United States

Office of Personnel Management

DIGEST OF SIGNIFICANT

CLASSIFICATION DECISIONS

AND OPINIONS

No. 20

October 1997

Office of Merit Systems

Oversight & Effectiveness

Preface

This is the twentieth issue of the DIGEST OF SIGNIFICANT CLASSIFICATION DECISIONS AND OPINIONS. In it we present summaries of several decisions and opinions that we believe have governmentwide applicability. The General Schedule Supervisory Guide continues to raise significant interpretive issues. In order to provide clarifying guidance that will ensure consistency of interpretation with respect to those issues, we are devoting Digest 20, as we did Digest 19, to articles on the General Schedule Supervisory Guide. The Digest is designed to aid classifiers in exercising their judgment; Digest items do not supersede or supplement classification standards and do not constitute "case law."

Suggestions for improving future issues of the Digest may be made via email to fedclass_appeals@opm.gov or fax at 202-606-2663, or by writing to the Director, Classification Appeals and FLSA Programs, U.S. Office of Personnel Management, 1900 E Street, NW., Washington, DC 20415-0001. The telephone number is 202-606-2990.

Digest issues are also available on the Office of Personnel Management's website and electronic bulletin board. The website address is http://www.opm.gov/classapp [OPM ONLINE was discontinued July 1999. The Digest can also be found on OPM's CD-ROM entitled General Schedule Position Classification and Federal Wage System Job Grading Standards, which is issued by OPM's Classification Programs Division.]

This issue of the Digest was edited by Mr. Robert Hendler (Philadelphia Oversight Division). Contributions were provided by Mr. Hendler, Ms. Kathy Day (Atlanta Oversight Division), Ms. Bonnie Brandon (Dallas Oversight Division), Mr. Delmar White (Office of Classification), and Mr. Denis Whitebook (San Francisco Oversight Division).

Jeffrey D. Miller, Director

Classification Appeals and FLSA Programs

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	N/A

Issue:	Coverage of the General Schedule Supervisory Guide for Supervision of Small Workloads

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of an appeal. The appellant occupied a Telecommunications Manager, GS-0391-12, position at a moderately large transportation facility, servicing approximately 1,800 employees. The appeal for upgrading was based on supervising three subordinate GS-0391-12 positions. The subordinate positions had been upgraded to the GS-12 grade level by a manager with delegated classification authority contrary to the advice provided by the servicing personnel office. The position description of record indicated that the appellant spent 10 percent of the work time on administrative supervisory functions. A proposed new position description credited the position with performing supervisory functions 25 percent of the work time.

Resolution

During the audit, the appellant stated that he spent approximately 50 percent of his time supervising two subordinates (a third position was vacant). The appellant described supervision as including working side-by-side with his subordinates in the communications room as well as watching their work in order to develop back-up skills. When evaluating potential new software interfaces and similar projects, he described the process as requesting ideas from and brain-storming with his subordinates after reviewing system literature, test results, etc. The position description to which the two subordinates were assigned described the supervision received as limited in nature and extent (Level 2-4), i.e., assignments are made:

in terms of the scope and objectives of the project . . . independently analyzes assignments to identify potential problem areas and determine reasonable approaches to resolving them. . . . Completed work is reviewed for adequacy of results achieved and conformance to policies and assignment objectives. Controversial findings and major deviations are reviewed for soundness of basic assumptions and extension and adaptation of principles and techniques.

Literal interpretation of the work controls described by the appellant during the desk audit would not exceed Level 2-2 within the Factor Evaluation System . At that level, the supervisor is intensely involved in the actual work process, e.g., suggesting work methods or advising on source materials available, and reviewing work for compliance with instructions and established procedures. Crediting the subordinate positions with Level 2-2 would have had a substantial negative impact on their grade level.

The oversight division found that the nature of the work control process described by the appellant was consultative in nature, typical of technical team direction rather than traditional supervision. This was reflected in the position description of record that recognized that the position devoted 10 percent of its time to personnel management, equal employment opportunity, and related actions, including "counseling employees on performance requirements." Assuming, arguendo, an additional 5 percent of the appellant's time was spent on traditional technical supervision over the subordinates' work (including the vacant position), the oversight division concluded the appellant's position fell short of the minimum 25 percent of the work time required for classification as a supervisory position. Therefore, the General Schedule Supervisory Guide could not be applied for grade level determination. The oversight division concluded the primary purpose of the appellant's position was technical program management evaluated properly by application of the Telecommunications Series, GS-0391, position classification standard.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 1, Program Scope and Effect

Issue:	Definition of "program" or "program segment"

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of a classification appeal and the subsequent reconsideration of the decision. The appellant functioned as the Chief of the Training Support Center (Center) at a large military installation with 17,000 military personnel. Troop training was one of the installation's primary missions, i.e., conducting combat exercises, mobilization training, and classroom training for the combat units. Maintaining combat readiness and advancing combat capabilities was of primary importance. The Center played an important role in advancing the combat effectiveness of supported units by maintaining a large and varied inventory of training aids, simulators, and visual information equipment used by combat units. The Center also provided visual information services. The work directed by the appellant was evaluated by the oversight division as a support element. In his reconsideration request, the appellant claimed the training support and visual information functions he supervised were "programs" constituting complex services essential to the conduct of training operations at the agency, thus meeting the definition of "programs" as defined in the General Schedule Supervisory Guide.

Resolution

Both the oversight division and the Office of Merit Systems Oversight found the functions supervised by the appellant did not meet the definition of "program" or "program segment." The General Schedule Supervisory Guide defines "program segment" as any subdivision of a program or major military function. "Program" is defined as the "mission, functions, projects, activities, laws, rules, and regulations which an agency is authorized and funded by statute to administer and enforce," the conduct of which "constitutes the essential purpose for the establishment and continuing existence of an agency." The guide also states that although most programs have an impact or effect which is external to the administering agency, comparable agencywide line or staff programs essential to the operation of an agency are considered programs.

The Office of Personnel Management determined the functions under the supervision of the appellant were support functions rather than programs or program segments. Although training represented an essential function of standing military forces, the appellant's organizational unit was not responsible for planning and conducting training. Rather, the unit provided certain support services, in the form of various training aids and accessories, that facilitated the conduct of training at the installation. These support functions did not constitute the essential purpose for the continuing existence of this military installation. Although the General Schedule Supervisory Guide provides for considering certain essential staff functions as "programs" whose impact does not extend beyond the agency, this is restricted to the agencywide administration of these functions. In contrast, the functions supervised by the appellant had impact limited to the installation and surrounding region.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 1, Program Scope and Effect

Issue:	Distinguishing Between Level 1-2 and 1-3 in Support Work

Identification of the Classification Issue

This issue arose because of the reorganization of information systems support work in an agency's regional office. The position initially directed a multifaceted information systems management program supporting a region covering approximately one-third of the continental United States. The region was staffed with more than 4,000 Government employees at multiple sites besides the regional center. The functions directed were: (1) computer operations, including systems analysis and programming for regionally controlled systems; (2) telecommunications within the region; (3) line program information advisory services provided to the serviced public by contact representatives; and (4) a forms center that supplied forms for all agency programs to the serviced public. Forms development functions were an integral part of the form distribution center function. Ancillary functions included the regional occupational safety and health program staffed with one position and the Freedom of Information Act program staffed with two positions. The position supervised approximately 62 combined staff years of supervisory and nonsupervisory work. The agency had evaluated the position at Level 1-3.

After restructuring, the functions directed were limited to computer operations (eight staff years); telecommunications (three staff years); Freedom of Information Act program (two staff years); occupational safety and health (one staff year); and, clerical support (one staff year). The issue was whether the reconfigured position continued to support Level 1-3.

Resolution

Scope

The Level 1-3 definition for internally focused support work is described within a Department of Defense setting, i.e., "Providing complex administrative or technical or professional services directly affecting a large or complex multimission military installation also falls at this level." The third illustration for Level 1-3 expands upon the factor level definition: "Directs administrative services (personnel, supply management, budget, facilities management, or similar) which support and directly affect the operations of a bureau or a major military command headquarters; a large or complex multimission military installation; an organization of similar magnitude; or a group of organizations which, as a whole, are comparable."

The oversight division found the program segment directed by the position approached Level 1-3 in that the organization internally serviced was equivalent to a large or complex multimission military installation. The program segment directed after the reorganization, however, was more limited in its scope than intended at Level 1-3, e.g., the full range of human resource management services or the full range of budget and financial operations in organizations that are not delegated authorized accounting activity functions. The reorganization reduced the functions vested in the position from providing a full range of information resource management services to those related preponderantly to providing computer operations and related communications services.

The oversight division also learned that control over telecommunications functions was limited to two staff years of work evaluable as complex clerical and technician in nature, i.e., equipment operations. The one staff year of two-grade interval communications work was administratively under the control of the position, but was technically managed by a position at the agency headquarters. Thus, the telecommunications program segment itself was not equivalent to the "complex" technical services "directly" affecting the organization serviced to the extent envisioned at Level 1-3. The oversight division concluded the position did not meet the threshold for Level 1-3 because of the restricted nature of program functions directed, and was evaluated properly at Level 1-2.

Effect

At Level 1-3, the work directly and significantly impacts a wide range of agency activities, the work of other agencies, or the operations of outside interests. For agency support work, e.g., work supporting large, complex, multimission organizations, the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions. The oversight division found the organization supported consisted of the numerous, varied, and complex functions envisioned at Level 1-3. The reorganization, however, limited the effect of the services provided to a significant but narrow area of information systems support, i.e., computer operations and related telecommunications equipment operations, the Freedom of Information Act, and the unrelated occupational safety and health program. The oversight division concluded the depth and breadth of support services provided were not equivalent to those envisioned at Level 1-3 and, thus, the impact was not equivalent to the provision of essential support operations envisioned at Level 1-3, e.g., the impact of the full range of human resource management, or budget and financial management services to a large, complex organization. Therefore, because the residual functions supervised did not meet Level 1-3 fully, they were evaluated properly at Level 1-2.

Thus, the Office of Personnel Management found that both Scope and Effect were evaluated properly at Level 1-2.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 1, Program Scope and Effect

Issue:	Distinguishing between Levels 1-2 and 1-3

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of an appeal. The appellant was a second-level supervisor in charge of a telephone service center (Center) providing line program services to the general public. Most of the work performed by the subordinate Contact Representative, GS-0962-8, workforce involved helping beneficiaries and inquirers by telephone and screening callers for potential benefits. The staff made claim referrals and scheduled appointments for interviews at field offices having full claim adjudication and authorization authority. They provided information about community services, services of other agencies, and referred callers to other agencies when appropriate. The staff handled entitlement issues for related programs administered by a related agency. They also processed a limited range of claims actions, e.g., resolving benefit overpayments, including waivers up to $500, and issuing critical payments to beneficiaries in dire need.

The appellant claimed her position met Level 1-3 for Scope because the Center served the general population of two States with a total population of 26 million individuals, practically all of whom have at some point had business with the agency. The toll-free 1-800 telephone number system also routed calls to the Center from elsewhere in the nation. The appellant claimed the Center averaged 29,000 calls each month, for a total of almost 350,000 calls each year, and concluded the population she serviced compared favorably with "small, moderate sized, and even large cities in the U.S.," meeting Level 1-3 for Scope. In addition, the appellant claimed her position met Level 1-3 for Scope because the Center supported other agency field offices by providing more than 4,000 leads for client appointments.

The appellant also claimed the Center met Level 1-3 for Effect because many or most of the calls received were complex, intricate, difficult, and multifaceted; were line program services essential to the basic mission of the agency besides providing administrative support to other agency elements (i.e., developing field office leads); and, the impact of Center services to its clientele are both direct and significant. The appellant claimed the Center, through her position, managed "multi-million dollar accounts," and committed program funds of that magnitude annually without higher level review. It also impacted directly a wide range of interests, including governmental, corporate, and individual.

The appellant claimed the General Schedule Supervisory Guide was internally disparate, stating it would be patently unfair to hold some positions in an individual agency responsible for literally having to provide a measurable, complex service to a population the equivalent of a small city while allowing another group of positions to claim a theoretically serviced employee-equivalent population of only 4,000. As an example, she claimed the Office of Personnel Management has never attempted to learn the actual number of complex personnel actions processed in a given year by a field Staffing Office or even a Personnel Office to decide whether a supervisory position being evaluated under the General Schedule Supervisory Guide reached a threshold of 4,000 direct, significant and complex action. The appellant also claimed the Office of Personnel Management had never suggested in any of its appeal decisions nor in any general guidance to agencies that they should determine actual counts of "complex" actions accomplished in a given time frame, much less discount a portion as noncomplex. If this were required, she claimed departments and agencies would have an enormous burden to classify supervisory positions.

Resolution

Scope

Level 1-3 includes providing complex administrative, technical, or professional services having coverage that encompasses a major metropolitan area, State, or a small region of several States; or, when most of the area's taxpayers or businesses are covered, coverage comparable to a small city. Illustrative of such work is providing services directly to the general public by furnishing a significant portion of the agency's line program to a moderate sized population of clients. The size of the serviced population is the equivalent of 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 total population serviced by the agency and the complexity and intensity of the service itself, however, the serviced population may be concentrated in one specific geographic area, or involve a significant portion of a multistate population, or be composed of a comparable group. Level 1-3 definition for internally focused support work is described within a Department of Defense setting, i.e., "Providing complex administrative or technical or professional services directly affecting a large or complex multimission military installation also falls at this level." The third illustration for Level 1-3 expands upon the factor level definition: "Directs administrative services (personnel, supply management, budget, facilities management, or similar) which support and directly affect the operations of a bureau or a major military command headquarters; a large or complex multimission military installation; an organization of similar magnitude; or a group of organizations which, as a whole, are comparable."

The oversight division found the geographic area of responsibility met Level 1-3. Scope, however, also considers the nature of services provided, i.e., the population directly and significantly serviced by a program, and not the total population serviced even if it has provided some degree of service at some point in time, e.g., how to replace a lost document. It is this population that has a major and direct effect on the difficulty and complexity of a supervisor's work. The oversight division concluded providing a person with no services or a few clerical services does not constitute a major and direct effect as established in previous Office of Personnel Management appeal decisions and advisory opinions from the Office of Personnel Management's Office of Classification.

Responding to the appellant's comments regarding the processing of personnel actions by Federal personnel offices, the oversight division found those functions would not exceed the complex clerical and equivalent technical services covered at Level 1-2 given the circumscribed purpose and nature of the work. Federal personnel functions contemplated at Level 1-3 involve complex advisory services, such as recruitment strategies, major organizational position management and classification issues, establishing positions on significant labor management relations issues, and program matters of equivalent direct and major effect. Thus, the oversight division also rejected the appellant's claim the General Schedule Supervisory Guide was internally inconsistent.

The oversight division found lead work, i.e., 32,400 leads per year entailing preliminary case research and documentation, supporting more than 4,000 other agency field personnel, a preliminary process. Full case review for these leads was work assigned to and performed by other field offices. Crediting both the Center and the final adjudicating office with these cases would be tantamount to double-crediting the same workload, violating established classification principles and practices. The oversight division found that case leads are not complex administrative or technical services within the meaning of the General Schedule Supervisory Guide. Rather, it concluded other field offices performed complex administrative work in reviewing and authorizing claims for benefits typically subject only to the claimant's right to formal reconsideration or appeal. It also concluded other field offices performed complex technical work in making final determinations on the full range of post-adjudicative actions, entitlement and nonentitlement to benefits, and continuing entitlement to benefits.

The oversight division found a significant portion of the work performed in the Center did have a substantial impact on benefits. Contrary to the appellant's claim, sufficient workload data must be available for agencies to apply classification standards properly as required under section 5107 of title 5, United States Code. The record showed the agency's decision to upgrade the Center's base level positions from GS-7 to GS-8 was based on a transfer of sufficient GS-8 workload, identified by duty type to meet the 25 percent work time threshold for grade level control purposes. Reviewing workload data, the oversight division found the Center handled less than 16,000 complex cases each year. This could not be construed as equivalent to serving the population of a small city. In addition, the technical complexity of the work was more circumscribed than envisioned at Level 1-3 as reflected in its allocation to the GS-8 grade level. Although the Center was integral to providing much of agency's line program to the public, the agency's complex technical and administrative field work was vested in other field operating components. The quasi-adjudicative work performed at the Center was much more limited than similar work performed within the other field components. Given the clear line of demarcation between the Center and the other field components, the oversight division found the Center provided less than a significant portion of the agency's line functions as discussed at Level 1-3 because much of it is preliminary in nature and is not complex administrative, technical or professional service within the meaning of the General Schedule Supervisory Guide.

The oversight division found the base level work was single-grade interval technical in nature, and found it was not "complex administrative or technical or professional" support services as discussed at Level 1-3. The GS-7 grade level is considered an advanced trainee level for administrative professional occupations. In turn, the GS-9 grade level is considered the first full performance level for administrative and professional work. Technical work within the meaning of the General Schedule Supervisory Guide parallels this structure as evidenced by the parallel construction between professional engineering position classification standards and engineering technician position classification standards. Therefore, the oversight division found the work did not fully meet Level 1-3 complexity for both external program and internal support services. Finding the position met Level 1-3 only for geographic coverage, but not for other aspects of Scope, the oversight division credited the position at Level 1-2.

Effect

At Level 1-3, the activities, functions, or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests, e.g., a segment of a regulated industry, or the general public. At the field activity level, involving a large, complex multimission organization or very large serviced populations, the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.

The oversight division found that because the Center provided services to a population failing to meet the population definition of a small city, it also failed to have the direct and significant impact on the general public comparable to a small city. It noted again that client lead work was not complex administrative or technical services within the meaning of the General Schedule classification system. In addition, the leads did not affect a "wide range of agency activities"; they were preliminary to higher level, more complex line agency functions. The Center did not independently control millions of dollars released directly to "governmental, corporate, and individual" interests. Center waiver, critical payment, and similar delegated authorities were limited in amounts and were released on a case-by-case basis. The oversight division found the Center provided technical services to a population of clients comparable to a portion of a small city, and technical services to other components of the agency that both met Level 1-2.

Thus, the Office of Personnel Management found that both Scope and Effect were evaluated properly at Level 1-2.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 3, Supervisory and Managerial Authority Exercised

Issue:	Crediting Level 3-3b

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of an appeal. The appellant supervised 11 employees: five directly and five others indirectly through a subordinate supervisor. The appellant believed his authority met Level 3-3b for two reasons. First, as required at Level 3-3b, he exercised nearly all the responsibilities described at Level 3-2c. Second, he believed that he exercised all 15 responsibilities listed under Level 3-3b. For instance, the appellant claimed he exercised responsibility 1 under Level 3-3b, since he used a subordinate supervisor to direct work.

Resolution

At Level 3-3b, a supervisor must exercise all or nearly all of the supervisory responsibilities described at Level 3-2c, plus at least 8 of the 15 responsibilities listed under Level 3-3b.

The oversight division agreed that the appellant exercised nearly all 10 responsibilities described at Level 3-2c. He also exercised 7 of the 15 responsibilities listed under Level 3-3b. Specifically, he exercised responsibilities 2, 7, 9, 10, 11, 13, and 15. For instance, he carried out responsibilities 7 and 9, since he approved selections for subordinate nonsupervisory positions, and heard and resolved group grievances and serious employee complaints.

However, the oversight division found that the appellant's position could not receive credit for the other eight responsibilities listed under Level 3-3b. That is, it could not receive credit for responsibilities 1, 3 through 6, 8, 12, and 14, for reasons discussed below.

Responsibility 1 describes a supervisor who uses subordinate supervisors, leaders, or comparable personnel to direct, coordinate, or oversee work. The appellant believed his position met this criterion because he had one subordinate supervisor. However, the General Schedule Supervisory Guide uses the plural when speaking of subordinate supervisors and leaders; this is deliberate. Level 3-3b is intended to credit only supervisors who direct at least two or three persons who are officially recognized as subordinate supervisors, leaders, or comparable personnel. Further, the supervisor's subordinate organization must be so large and its work so complex that it requires using those two or more subordinate supervisors or comparable personnel. Since the appellant had only one subordinate supervisor, his position could not receive credit for this responsibility.

Under responsibility 3, a supervisor must assure reasonable equity among subordinate units of both performance standards and rating techniques developed by subordinates. The appellant maintained that this criterion was met because he reviewed documentation and approaches to evaluating personnel involved in various units to ensure equity and fairness. However, responsibility 3 could not be credited for two reasons. Most important, the appellant's subordinates did not develop performance standards, as required for this responsibility. Second, similar to responsibility 1, responsibility 3 envisions that these performance standards and rating techniques are developed by at least two or three subordinate supervisors, team leaders, or comparable personnel.

Responsibility 4 requires direction of a program or major program segment with significant resources (for instance, a multimillion dollar level of annual resources). The appellant held that this criterion was met because his office approved and decided claims paying many millions of dollars. However, responsibility 4 is intended to credit only positions that exercise direct control over a multimillion dollar level of annual resources. The appellant lacked direct control over the millions of dollars paid to claimants. For instance, those amounts were paid from a national trust fund, not from a fund in the appellant's office. The appellant did have control over his office's operating budget. However, this budget involved less than a million dollars annually. Since the appellant lacked direct control over a multimillion dollar level of annual resources, responsibility 4 could not be credited.

Like responsibility 1, responsibilities 5, 6, and 8 are intended to credit only supervisors who direct at least two or three subordinate supervisors, team leaders, or comparable personnel. Therefore, credit could not be awarded for those three responsibilities.

Under responsibility 12, a supervisor must determine whether contractor-performed work meets standards of adequacy needed to authorize payment. The appellant believed that this criterion was met since he was a contracting officer and had to sign off on certain forms before contractors could be paid. These contractors furnished various supplies and services, such as preprinted envelopes, answering machines, and photocopy supplies. However, responsibility 12 is intended to credit supervisors who regularly oversee the work of contract employees in a manner somewhat comparable to the way in which other supervisors direct the work of subordinate employees. As part of that regular oversight, such supervisors determine whether contractor-performed work meets standards of adequacy, much as the appellant determines whether his own subordinates' work is adequate. Since the appellant did not oversee the work of contractor employees, this responsibility could not be credited.

Responsibility 14 involves recommending awards or bonuses for nonsupervisory personnel and changes in position classification. The appellant recommended awards and bonuses. Further, he claimed that he could recommend changes in classification. However, responsibility 14 envisions crediting supervisors for making award and classification recommendations that superiors will carefully consider and that have a reasonable chance of adoption. All employees supervised by the appellant were assigned to standard nationwide position descriptions classified in headquarters that were required for use throughout the agency. Therefore, a recommendation by the appellant to change their classification would not have had a reasonable chance of adoption. Consequently, this responsibility could not be credited.

Since the appellant's position could receive credit for only 7 of the 15 responsibilities listed under Level 3-3b, it did not meet that level. It was therefore evaluated at Level 3-2c, the highest level met.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 5, Difficulty of Typical Work Directed

Issues:	(1) Alternative Method for Second- and Higher-Level Supervisors

(2) Calculating Base Level

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of an appeal. The appellant occupied a Supervisory Electrical Engineer, GS-0850-12, position in a medium size military installation. The position was a Division chief in the Public Works Department. The Division consisted of three branches. The appellant stated that he spent 50 percent of the time in "second-level supervisory efforts over non-supervisory GS-11" level work, and that the alternative base level methodology should result in crediting the position at Level 5-6 (800 points). He also stated that his position should be credited with a "supervisor- employee relationship" with the owners, managers, CEO's, and/or project managers of Architect/Engineer and service contractors because "it makes no difference that the contractor's working level employee is a laborer, I am dealing with the contractor's top management in a second-level supervisory role."

Resolution

(1) Alternative Base Level Methodology

The oversight division found the approved organizational structure consisted of approximately 107 staff years of civilian employee work, 11 of which were intermittent (less than a full staff year) and 20 staff years of base support contractor work. Assuming each subordinate nonsupervisory position performed grade controlling work 100 percent of the time (and basing nonsupervisory work performed by supervisors on the position descriptions of record), the oversight division found the subordinate workload consisted of 5.75 staff years of GS-11 grade level and 11 staff years of GS-9 level work under the direction of two first-level supervisors. The oversight division determined that the contractor owner, manager, CEO, and project manager workload was specifically excluded from base level consideration because the work was supervisory, i.e., supervising the nonsupervisory contractor work performed for the activity.

The appellant stated that professional architect and engineer design fees typically represented 10 percent of total contractor cost. Based on the average annual contracts controlled by the Division, the oversight division concluded that the architect and engineer work would not exceed three additional staff years of GS-11 and two additional staff years of GS-9 grade level work. Based on the significant delegation of authority and freedom from supervision present in the GS-11 position descriptions of record (certified by the appellant as current and accurate), the use of those positions to review the architect and engineer work performed for the activity, and the existence of a subordinate supervisory position over the GS-11 work, the oversight division concluded the record did not support the appellant's contention that he devoted 50 percent or more of his work time overseeing the GS-11 grade level work performed for the Division. Based on the two subordinate supervisors over the GS-9 grade level work of the Division, and the level of independence vested in the GS-9 grade level positions themselves (certified as current and accurate by the appellant), the oversight division also concluded the appellant did not devote 50 percent of his work time overseeing work at or above the GS-9 grade level. It concluded, therefore, that the alternative base level methodology was not applicable to the position.

(2) Calculating Base Level of Work

The oversight division found the in-house staff and base support contractor work, without fully calculating the amount of work performed by the 11 intermittent positions, resulted in a total of approximately 102 staff years of nonsupervisory civilian and ongoing base support contract work. The oversight division also concluded the 21.75 staff years of GS-9 and GS-11 grade level and equivalent work did not meet the 25 percent of workload criteria required to control the evaluation of Factor 5. It also determined that it could not limit consideration of contractor workload, as proposed by the appellant, to the professional work performed for the installation. Rather, it had to consider all work performed under contract reflective of ongoing Division functions, including construction, maintenance, and repair trades work, which further decreased the percentage of workload evaluable at and above the GS-9 grade level.

Based on a review of the Federal Wage System work performed at the activity, the oversight division concluded that, when combined with GS-9 and GS-11 grade level work, there was sufficient WG-10 level work to meet the 25 percent criteria of Factor 5. Observing that while it was not possible to make a direct correlation between the two pay systems for General Schedule and Federal Wage System positions, the oversight division concluded the work performed at the WG-10 level did not exceed that performed at the GS-7 grade level. It also concluded that Electrician, WG-2810-10, work was typical and representative of the WG-10 building, utility, grounds, and equipment trades work performed within the Public Works Department and for major contractor performed functions. It compared the complexity of work assignments, skills and knowledge, and responsibility typical of journey level Electricians, WG-2805, jobs in installing, modifying, maintaining, troubleshooting, and testing complete electrical systems and equipment to the Engineering Technician, GS-7, review of designated portions of plans submitted by contractors for interior electrical wiring of residential and office plans for the technical accuracy and adequacy of light, power, illuminations, loads, conductor size, switches, controls, and other equipment selected by the contractor.

The oversight division concluded WG-10 electrical work was not inherently more complex than GS-7 engineering technician work. Thus, without attempting to equate Federal Wage System and General Schedule grades, the oversight division concluded the representative Federal Wage System work performed within the Division did not provide a basis for crediting a higher level than GS-7 as the base level of work applicable to the appellant's position resulting in the crediting of Level 5-4 (505 points).

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 6, Other Conditions

Issue:	Linkage of Factor 6 to Previous Factors in the Guide

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of the same Supervisory Electrical Engineer, GS-0850-12, appeal discussed in the previous article. The position was a Division chief in the Public Works Department of a medium size military installation. The Division consisted of three branches. The appellant stated that he spent 50 percent of the time in "second-level supervisory efforts over non-supervisory GS-11" level work, and that the alternative base level methodology should result in crediting the position at Level 5-6 (800 points). Using this same base level, the appellant stated that the position should be evaluated at Level 6-5a because it required substantial coordinating and integrating of work.

Resolution

The oversight division observed that Factor 6 is linked directly to the previous factors in the Guide. The difficulty of work is measured primarily by the base level determined in Factor 5. Complexity is measured by the degree of coordination required, and increases as the base level increases. The numbered paragraphs under Factor 6 are structured to address positions that function as either first-level or second-level and higher-level supervisors. Level 6-5a pertains to first-level supervision of GS-12 base level work. The oversight division, in its evaluation of Factors 3 and 5, found the position functioned as a second- and higher-level supervisor over a GS-7 base level of work. Thus, the position could not be credited at Level 6-5a.

The oversight division also found that Level 6-4a was not appropriate because the appellant did not directly supervise nonsupervisory work that supported a GS-11 base level. Rather, the appellant supervised GS-11 grade level work indirectly as a second-level supervisor. Level 6- 4b also was not applicable to the position since there was not sufficient work at or above the GS-9 grade level in the Division to permit the crediting of each subordinate supervisory position with supervising substantial workloads with a GS-9 or GS-10 base level. The oversight division concluded the position met Level 6-3b because, based on the amount of GS- 7 (base level credited in Factor 5) grade level and higher level work in the Division, the position was characterized as entailing the direction of subordinate supervisors over positions in grades GS-7 or GS-8 or the equivalent which required consolidation and coordination similar to Level 6-2a.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 6, Other Conditions, Special Situations

Issue:	Crediting Physical Dispersion

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of a classification appeal. The appellant was a second-level supervisor who directed the work of a transportation unit and a buildings and grounds maintenance unit associated with a military base dependent school system. The agency credited the appellant with Physical Dispersion because: (1) the maintenance and transportation units were located in separate buildings on the base; (2) there were 10 different buildings on the base associated with the school system and 1 building approximately 14 miles away; and (3) the transportation personnel (bus drivers) were dispersed throughout the base and surrounding community daily making supervision more difficult.

Resolution

The oversight division denied credit because the physical dispersion of the units in this case did not make the appellant's day-to-day supervision more difficult to administer. According to the General Schedule Supervisory Guide, Physical Dispersion is credited 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 (as in 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 location of the subordinate supervisors themselves did not impact on the appellant's day- to-day supervision since work assignments were normally made by telephone, written memorandum, or occasional face-to-face meetings. As subordinate supervisors, they did not require close daily supervision anyway. More importantly, as a second-level supervisor, the appellant did not make daily onsite visits to supervise the actual maintenance or transportation work being performed by the maintenance mechanics and bus drivers. In addition, bus drivers, by the very nature of their work, are not subject to close daily supervision.

Although the appellant supervised a workload carried out in many locations, this did not impact on the difficulty of his day-to-day supervisory responsibilities. Therefore, the oversight division determined Physical Dispersion could not be credited.

Standard:	General Schedule Supervisory Guide

(April 1993)

Factor:	Factor 6

Issue:	Special Situations

Identification of the Classification Issue

This issue arose in an Office of Personnel Management oversight division's adjudication of an appeal. The appellant was a second-level supervisor in charge of a telephone service center (Center) providing line program services to the general public. Most of the work performed by the subordinate Contact Representative, GS-0962-8, workforce was helping beneficiaries and inquirers by telephone and screening callers for potential benefits. The staff made claim referrals and scheduled appointments for interviews at field offices having full claim adjudication and authorization authority. They provided information about community services and services of other agencies, and referred callers to other agencies when appropriate. The staff handled entitlement issues for related programs administered by a related agency. They also processed a limited range of claims actions, e.g., resolving benefit overpayments, including waivers up to $500, and issuing critical payments to beneficiaries in dire need. Employees at another field component handled part of the workload during peak traffic periods, obtaining technical guidance from the appellant as necessary.

The appellant initially claimed six Special Situations were creditable to her position. She prefaced her rationale by stating that Special Situations in the General Schedule Supervisory Guide (GSSG) do not equate to similar conditions that were found in the previous supervisory guide--the Supervisory Grade Evaluation Guide (SGEG). She claimed since partial credit for each condition had been allowed under the SGEG, but no credit for meeting one or two situations under the GSSG, the Office of Personnel Management had decided when the GSSG was formulated to make the Special Situations in the GSSG easier to meet than under the SGEG. Thus, while the appellant's employing agency's interpretation of these situations might have had applicability to SGEG, the operative premise under the GSSG is whether the condition, if present, makes the work of the supervisor more difficult.

Resolution

1. Shift Operations

This situation is credited when the position supervises an operation carried out on at least two fully staffed shifts.

The oversight division found the Center operated from 8:00 a.m. to 5:15 a.m. There were two tours for full-time permanent and part-time personnel. Tour One started between 7:30 and 8:30 a.m. and ended between 4:00 and 5:00 p.m. Tour Two started between 7:45 and 8:45 a.m. and ended between 4:15 and 5:15 p.m. Employees could sign in at 15 minute intervals during those tours. The heaviest telephone traffic was between 8:00 a.m. and 4:00 p.m. Mixed tour personnel had a set 9:00 a.m. to 2:00 p.m. tour during from April to December and were covered by Tour One or Two when they worked full time. Most employees arrived between 8:00 and 8:30 a.m., although some arrive earlier during the summer. One employee was on a compressed work schedule. Vacation schedules were established on a six-month basis. The appellant reported to agency headquarters by 2:00 a.m. each day on the number of people expected in two days in the future based on leave projections, and reported the number of people available that day between 4:00 and 5:15 a.m. to the region, determined by checking the sign-in sheet.

In her appeal rationale, the appellant claimed credit for shift operations because the "tremendous variance in shifts, tours, and work schedules" and off-site peak workload personnel put a distinct extra burden on managing the Center. She claimed the Center did have two fully staffed eight hour shifts, and that it did not make any difference if the shifts start fifteen minutes, one hour, two hours, or eight hours apart. She stated that supervising Center- type shift operations was materially more difficult, where employees were allowed to start work anytime within the beginning of their shift, than to supervise two widely separated but fixed starting-time shifts. This made it difficult for management to plan the workday, to determine how many employees would be available to handle the fluctuating volume of calls during the workday, decide how the pending workload would be distributed, and when to conduct training. This situation was exacerbated by the mixed-tour employees and part- timers, who arrive and leave at various times of the day, and was further complicated by the fact that many of these employees are trainees, who require additional guidance, training, and monitoring during their shifts. The appellant stressed the Center was not a back-office type of situation where some amount of variation in staffing levels could be routinely adapted to, but a real-time, front-line operation dealing directly with the general public.

Placing the General Schedule Supervisory Guide in its proper interpretive context, the oversight division stated a shift has traditionally been defined as consisting of a full eight hour tour of duty, e.g., day, evening, and night shifts. The General Schedule Supervisory Guide was developed during a time when compressed work schedules, flexitime, and similar work scheduling options were well-established and widely used. Therefore, using the term "shift," without reference to compressed work schedules or flexitime, must be considered a careful and deliberate decision by the Office of Personnel Management in its developing of the General Schedule Supervisory Guide. Center staffs operate during a nine-and-three-quarter hour work day, which is three-quarters of an hour longer than a typical Federal eight-and-one-half hour work day. The Center tour structure is most appropriately considered as a broadened flexitime construct. As in any compressed work schedule or flextime situation, office coverage during hours of operation is a standard, predictable supervisory responsibility. Integral to second- level supervisory responsibilities at Level 3-3, credited to the appealed position, were controlling leave, overtime, and similar scheduling issues for the larger workloads managed through subordinate team leaders, leaders, team chiefs, or comparable personnel. The appellant used four subordinate supervisors to manage the Center.

The oversight division found the toll-free 1-800 telephone number system was monitored at the agency's headquarters which moved traffic with the goal of having all calls answered within five minutes. Calls were routed to an intervening traffic control site and then to the Center based on availability. Serious call backups were handled by this process. The workload volume issues stressed in the appellant's rationale were controlled, in large part, through a sophisticated computerized calling system. In contrast, the oversight division found shift work within the meaning of the General Schedule Supervisory Guide required greater attention to planning, coordinating, and integrating work, e.g., by assuring work was successfully passed off from one shift to another, and resources were staged to support the work to be accomplished within each shift. Therefore, this situation was not credited to the position.

2. Fluctuating Work Force or Constantly Changing Deadlines

The General Schedule Supervisory Guide provides for crediting Fluctuating Work Force when the work force supervised by the position has large fluctuations in size (e.g., when there are significant seasonal variations in staff) and these fluctuations impose on the supervisor a substantially greater responsibility for training, adjusting assignments, or maintaining a smooth flow of work while absorbing and releasing employees. Constantly Changing Deadlines may be credited when frequent, abrupt, and unexpected changes in work assignments, goals, and deadlines require the supervisor constantly to adjust operations under the pressure of continuously changing and unpredictable conditions.

The appellant claimed the work flow in the Center, i.e., balancing of daily telephone traffic, heaviest workloads in the beginning of the week, different demands certain days of the month, and heavy traffic the first three months of the year due to new claims, and constantly increasing workload placed a heavy demand on her position. She cited the need to use off-site employees, and the unpredictability of a workload increase due to phone system problems, media reports, or similar system problems as continuing workload management difficulties. If the event was severe enough, she might have to redeploy her staff to other offices. She cited the impact of constant program changes, the need for almost immediate briefings and training on the latest changes, and the high turnover rate that typically prevented her from achieving her authorized staffing level, and the significant portion of the workforce in a training status as conditions supporting the crediting of this situation.

The appellant claimed the work tour structure of the Center imposes a substantially greater responsibility for training, adjusting assignments, and maintaining a smooth flow of work. Ensuring variable schedule employees received the same training made available to regular employees was especially difficult. She discussed the impact of the high attrition rate for mixed-tour and part-time employees, the need to assure personnel administrative changes were made when employees were converted from full-time to part-time and vice versa, claiming this constituted two separate employment seasons, each with its own characteristics and complications. The appellant challenged the agency's claim that the workload was cyclical and Center's made appropriate plans to deal with it as precluding credit for this situation; it was whether the workload imposed a substantial additional burden on the supervisor that controlled the crediting of this situation. She stated the additional burdens placed on her position by the nature of the Center work, the makeup of the workforce, the flexibility of employee schedules and the unpredictability of staff availability, the cyclical nature of the work, the constantly changing legislative policy, procedural, and technical framework, the continual need for training, the high turnover, the constant pressure to meet an ever-present five minute deadline for caller response, and the requirements for accuracy and world-class customer service, all made her job materially more difficult and significantly added to her responsibilities. The appellant stated that whether this impact on the position is credited under "shift work" or under "workforce and deadlines" or both is unimportant--simply stated, this overall situation should be credited to the position.

The oversight division observed the position classification process required the full intent of a position classification standard be discerned and applied according to established classification principles and practices that do not permit crediting the same aspects of a position multiple times. For example, credit for dealing with the impact of multiple tours, and similar workload control and assignment issues could not be credited under Shift Operations, Physical Dispersion, and this situation. As a threshold position classification standard, Special Situations required that three of eight situations be met fully to add an additional level under Factor 6. The presence of a substantial number of and widely varying alternative situations shows the General Schedule Supervisory Guide recognized many positions might meet one or two additional demands, but not three and, therefore, would not receive an additional level for this factor.

Special Situations deal with various conditions not credited fully in applying earlier portions of the General Schedule Supervisory Guide. For example, Factor 3 covers the demands of work planning, scheduling, employee instruction, and similar inherent supervisory duties and responsibilities. In crediting Level 6-3 to the position, the oversight division recognized the coordinative demands on the appellant in ensuring consistency of product, service, interpretation, or advice; conformance with the output of other units, with formal standards, or with agency policy; and coordinating with supervisors of other units to deal with requirements and problems affecting others outside the organization.

Turnover information showed 19 employees left the Center from June 1995 to December 1996. Nine of these employees resigned in lieu of termination, four of whom were in the same class of trainees. Two employees transferred to other Centers, one was promoted, two were fired, one retired, and three left for better jobs. One summer aide was employed in 1995 and 1996, and the employment of one was anticipated for 1997. The oversight division found turnover is predicable and could be anticipated based on the nature and conditions of the organization's work, even though it did place a burden of additional training on the appellant and her staff. Primary turnover, however, was among the mixed-tour staff due to the limited hours of work. Mixed tour employees comprised less than 15 percent of the staff. Full time staff turnover was limited and typically was to enter other agency field offices with greater career potential. The oversight division found these losses fell far short of "large fluctuations" as defined by the General Schedule Supervisory Guide, e.g., large seasonal variations in the staff. These large fluctuations are typified by demanding and concentrated recruitment and related functions, extensive training or similar preparatory requirements, and planning for and implementing large scale staff losses. The appeal record showed the work force fluctuations at the Center did not have an equivalent impact on the appellant's supervisory demands.

Center work assignments, goals, and deadline changes were not frequent and abrupt within the meaning of the General Schedule Supervisory Guide. Within the previous year, problems shut down the telephones for one day. There was sufficient non-telephone work, however, to continue operations at the Center. If equipment problems persisted beyond one day, the appellant had to consider sending her staff to other sites, requiring the appellant to contact her supervisor, the Area Director, the union, and the other sites. The oversight division again noted the Center workload was not locally controlled entirely. Major toll-free 1-800 telephone number system problems are controlled by agency headquarter's rerouting, and more limited issues were controlled and monitored at the intervening traffic management site. The oversight division concluded the multi-layered control network system, and the relatively predictable peaks and valleys of activity based on historical information, failed to meet the frequency, abruptness and unexpected nature of changes required for the crediting this situation.

3. Physical Dispersion

The General Schedule Supervisory Guide provides for crediting this situation when a substantial portion of the workload for which the supervisor is responsible is regularly carried out at one or more locations that are physically removed from the main unit (as in different buildings, or widely dispersed locations in a large warehouse or factory building), under conditions that make day-to-day supervision difficult to administer.

The appellant withdrew her claim for crediting of this situation due to the decrease in technical assistance calls from off-site personnel. The oversight division, however, decided to address the claim for interpretive purposes. The third exclusion in the General Schedule Supervisory Guide states positions with continuing supervisory responsibility meeting the minimum coverage requirements of the guide may be graded by using the guide provided "due care is taken to avoid crediting direction of the same work" to supervisors in different chains of command. The example alluded to in the General Schedule Supervisory Guide is of a supervisory position that also oversees project or program management work performed by employees who officially report to and are under the permanent supervision of supervisors in a different chain of command. The oversight division found off-site employees performing Center work during peak workload periods were permanently in another field office chain of command. As such, those employees could not be credited to the appellant's position under the General Schedule Supervisory Guide, whether she previously provided training to them or continue to answer their technical questions.

4. Special Staffing Situations

The General Schedule Supervisory Guide permits crediting this situation when: (1) a substantial portion of the work force is regularly involved in special employment programs; or in similar situations that 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.

In her initial rationale, the appellant stressed the workload pressure in the Center, dealing with an often unhappy clientele who were usually bolder and more aggressive over the phone than they would be in person, and often have personal problems that may be unrelated to their benefits claim or informational request, but surface simply because the phone number is toll free and available. Suicide calls were relatively frequent, and bomb and death threats were occurring with ever more regularity. The appellant stated the constant changes in legislation, regulations, policies, and procedures increased the stress level, accentuated by calls coming in from around the country that required familiarity with State practices as they pertained to benefit issues. She claimed the stressful and demanding nature of work produced a great deal of absenteeism and the supervisory staff continually referred employees for counseling. In addition, the appellant claimed many Center employees were single parents and had child-care problems, an additional cause of absenteeism. She claimed the relatively low pay in comparison to many other jobs to which the better Center employees might aspire and the many different cultures and socio-economic levels represented in the Center workforce placed additional pressures on management in dealing with workplace issues. The appellant claimed she had to meet with union representatives regularly to discuss office problems and try to solve many of the grievances filed by the employees.

The appellant stated the Center employs many blind, deaf, and other physically handicapped employees; usually there were four totally blind employees out of the overall staff of 50 or more imposing special requirements for counseling and motivation. In addition, she claimed job assignments, working conditions, and training had to be tailored to fit the special circumstances of these employees. To this end, she worked with handicapped program coordinators whenever problems occurred with the software or any equipment those blind employees used. Because the Center lacked a reader, lead employees and subordinate supervisors had to sit with the blind employees to read names off a list for their overpayment work, prepare special disks for training purposes, know how to operate the special equipment, and prepare handouts and other training material in different formats accessible to those without sight.

The oversight division found the Center employed two blind employees; each reported to a different supervisor. The appellant met at least weekly with the on-site union representative, who was a member of the local award panel, and dealt with a wide range of issues as part of the Partnership process, e.g., employee training. The appellant was a management representative on arbitration cases and had the authority to settle EEO cases; she settled two of the three cases filed against the management staff within the previous eight months. Data showed she reprimanded three employees and gave one a sick leave warning in 1995. In 1996, she reprimanded one employee, fired two, gave sick leave warning to two, and put one on sick leave restriction. In 1995, she referred 11 employees to counseling, 10 in 1996, and 5 by May 1997. Some employees referred eventually resigned in lieu of termination during their probationary period.

The oversight division concluded the subject-matter knowledge required in nonsupervisory Center work and the stress integral to client contacts had been credited fully in the evaluation of the base level positions. These aspects of Center work have been credited under Factor 5 and could not be credited again.

This situation is intended to recognize the heavy demands on the supervisor's time in dealing with difficult and complex human resource issues and problems. The oversight division found two blind employees, or the previous four employees, were not a substantial portion of the work force. The demands on the appellant's position were mitigated by the involvement of two immediate supervisors and the lead employees. The number of disciplinary and work performance and counseling problems were issues properly recognized under this situation. The extensive internal training discussed previously for new mixed-tour employees; the need to break out work and tailor work for the significant number of employees in developmental positions from that performed by full performance level employees; and the need to refer employees to counseling, including some trainees who evidenced performance problems despite intensive training, also were properly considered under this situation. When viewed as a whole, the oversight division found these human resource management issues reflected the difficulty and complexity of staffing and related issues supporting the crediting of this situation.

5. Changing Technology

The General Schedule Supervisory Guide credits this situation when 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 appellant claimed the Center was on the cutting edge of telecommunications technology, and that constant change in telephone and computer systems, software enhancements, the introduction of new technology, the upgrading of current equipment to handle new requirements, and the automation of manual procedures were "habitual." She provided information on the pending installation of IWS/LAN technology, including training requirements, and information on administrative support software updates and enhancements. She also provided a list of software releases for March 1996 through March 1997 and the training given as the result of software changes.

The oversight division found during the months of April through December all Centers are given one hour on a set day, two to three times a month, to train their entire staff. The nature of Center tours, particularly mixed-tour and part-time, made it difficult to schedule the training to cover the entire staff and required arrangements for employees who miss the training. The training covered updates on problems and work review issues, observations, and new legislation. The appellant also provided information on pending system changes and training requirements. Unlike other agency components that receive basic and follow-on subject matter training from a regional staff component, the Centers perform their own basic and follow-on training. To place the training demands of her position in context, the oversight division requested additional information from the appellant's supervisor documenting major training on systems updates in the past five years. This equated to an average of approximately 37 hours of "major training on system updates" per year. Migration to personal computers from dumb terminals (the IWS/LAN migration), the first major equipment change in approximately 10 years, will include 12 non-consecutive hours of mandatory introductory training, with optional components.

The oversight division found Center training, although more intense than typical of some Federal organizations, is not extensive within the meaning of the General Schedule Supervisory Guide. Eighty hours of training in 1990 (40 hours) and 1994 (40 hours) covered basic program changes flowing from planned management action, and not training emanating from processes and procedures that vary constantly due to the impact of changing technology as covered by this situation. The latter training initiative was part of the agency decision to assign sufficient GS-8 grade level work to the Center to upgrade non-mixed-tour base level positions to GS-8. IWS/LAN training reflected migration from old to current widely used automation technology and could not be construed as an impact of changing technology within the meaning of the General Schedule Supervisory Guide. Therefore, training caused by agency process and procedural changes was much less than the 37 hours per year, falling far short of the intent of constantly varying processes and procedures due to the impact of changing technology within the meaning of the General Schedule Supervisory Guide. The oversight division found the training fully covered and credited under Level 3-3b, and the coordinative demands credited under Level 6-3, i.e., training to assure consistency of product, service, and interpretation, and conformance with agency standards and policy. Therefore, the position could not be credited with this situation.

6. Special Hazard and Safety Conditions:

The General Schedule Supervisory Guide credits this situation 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.

In the initial appeal rationale, the appellant claimed she: (1) informed blind employees of any physical office changes; (2) dealt with employee concerns regarding the impact of video display terminal exposure on unborn children; (3) responded to constant headset complaints regarding buzzing and, at times, shocks; (4) dealt with the danger of thunderstorms because lightening can damage equipment and "can enter the phone lines providing shocks and deafening noise"; (5) made frequent inspections to assure cables and wiring are covered and do not cause a tripping hazard; (6) dealt with old terminals that, due to age, have shorted out, causing smoke, odor, and the danger of fire; (7) assured critical temperatures in the telephone equipment room are maintained; and, (8) conducted monthly safety meetings, making sure fire extinguishers were working and the staff was trained to use them. She claimed she had to assure safety was considered in the design of the new Center site, e.g., assuring cables and wires were covered and the telephone equipment room met established electrical safety requirements.

Disagreeing with the agency administrative report, the appellant claimed the General Schedule Supervisory Guide did not limit this situation to law enforcement, warehouse hazards, or exposure to environmental hazards. She claimed the mission created an extremely sensitive health and safety environment because high stress jobs had to be carried out in a constricted area, with repetitive motion an integral part of their function. Repetitive motion problems required providing time off-line for employees, dealing with special or complex leave problems, workers' compensation issues, and issues under the Americans with Disabilities Act. She referenced an agency job safety analysis project pursued since 1995 regarding Center positions, and the continuing interest by the union in these issues.

The oversight division observed the General Schedule Supervisory Guide was developed during a time when the ergonomic issues cited by the appellant were well-known and typical of many office operations. Scheduling breaks and assuring that wires and cables do not create a hazard and that blind employees are informed of changes were not significant actions dealing with special safety hazard and safety conditions within the meaning of the General Schedule Supervisory Guide. Personal computer or terminal fires are easily remedied by standard precaution and actions, i.e., cutting off electricity. This situation concerned managing people. It did not pertain to assuring air conditioning was supplied to the telephone equipment room or planning general office ergonomic layout. Therefore, this situation was not creditable to the position.

Because only one situation was creditable, an additional level for Factor 6 could not be credited to the position.