply systems of organizations within and outside his agency. He believes that Level 5-4 is correct for this factor. At Level 5-3, the work involves resolving a variety of conventional supply problems, questions, or situations. The employee monitors established supply systems and programs or an assigned block of activities in one of the technical supply areas, performs independent review, and/or recommends actions involving well-established criteria, methods, techniques, and procedures. The employee’s work products, advice, and assistance affect the efficiency of established supply operations or specialized programs and contribute to the effectiveness of newly introduced programs requiring supply support. The effect of the work is primarily local in nature, although some programs may be part of multi-facility or nationwide program operations with interlocking supply requirements. Level 5-3 is met. The work performed by the appellant involves investigating and analyzing a variety of conventional packaging and material handling problems, questions, and conditions. He develops alternatives and options to established procedures to assist contractors, whose packaging operations involve a wide variety of physical and environmental circumstances and meet contractual requirements and specifications. The appellant has responsibility for monitoring the operations of assigned contractors through reviews, analyses, surveys and assessments. The appellant's work products, advice, and assistance affect the efficiency of established contractor operations and contribute to the effectiveness of newly introduced programs requiring supply support. While his work can impact other facilities or installations, the primary impact is on the activities of DCM [location]. At Level 5-4, the work involves investigating and analyzing a variety of unusual supply problems, questions, or conditions associated with general questions about supply programs, formulating projects or studies to substantially alter existing supply systems, or establishing criteria in an assigned area of specialization. Employees develop alternatives and options that are designed to meet requirements in a variety of physical and environmental circumstances. The employee’s work affects supply system design, installation, and maintenance in a wide range of activities within the organization and in non-government organizations. Level 5-4 is not met. The appellant's regular and recurring activities do not entail investigation or analysis of unusual program problems, the formulation of projects or studies which substantially alter existing packaging program systems, or involvement with broad program issues typical of this level. His work does not directly affect packaging system design, installation, and maintenance in a wide range of activities within his organization or outside organizations. The focus of the work he performs is to ensure that contractors conform with established program and contractual requirements and specifications. Level 5-3 is credited for 150 points. Factor 7, Purpose of Contacts: The purpose of contacts ranges from factual exchanges of information to situations involving significant or controversial issues and differing viewpoints, goals, and objectives. The agency credited Level b. The appellant states that he participates in actions where contracts are terminated for cause by the government. In these instances, he is responsible for arranging for the packaging and removal of commodities from the contractor's facility. He maintains that these are very volatile situations where the contractors are usually very irate and far from cooperative. He believes that Level c is correct. At Level b, the purpose of contacts is to plan, coordinate work, or advise on efforts and resolve operating problems by influencing or motivating individuals or groups who are working toward mutual goals and who have basically cooperative attitudes. Level b is met. The appellant’s regular and recurring contacts are primarily for the purpose of planning and coordinating work, advising contractors on requirements needed to meet contractual requirements, obtaining compliance with policies and regulations, resolving operating problems and disputes, or obtaining information regarding the efficiency and effectiveness of contractor operations. The parties contacted are typically cooperative and working toward mutual goals. Although there may be areas of disagreement, the contacted parties are primarily interested in ensuring their operations conform with applicable policies and requirements and allow them to keep their contracts. At Level c, the purpose of contacts is to influence, motivate, interrogate, or control persons or groups. The persons contacted at this level may be fearful, skeptical, or uncooperative. In these situations, the employee must be skillful in approaching the individual or group in order to obtain the desired effect, such as gaining compliance with established policies and regulations by persuasion or negotiation. Level c is not met. The appeal record contains no indication that the appellant must routinely influence, motivate, or control individuals or groups who are fearful, skeptical, or uncooperative, where some degree of skill must be used in approaching them to avoid hostile situations. His primary responsibility is to advise contractors on what they must do to maintain their status, assist them in resolving operational problems, and recommend alternative methods that will allow them to meet conditions specified in their contracts. There is no evidence that the appellant’s normal contacts involve parties that are hostile or uncooperative. Level b is credited for 50 points. SUMMARY FACTOR 1. Knowledge Required by the Position LEVEL 1-7 1250 POINTS 2. Supervisory Controls LEVEL 2-4 450 POINTS 3. Guidelines LEVEL 3-3 275 POINTS 4. Complexity LEVEL 4-4 225 POINTS 5. Scope and Effect LEVEL 5-3 150 POINTS 6. Personal Contacts and 7. Purpose of Contacts LEVEL 3b 110 POINTS 8. Physical Demands LEVEL 8-2 20 POINTS 9. Work Environment LEVEL 9-2 20 POINTS Total 2,500 POINTS A total of 2,500 points falls within the range for grade GS-11, 2,355 to 2,750 points, according to the Grade Conversion Table in the Guide. Decision The appellant’s position is properly classified as Packaging Specialist, GS-2032-11.