Washington, DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Damon B. Ford
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


12/06/2023

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Date

Finality of Decision

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision changes the classification of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702. As discussed in this decision, our findings also show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E of the Introduction. Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected PD and a Standard Form (SF) 50 showing the personnel action taken. The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as Forest Fire Operations Risk Management Specialist, GS-0301-11, but he believes it should be classified at the GS-12 grade level. The position is assigned to the Supervisor’s Office, Shoshone National Forest, Rocky Mountain Region-R2, U.S. Forest Service (FS), U.S. Department of Agriculture (USDA), in Cody, Wyoming. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General Issues

The appellant makes various statements about his agency’s review and evaluation of his position and compares his position to higher graded safety and risk management positions at other Forests within his agency. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position. By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards (PCSs) and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to PCSs is the exclusive method for classifying positions, we cannot compare the appellant’s position to others that may or may not be properly classified, as a basis for deciding his appeal. Because our decision sets aside any previous agency decisions, the appellant’s concerns regarding his agency’s classification review and evaluation of his position is not germane to the classification appeals process.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines. The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions. If the appellant considers his position so similar to others that they all warrant the same classification, he may pursue the matter by writing to his headquarters human resources office. In doing so, he should specify the precise organizational location, classification, duties, and responsibilities of the positions in question. If the positions are found to be basically the same as his, the agency must correct their classification to be consistent with this appeal decision. Otherwise, the agency should explain to him the differences between his position and the others.

The appellant states his PD (number FS6052) depicts the operational risk management duties that he was hired to perform, but it is not representative of the work he currently performs. Specifically, he asserts it does not reflect additional work he performs in support of various national agency programs coordinated at the regional level. In addition, the appellant states that because he performs these additional duties, he performs more work than other risk or safety specialist positions at other forests at the same or higher-grade level, and this should be considered when classifying his position. However, we may not consider volume of work in determining the grade of a position (The Classifier’s Handbook, Chapter 5). He also states that the complexity of his position has and continues to increase due to the unique approach used by his agency and the Forest Leadership team to develop its safety program using operational risk management to create a learning and just culture among employees, and this should be considered when classifying his position. In an email dated May 24, 2022, the appellant’s supervisor certified to the accuracy of the appellant’s PD, but during his interview with OPM he stated the PD does not capture the duties of the appellant’s position as they are today. A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work. A position is the duties and responsibilities that make up the work performed by the employee. Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee. An OPM appeal decision classifies a real operating position and not simply a PD. This decision is based on the work currently assigned to and performed by the appellant.

Our review disclosed the appellant’s PD is not completely accurate because it overstates some duties and does not describe others he performs. For instance, the appellant is not responsible for operational risk policy development or serves on Forest committees with responsibility for developing Forest policy in operational risk management as stated in his PD. Rather, he implements the FS’s operational risk management process to assess, reduce, and manage risks, and develops risk-based management operating guidelines or plans. Further, the purpose of his participation in Forest committees (with the Forest Leadership team) is to discuss and propose the integration of procedures/plans in fire and resource programs to keep employees safe. Our fact-finding does not support that the appellant plans and coordinates “risk management studies.” Rather, he conducts risk assessments to evaluate risks identified in resource program operations or projects and proposes plans for how those risks can be managed. He also does not develop long and short-range objectives, establishes program priorities, or develops budgets (in contrast to cost estimating), as stated under the description of the appellant’s fire risk management coordination duties in the PD. Although the appellant makes recommendations in these areas, these are program management responsibilities that are assigned to the Forest Fire Management Officer (FFMO) or to members of the Forest Leadership Team, as applicable. Our fact-finding does not support that the appellant maintains “continual contact with research, industry, and universities to keep current on new developments in equipment, materiel, capabilities and techniques that can be applied to resource operations activities” as stated in his PD.

Furthermore, the appellant’s PD does not describe his duties and responsibilities as a safety officer as it relates to the work he performs and described later in this decision for the Safety and Occupational Health Program, which is managed by the region’s Safety and Occupational Health Manager (i.e., Regional Safety Manager). Moreover, our findings show the duties performed by the appellant are appropriately addressed within the context of another occupational series rather than the Miscellaneous Administration and Program Series, GS-0301. Therefore, for all the reasons mentioned above, the appellant’s PD of record does not meet the standard of adequacy addressed on pages 11-12 of the Introduction, and the agency must revise the PD to reflect our findings.

Regarding the duties the appellant states he performs in support of national agency programs coordinated at the regional level, our review shows the appellant is assigned various collateral duties to assist the Regional Safety Manager by serving as a coordinator for employee support programs, including the Casualty Assistant Program (CAP), which ensures that employees and their families are supported following a fatality, serious injury or illness. The program provides for Critical Incident Stress Management (CISM) peer support and various trainings to help employees and leaders navigate the serious injury, serious illness, or death of an employee. It also provides for trained hospital and family liaisons who serve as intermediaries between the family and the FS to ensure family needs are met. As a CAP coordinator, the appellant responds to data call requests from agency or regional level program managers and coordinators. He also serves as table coach leading discussions for various trainings and is trained as a family liaison for employees having gone through a critical incident. In addition, he volunteers as a training instructor for Stress First Aid (SFA), a method of assisting employees in a range of occupations (e.g., wildland firefighters, emergency service personnel, natural resource professions) undergoing stress which provides a framework to improve recovery from stress reactions. The appellant provides virtual and in-person training to employees and management positions within and outside his region. The proportion of time spent on these collateral activities varies depending on requests for training and critical incident assistance needed but as indicated by the appellant and confirmed by management, these duties are performed on a recurring basis. Therefore, we have considered the impact of this work when evaluating the appellant’s position.

Position Information

The mission of the FS is to sustain the health, diversity, and productivity of the nation’s forests and grasslands to meet the needs of present and future generations. The Shoshone National Forest is America’s first national forest located in the northern Rocky Mountains in northwest Wyoming. Its 2.4 million acres are an integral part of the 10-million-acre Greater Yellowstone Ecosystem, which is centered in Yellowstone National Park. The forest encompasses an area from the Montana state line south to Lander, Wyoming. It is home to 335 species of wildlife, including the largest population of bighorn sheep and one of the few remaining grizzly bear populations in the lower 48 states. The appellant’s position is part of the forest fire and aviation staff and reports directly to the Forest Fire and Aviation Staff Officer, GS-0301-13 (i.e., FFMO). The appellant serves as the safety and risk management specialist directly supporting the Safety and Occupational Health program managed by the Regional Safety Manager, the Risk Management Program, managed by the Regional Risk Management Manager, and the Fire and Aviation Management Program directed by the FFMO.

The appellant carries out the duties of a safety officer to ensure that employees work in a safe and healthful forest environment in compliance with Occupational Safety and Health Administration (OSHA) regulations and standards. He conducts inspections and surveys of occupational safety and health programs (e.g., bloodborne pathogen, conservation, confine space, engineering, ergonomics, employee training, lockout/tagout) and makes recommendations regarding safety prevention measures. He investigates when accidents and injuries occur and uses the FS’s safety and occupational health and workers’ compensation incident reporting and case management system (i.e., eSafety) to track employee incidents and reporting information submitted by employees. On an annual basis he compiles data of all work-related injuries and/or illnesses from eSafety and posts required OSHA Form 300-A in the workplace. He provides an annual report of statistics on recordable incidents including fatalities in his forest to the Regional Safety Manager. He also conducts forest facility and equipment inspections and ensures all safety deficiencies are corrected by the appropriate personnel. The appellant represents his forest in the Regional Safety Council, which is made up of safety and operational risk management positions from all forests within his region. The council meets on a monthly basis to discuss accident trends, safety concerns and challenges, and to develop safety emphasis items, and revise or update local safety manuals and handbooks. The appellant is the hazardous materials (HAZMAT) coordinator and as such he investigates and reports all HAZMAT spills that occur on the forest.

The appellant coordinates and works with resource staff officers (i.e., resource specialists or managers) to identify hazards and assess risks in resource operations and projects and to evaluate how to mitigate risks to avoid or reduce injury or damage of property. In performing these duties, he applies an operational risk management process, which the FS has adopted to help managers and employees identify and communicate value and objectives, identify risks, evaluate how to mitigate them to the lowest practicable level, and then decide if the value or attempting to achieve the objectives is worth accepting the residual risks. Furthermore, as a qualified Safety Officer Type 1, he supports the Fire and Aviation Management Program by monitoring incident operations from a risk management perspective and advises the Incident Commander (IC) on matters relating to the health and safety of incident personnel and welfare resources. The proportion of time spent on this activity varies depending on the number of fire incidents and other fire operations (e.g., prescribed fires) during the fire season and throughout the year. The appellant serves as the firearm coordinator making recommendations to the Forest Leadership Team (composed of the FFMO, district rangers and resource staff officers) for procurement of firearm storage including the control and access of firearms and ammunition. The appellant’s position is authorized to carry a firearm for personal and/or crew safety when in the backcountry and dealing with carcasses. He serves as a technical expert for the Forest Leadership team on hazardous or potentially hazardous work situations and activities and in operational risk management.

In reaching our classification decision, we have carefully reviewed all information provided by the appellant and his agency including his official PD which, although not completely accurate, we find sufficient for purposes of classification when relied upon in conjunction with information obtained from our fact-finding. Therefore, we have incorporated the PD by reference into this decision. In addition, to help decide the appeal we conducted separate telephone interviews with the appellant and his immediate supervisor. Further, to clarify information from the record, we conducted an interview with the Regional Safety Manager (i.e., Safety and Occupational Health Manager, GS-0018-13).

Series, title, and standard determination

The agency classified the appellant’s position in the Miscellaneous Administration and Program Series, 0301, titling it Forest Fire Operations Risk Management Specialist and evaluated the position by application of the grading criteria in the Administrative Analysis Grade Evaluation Guide (AAGEG). The appellant does not dispute these determinations. However, our fact-finding does not support placement of the appellant’s position in the Miscellaneous Administration and Program Series, 0301. For the reasons discussed below the appellant’s position is appropriately classified in the Safety and Occupational Health Management Series, 0018.

The Miscellaneous Administration and Program Series, 0301, includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no other series is appropriate. The work requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives. The Safety and Occupational Health Management Series, 0018, involves the management, administration, or operation of a safety and occupational health program or performance of administrative work concerned with safety and occupational health activities and includes the development, implementation, and evaluation of related program functions. The purpose of the work is to eliminate or minimize human injury and property and productivity losses, caused by harmful contact incidents, through the design of effective management policies, programs, or practices. Safety and occupational health management work requires application of the knowledge of (a) the principles, standards, and techniques of safety and occupational health management and (b) pertinent elements of engineering, physical science, ergonomics, psychology, industrial hygiene, physiology, sociology, and other scientific and technological fields that contribute to the achievement of comprehensive safety and occupational health objectives.

Safety and occupational health activities include developing a comprehensive plan for safety and occupational health; achieving compliance with the intent of safety and occupational health legislation and related standards, order, rules, and regulations; analyzing accident and illness data, applicable legislation, and job hazards to design appropriate education activities; inspecting work areas to identify and eliminate unsafe and unhealthful environmental conditions; the identification and implementation of adjustments needed in purchase, storage, process, alteration, repair, and salvage operations to assure the inclusion of counter measures for potential accident and illness related losses. The safety and occupational health activity necessitates continuous cooperation with the program managers responsible for functions such as personnel, supply, engineering, maintenance, budgeting, and medical services; the determination of employee and supervisor training and education resources to reduce or eliminate potential accident related loss and the establishment of procedures to accomplish this objective; the compensation of human factors that may have undesirable influences on the achievement of safety and occupational health objectives; and the assessment, regulation, and preservation of environmental conditions to minimize adverse effects on the safety and occupational health of individuals.

Our fact-finding shows the purpose and primary duties of the appellant’s position is to evaluate safety and occupational health problems and assess fire and resource operations and employee performance patterns to identify hazards, detect risks, determine causal relationships, and develop abatement plans to eliminate, reduce or control hazards which could cause injuries to people and damage to property. To perform one element of his work, the appellant applies an operational risk management process and assessment tools to evaluate risks arising from hazards and make recommendations on risk-based procedures or plans for mitigating risks in fire operations and resource programs. The FS operational risk management process focuses on evaluating and reducing risks to acceptable levels including determining the severity and likelihood of incidents that could result for each hazard identified and using this information to prioritize corrective actions. Like positions in the 0018 series, the paramount knowledge needed by the appellant to perform his primary duties include a broad knowledge of safety and occupational health principles, methods, and techniques and skill in recognizing hazardous or potentially hazardous conditions, developing measures to eliminate or control these conditions, and effectively communicating the appropriate measures to resolve these problems. In addition, he also applies knowledge of pertinent elements in the field of engineering, ergonomics, physiology, sociology and other scientific and technological fields typical of 0018 positions to achieve compliance with the safety and occupational health objectives and related standards when conducting inspections and surveys. We also note that the 0018 PCS states that a practical knowledge of the methods, techniques, and procedures applied by fire prevention engineers is frequently necessary for positions in this series. Similarly, the appellant applies practical knowledge of the methods, techniques, and procedures to identify risks and hazards associated with fire and aviation activities to perform risk-based assessments during fire incidents. Because the appellant’s PD  identifies his position as a “secondary firefighter position,” we reviewed the Wildland Fire Management, 0456, series definition. However, while the appellant may be called upon to perform secondary firefighter duties on a collateral and as needed basis, this work is not the primary duty required of his position. Furthermore, the “Additional Occupational Considerations” section in the 0456 series PCS indicates that fire protection and prevention knowledge and skills are recognized responsibilities within the context of the 0018 series and thus do not separately warrant classification to the 0456 series.  

We find the appellant’s position fully meets the definition and required specific occupational subject-matter knowledge for positions classified in the 0018 series, thus assignment of the position to the 0301 series is inappropriate. Positions classified in the 0018 series are evaluated by application of the grading criteria in the 0018 PCS. The authorized title for nonsupervisory positions like the appellant’s that are assigned a number of program elements such as inspection, evaluation, training, or responsibility for providing administrative and technical services to management representatives and employees at grades GS-12 and below is Safety and Occupational Health Specialist.

Grade Determination

The 0018 PCS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors. The total is converted to a grade level by use of the grade conversion table provided in the PCS. Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some respects and still not be credited at a higher level. Our evaluation with respect to the nine FES factors addressed in the 0018 PCS follows.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or facts which the safety and occupational health manager or specialist must understand to do acceptable work, (e.g., steps, procedures, practices, rules, policies, theories, principles and concepts), and the nature and extent of the skills of a safety and occupational health manager related to the planning, organizing, directing, and evaluating of a safety program and that of a specialist to the performance of assignments which taken as a whole represent a component of safety and occupational health program.

At Level 1-7, the work requires knowledge of a wide range of safety and occupational health concepts, principles, and practices, laws, and regulations applicable to the performance of complex administrative responsibilities which requires the planning, organizing, directing, operating and evaluation of a safety and occupational health program; or comprehensive knowledge of regulations, standards, procedures, methods, and techniques applicable to a broad range of safety and occupational health duties in one or more specific areas of safety and occupational health (e.g., identifying, evaluating, and controlling a wide variety of industrial hazards related to the full range of work operations). In addition, the following knowledge is also required:

• Knowledge of standards, procedures, methods, and techniques applicable to construction projects including construction equipment, materials, and utility systems.
• Sound, technical knowledge sufficient to analyze safety design features and specifications and develop new methods and procedures to identify or control hazardous construction processes and equipment usage.
• Knowledge of psychological and physiological factors sufficient to evaluate the relationship of an individual to the working environment and to motivate individuals to perform in a safe manner.

At Level 1-8, in addition to the knowledge and skills described at Level 1-7, work requires expert knowledge of safety and occupational health concepts, principles, laws, regulations, and precedent decisions that provide the capability to recommend substantive program changes or alternative new courses of managerial action requiring the extension and modification of existing safety and occupational health management techniques critical to the resolution of safety and occupational health management problems; or knowledge sufficient to serve as a technical authority and make significant, far-reaching decisions or recommendations in the development, interpretation or application of the principal agency safety and occupational health policies or critical criteria. The 0018 PCS includes the following illustrations of Level 1-8 work:

At Level 1-8, in addition to the knowledge and skills described at Level 1-7, work requires expert knowledge of safety and occupational health concepts, principles, laws, regulations, and precedent decisions that provide the capability to recommend substantive program changes or alternative new courses of managerial action requiring the extension and modification of existing safety and occupational health management techniques critical to the resolution of safety and occupational health management problems; or knowledge sufficient to serve as a technical authority and make significant, far-reaching decisions or recommendations in the development, interpretation or application of the principal agency safety and occupational health policies or critical criteria. The 0018 PCS includes the following illustrations of Level 1-8 work:

• applying expert knowledge of special hazards (for example, ballistic missile research) and recommending control measures devised thorough extension of present guidelines or analysis of new safety procedures;
• using expert knowledge of special analytical techniques (for example, fault tree analysis and risk tree analysis) sufficient to identify high safety risks to military flight and supporting ground systems of a major military command and recommend program changes affecting the testing, maintenance, and operation of these systems;
• applying knowledge sufficient to (1) manage a program in a worldwide setting for military explosives and hazardous materials (munition, chemical, and radiological substances), (2) develop and apply safety policies, controlling their use, storage, handling, and transportation, and (3) authorize exemption from critical explosive requirements;
• using knowledge sufficient to manage the safety and occupational health program of a major industrial operation requiring the development and application of technical standards to major industrial operations (for example, shipyards and airfields) and advise top management on methods and procedures controlling the introduction of new equipment and toxic and radiological materials; and
• applying knowledge to develop and recommend to the agency administrator critical programs that (1) require modification of known safety and occupational health techniques and (2) are applicable to an extensive range of health care operations and highly hazardous health research activities.

The appellant’s position meets Level 1-7. The nature of the appellant’s work requires a comprehensive knowledge of established safety and occupational health regulations, standards to identify, evaluate, and control a wide variety of forest hazards related to the full range of fire and resource work operations. Similar to Level 1-7, he applies knowledge of methods and techniques applicable to forestry road or complex trails construction projects including forestry construction equipment such as that used by loggers and heavy mobile machinery used for removing dead trees. Comparable to this level, the appellant applies technical knowledge to analyze safety design features and develops risk-based methods and procedures to control hazardous construction processes and equipment usage (e.g., harvesting timber using chain saws). Like Level 1-7, the appellant applies knowledge of psychological and physiological factors (e.g., work performance concerns and heat exhaustion) causing workforce stress and poor mental health to evaluate the relationships of individuals to the working environment and motivate individuals to perform in a safe manner. For instance, the appellant provides SFA training not only to individuals that have gone through a critical incident but to those undergoing workplace stress to provide a framework of practical actions used to evaluate the intensity of the reaction to the stress and help reduce the likelihood that stress reactions will develop into long term problems, thereby motivating employee to perform their work in a safe manner.

The appellant’s position does not meet Level 1-8. While the appellant has extensive knowledge of safety and occupational health concepts, principles, laws, and regulations as applied to the activities performed on the Shoshone National Forest, he does not apply the level of expertise needed to recommend substantive program changes or alternative new courses of managerial action to the Forest or the region’s overall safety program. Unlike Level 1-8, his advisory services do not require the extension and modification of existing safety and occupational health management techniques critical to resolving major safety and occupational health management problems. In addition, he does not serve as a technical authority making the kinds of significant and far-reaching decisions and recommendations affecting agency-wide FS safety and occupational health policies or critical criteria. These responsibilities reside with the regional Safety and Occupational Program Manager. As opposed to Level 1-8, the breadth of the appellant’s responsibility is limited to the abatement or elimination of significant potential safety and occupational health hazards in the Shoshone National Forest. His role is to interpret and apply established guidance and evaluate local operations to identify safety hazards and assess how to manage identified problems and issues applying a risk management approach. Moreover, the appellant’s duties and responsibilities do not meet the intent of the illustrations listed under Level 1-8.

This factor is credited at Level 1-7 and 1250 points are assigned.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the responsibility of the safety and occupational health specialist, and the review of completed work.

At Level 2-4, the supervisor sets the overall safety and occupational health objectives and management resources available to achieve the expected results. Program or specialized requirements and time constraints typically are developed in consultation with the supervisor. At this level, the employee typically has responsibility for independently planning and carrying out a safety and occupation health program or a significant assignment and resolving most conflicts and hazardous situations. The work is coordinated with principal organizational representatives, and initiative must be taken to interpret safety and occupational health policy, standards, and regulations in terms of established objectives. The course of action to be taken or methods and techniques to be applied may also be determined by the employee. The supervisor is kept informed of progress, potentially controversial safety and occupational health matters, or far-reaching implications. Completed work such as reports of program accomplishments are reviewed only from an overall standpoint in terms of compatibility with other activities, or effectiveness in meeting safety and occupational health objectives.

At Level 2-5, the supervisor provides administrative direction with assignments in terms of broadly defined safety and occupational health mission or functional goals. The safety and occupational health manager independently plans, designs, and carries out programs within the framework of applicable laws. As the safety and occupational health manager at this level typically provides technical leadership, work results are considered authoritative and are normally accepted without significant change. If the work is reviewed, the review usually is focused on such matters as fulfillment of program objectives, effect of advice, or the contribution to the advancement of safety and occupational health management. Recommendations for changes in program direction or the initiation of new safety and occupational health management projects are usually evaluated for such considerations as availability of funds and other resources and relationship to broad program goals or national priorities.

The appellant’s position meets Level 2-4. Like this level, the appellant’s supervisor is responsible for setting overall objectives and resources available to meet program needs. For example, when creating a plan with cost estimates for the procurement of inReach satellite communication devices for tracking employees working in the backcountry and ensuring they are safe. The plan is subject to review by the appellant’s supervisor with final approval and funding authorization. Comparable to Level 2-4, the supervisor discusses program or specialized requirements and timeframes, e.g., for checking fire shelters and evaluating the adequacy of personal protective equipment (PPE). Like Level 2-4, the appellant works with a considerable degree of independence in planning and carrying out the safety and health program objectives and resolving most conflicts and hazardous situations. For instance, he took initiative to research and gather information from various sources and professionals and developed a local bear safety plan and associated training providing safety measures to minimize bear encounters.

Similar to Level 2-4, the appellant coordinates with resource staff officers and takes initiative to interpret safety and health program policies in terms of established Forest resource program objectives, and determines the best course of action to eliminate or manage risks. For example, he analyzed accident trends occurring in livestock program operations, presenting findings to the Forest Leadership Team and developed safety training to meet program objectives. Like Level 2-4, the appellant keeps his supervisor informed on potential or controversial safety problems, or far-reaching program implications. Consistent with Level 2-4, the supervisor does not review the technical methods used by the employee to complete his work assignments or projects and only reviews it for soundness of overall approach and effectiveness in achieving intended program objectives or goals.

The appellant’s position does not meet Level 2-5. The appellant functions within specific agency program parameters, policies and standards which are more definitive than broadly stated agency safety and occupational health mission or functional goals. His work is focused on the implementation and evaluation of the FS’s safety and occupational health program at his Forest including fire safety and the incorporation of risk management practices to mitigate risk of injury or loss of life. The responsibility for the design of programs including policy development, or the contribution to the advancement of safety and occupational health management rests on higher-echelon program management positions of the agency (i.e., headquarters levels). Although the appellant works independently, unlike Level 2-5 his completed work is reviewed more closely for achievement of program accomplishments, compatibility with the other activities of the Forest, and meeting local safety and occupational health program objectives.

This factor is credited at Level 2-4 and 450 points are assigned. 

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment needed to apply them.

At Level 3-3, the specialist has available for application public laws, Executive Orders, State and municipal codes, Occupational Safety and Health Administration (OSHA) standards, agency manuals, procurement contract clauses, safety council reports, national safety association publications, and manufacturing association criteria. The work assignments typically require independent interpretation, evaluation, selection and application of guidelines to specific situations including modifications and adaptations when necessary. In addition, judgment frequently must be exercised in applying standard hazard control or elimination practices to different situations.

At Level 3-4, available guidelines tend to lack specificity for many applications such as departmental or agency policies, recent developmental results, and findings and approaches of nationally recognized safety and occupational health organizations. These guidelines also are often insufficient to resolve highly complex or unusual work problems such as determining the potential hazard of detonating various experimental explosive devices in a research and development environment. The safety and occupational health manager or specialist must modify and extend accepted principles and practices in the development of solutions to problems where available precedents are not directly applicable. Experienced judgment and initiative are required to evaluate new trends for policy development or for further inquiry and study leading to new methods for eliminating or controlling serious hazards to life and property.

The appellant’s position meets Level 3-3. Like this level, available guidelines include agency directives, manuals and policies (i.e., Forest Service Manual 6700-Safety and Health Program and Risk Management Guide and Incident Response Guide), OSHA safety and health standards, State and local laws such as those pertaining to wildlife and hunting, procurement contract clauses, safety council reports and other recognized standards (e.g., horsemanship training standards provided by Missoula Technology and Development Center (MTDC)). Comparable to Level 3-3, the appellant independently interprets and applies guidelines to specific fire and resource situations. He also modifies, adapts, or develops local safety supplemental guidelines to local circumstances of the forest. For example, he developed an employee field guide containing quick references to key elements of the Safety and Occupational Health program objectives. Also, because the Shoshone National Forest is home to both grizzly and black bears the appellant researched and compiled information from various sources and professionals regarding bear safety and developed a plan and training materials to provide education and guidelines on how to minimize bear-human encounters to protect public safety. Additionally, he provides bear safety training to forest employees and visitors. Similar to this level, the appellant uses judgement in applying standard hazard control or elimination practices to differing situations, e.g., recommending that a tree faller use heavy mobile equipment for removing snags as opposed to only using hand labor to increase protection and minimize risk of injury to the employee.

The appellant’s position does not meet Level 3-4. Unlike that level, the guidelines used by the appellant are more definitive and specific than those described at Level 3-4. Unlike Level 3-4, because the appellant is not faced with the kinds of highly complex or unusual problems described at Level 3-4 (e.g., determining the potential hazard of detonating various experimental explosive devices in a research and development environment), there is no need to significantly modify or extend accepted practices or principles in the development of solutions where available precedents are not directly applicable. Furthermore, his position does not require the degree of judgement and initiative characteristic of Level 3-4, where the employee is involved in the evaluation of new trends for policy development. In contrast, the appellant analyzes specific accident data to determine trends for the purpose of creating standard operating procedures or provide technical guidance to Forest staff officers.

This factor is credited at Level 3-3 and 275 points are assigned.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

At Level 4-4, the assignments cover a wide range of work operations and environmental conditions involving a substantial number and diversity of hazards; or a wide variety of independent and continuing assignments in a specialized area of safety and occupational health that have exacting technical requirements. The safety and occupational health manager or specialist evaluates a variety of complex, interrelated physical conditions, operating practices, hazardous human machine interaction, and serious mishaps. Assignments require analysis of unconventional safety and occupational health problems or circumstances, inconclusive facts or data, and are characterized by the uncertainty of accepted control or abatement methods that are available for selection and use. The nature of the hazards is such that generally no single approach is adequate to control or eliminate a given problem; rather, the adaptation of proven safety and occupational health techniques is necessary. The work typically requires interpretation of a variety of occupational circumstances to adapt known control or protective measures to eliminate or minimize hazardous situations.

At Level 4-5, the work includes broad and diverse assignments requiring innovative analysis of high safety risk activities. The safety and occupational health manager weighs, considers and evaluates (1) high safety risks in a field with constantly changing hazards, or (2) serious conflicts between operational requirements involving hazardous materials and the application of safety and occupational health standards that require protective measures affecting the timeliness of mission accomplishment, or (3) diverse hazardous work processes and environmental conditions for a broad field characterized by a wide variety of problems such as extreme fluctuation in workforce employees assigned high safety risk jobs, large number of visitors engaged in hazardous activities, or widespread geographic dispersion of operations. In many instances, elimination or control of unsound but often traditional work practices and dangerous physical conditions threatening individual safety and property requires the development of new accident prevention techniques for modification of accepted specialized safety procedures.

The appellant’s position meets Level 4-4. Like this level, the appellant’s work assignments cover a wide range of work operations involving a substantial number and diversity of hazards found in forestry (e.g., dead or dying trees (falling trees), machinery, chemical, high noise, logging, fire). Like Level 4-4, through safety inspections, surveys, and investigations the appellant evaluates a variety of complex, interrelated physical conditions, operating practices (e.g., logging and road maintenance procedures), hazardous human-machine interactions during road or trail construction work, and serious mishaps involving chainsaw kickbacks, falling trees, burns, exposures to hazardous chemical fumes and heat stress from working in hot weather. Similar to Level 4-4, the appellant’s assignments sometimes require analysis of unconventional safety and occupational health problems, or circumstances characterized by the uncertainty of accepted control or abatement methods available for selection or use. For instance, riding horses in an area that has good quality sand and in a safe and confined area in order to determine and analyze risks to employees and how they can be mitigated prior to prohibiting riding horses in rugged rocky terrain (e.g., in an emergency situation). Comparable to Level 4-4, due to the nature and variety of hazards encountered in the forest generally no single approach is adequate to control or eliminate a given problem, thus the appellant must adapt proven safety and occupational health techniques as necessary where the appellant must interpret and apply a number of different but known mitigation techniques to control, eliminate, or minimize the hazardous situation (e.g., tree faller using heavy mobile equipment for removing snags as opposed to only using hand labor to increase protection and minimize risk of injury to the employee).

The appellant’s position does not meet Level 4-5. Unlike this level, while the appellant deals with diverse hazards and sometimes high safety risk activities, his assignments do not require innovative analysis of such risks. Although he evaluates various risks encountered throughout the Forest, unlike Level 4-5 they are recurring and not constantly changing, and mitigation processes are generally in-place to deal with them. They do not typically present serious conflicts between meeting the timeliness of mission accomplishment and the need to take measures to reduce a particular safety risk. Although the appellant is confronted with diverse hazardous work processes and environmental conditions throughout the Forest’s geographic area, unlike Level 4-5 they are not characterized by a wide variety of problems where there is, for example, extreme fluctuation in workforce employees assigned high safety risk jobs. In contrast to Level 4-5, while thousands of individuals visit the Forest’s campgrounds and recreation areas each year, most are not engaged in hazardous activities. Unlike Level 4-5, the appellant is not regularly engaged in the development of new accident prevention techniques for modification of specialized safety procedures, particularly high safety risk activities. Rather, we find these already have established safety operational requirements and procedures.

This factor is credited at Level 4-4 and 225 points are assigned.

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 the work products or services both within and outside the organization. 

At Level 5-3, the work involves the evaluation and analysis of safety and occupational health problems, conditions and administrative practices affecting work operations and environmental conditions. Work efforts affect the quality of surveys and inspections conducted, the adequacy of techniques applied to control or eliminate hazards and the physical safety and occupational health of employees and the general public.

At Level 5-4, the purpose of the work is to assess the effectiveness of specific programs, projects, or functions. The safety and occupational health manager or specialist plans alternative courses of specialized action to resolve hazardous conditions and unsafe working practices. The work often involves the development of safety and occupational health criteria and procedures for major agency activities. Work products impact on (1) a wide range of agency safety and occupational health programs; or (2) safety and occupational health programs of large, private sector establishments.

The appellant’s position meets Level 5-3. As the safety and risk management specialist in his organization, the appellant is responsible for conducting safety and occupational health inspections, surveys, and accident investigations to evaluate and analyze safety and health problems and conditions. He also ensures completion of a job hazard analysis or risk assessment for fire and fire aviation activities and implements applicable risk mitigation measures and safeguards. Like Level 5-3, the appellant’s work efforts affect the quality of survey, inspections, fire incidents and resource risk assessments conducted, the adequacy of procedures used to control or eliminate a variety of hazards in a field environment, and the physical safety and occupational health of Forest employees and the general public visiting Forest campgrounds, trails, and recreational sites.

The appellant’s position does not meet Level 5-4. The appellant assesses safety and health programs to ensure compliance with agency level requirements and determine success in meeting local objectives However, unlike Level 5-4 he does not assess the overall effectiveness of the Safety and Occupational Health Program. It is the Regional Safety Manager who has the responsibility of assessing the effectiveness of specific programs, and planning, executing and administering the safety and occupational health programs for all forests in region 2. Further, unlike Level 5-4, the appellant typically does not plan alternative courses of specialized action as intended at this level to resolve hazardous conditions and unsafe working practices. Also, unlike Level 5-4 his work does not involve the development of safety and occupational health criteria and procedures for major agency activities. Rather, his assignments involve the application of well-developed safety and occupational health, fire safety and risk management criteria and program objectives for the Shoshone National Forest.

This factor is credited at Level 5-3 and 150 points are assigned.

Factor 6, Personal contacts

This factor includes face-to-face contacts and telephone and radio dialogue with persons not in the supervisory chain. Above the lowest level, points should be credited under this factor only for contacts which are essential for successful performance of the work and which have a demonstrable impact on the difficulty and responsibility of the work performed.

At Level 6-2, personal contacts are with employees in the same agency, but outside the immediate organization such as line supervisors, safety and occupational health specialists, safety engineers, attorneys, medical officers, industrial hygienists, health physicists, contract specialists, personnel management specialists, labor representatives, and supporting technicians. Included also at this level are contacts with private sector employees during an inspection or survey. These contacts are generally routine and within a structured setting.

At Level 6-3, personal contacts of a nonroutine nature are with a variety of individuals (e.g., managers, administrative law and Federal judges, and professionals from other agencies or outside organizations). Contacts also include individuals such as managerial representatives of privately owned businesses, contractors and consultants, university professors, State and local government officials, representatives of professional societies and national safety associations, safety engineers, and safety and occupational health specialists from private establishments.

The appellant’s position meets Level 6-2. Comparable to this level, the appellant’s regular and recurring contacts are not limited to those of his immediate organization (i.e., fire and aviation unit) but expand outside his unit to a variety of Forest employees including the Forest Supervisor, technicians, specialists and engineers in various occupational groups, resource staff officers, district rangers, regional safety council representatives which include safety and occupational health specialists and risk management specialists from other Forests within the region, contract specialists, public visitors, and private sector employees such as emergency services personnel when serious injuries occur.  The contacts are generally routine and within a structured setting.

The appellant’s position does not meet Level 6-3. Although the appellant may occasionally meet with safety engineers and OSHA representatives, unlike Level 6-3 his contacts are primarily with individuals within his agency. In contrast to Level 6-3 he does not have contact with managerial representatives of privately owned businesses, university professors, State and local government officials, representatives of professional societies and national safety associations, and safety and occupational health specialists from private establishments. The nature of the work performed by the appellant in a national forest environment does not lend itself to having the types of contacts characteristic or comparable to those described at Level 6-3.

This factor is credited at Level 6-2 and 25 points are assigned.

Factor 7, Purpose of contacts

This factor covers the purpose of personal contacts, which ranges from factual exchanges of information to situations involving significant or controversial issues and different viewpoints, goals, or objectives. The personal contacts which serve as the basis for the level selected for this factor must be the same as the contacts which are the basis for the level selected for Factor 6.

At Level 7-2, the purpose of the personal contacts is to resolve safety and occupational health problems by planning and coordinating activities in conjunction with supervisors and employees to control or eliminate hazards. Through advisory and promotional efforts safety and occupational health specialists and managers motivate employees and public visitors to apply safe operating practices and procedures. Individuals contacted at this level are usually working toward a common goal and generally are cooperative.

At Level 7-3, the purpose of contacts is to influence, motivate, and encourage unwilling, skeptical and often uncooperative individuals to adopt or comply with safety and occupational health standards, practices, procedures, or contractual agreements. For example, contacts are established to: (1) persuade and negotiate agreements involving agency managers or private sector executives where there are serious technical disagreements and complex employee-management relations; or (2) justify changes in operational programs to agency managers. This level also includes deposing, making affidavits, and testifying in a court of law where an opposing attorney may challenge the competence of a safety and occupational health manager including work methods or findings.

The appellant’s position meets Level 7-2. Like this level, the purpose of the appellant’s personal contacts is to resolve safety problems by planning and coordinating safety and health program inspections and risk management assessments with supervisors, managers, and fire and resource staff officers to control, eliminate or reduce hazards from program operations. Comparable to Level 7-2, the appellant promotes and encourages managers and employees to embrace the FS’s operational risk management process to better plan for and address inherent risks faced by employees by identifying or recognizing hazards that are present or that could be anticipated and setting controls to mitigate risks. Like Level 7-2, he motivates employees and Forest visitors to apply safe operating practices and procedures including providing information and training on bear interactions and techniques for how to stay safe from bears while camping or hiking in bear country. Consistent with level 7-2, his contacts are generally cooperative and usually working towards common goals to eliminate or minimize hazards which could cause injuries to employees and damage to Forest property (including natural resources).

The appellant’s position does not meet Level 7-3. Unlike this level, the purpose of the appellant’s contacts is not to influence, motivate, and encourage unwilling, skeptical and often uncooperative individuals to adopt or comply with safety rules, practices, procedures, or contractual agreements. The work performed by the appellant does not require him to persuade and negotiate agreements involving agency managers or private sector executives where there are serious technical disagreements and complex employee-management relations, or to justify changes in operational programs to agency managers typical of Level 7-3. Moreover, unlike this level the appellant does not depose individuals, make affidavits, and testify in a court of law where an opposing attorney may challenge the competence of a safety and occupational health manager including work methods or findings. Such requirements are not inherent in the appellant’s position.

This factor is credited at Level 7-2 and 50 points are assigned.

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment. This includes physical characteristics and abilities and the physical exertion involved in the work.

At Level 8-1, the work is generally sedentary. There may be some walking, standing or bending and carrying of small and light objects.

At Level 8-2, the highest level for this factor described in the 0018 PCS, the work requires regular and recurring physical exertion related to frequent inspections and surveys requiring considerable standing, walking, climbing, bending, crouching, stretching, reaching or similar movements. Occasionally, there may be a need to lift and carry moderately heavy objects. The work may require some degree of agility and dexterity when, for example, it involves inspecting ships or construction sites.

The appellant’s position meets but does not exceed Level 8-2. Like this level, the appellant’s work involves regular and recurring physical exertion requiring standing, walking, climbing, bending or similar movements when conducting inspections of work areas, facilities, and equipment and when assessing risks during fire and resource operations. Similar to this level, his position may require common physical characteristics and abilities including agility, dexterity, and strength, e.g., when riding horses for the purpose of assessing potential injuries to personnel and stock.

This factor is credited at Level 8-2 and 20 points are assigned.

Factor 9, Work environment

This factor considers the risks and discomforts in the employee’s physical surroundings, and the safety precautions required.

At Level 9-1, the work is usually performed in an office setting. Occasionally, there may be exposure to the risks and hazards of work environments and conditions requiring special safety precautions and clothing.

At Level 9-2, the highest level for this factor described in the 0018 PCS, the work involves regular and recurrent exposure to hazards, unpleasantness, and discomforts such as moving machine parts, shielded radiation sources, irritant chemicals, acid fumes, physical stress, high noise levels, adverse weather conditions, and high temperatures from steam lines. Protective equipment and clothing may be needed, including hard hat, metatarsal shoes, earmuffs or plugs, goggles, respirators and gloves.

The appellant’s position meets but does not exceed Level 9-2. The appellant works both in an office and in the outdoors. When working in an office setting his work involves the everyday risks or discomforts of an office setting and requires normal safety precautions. When working in the field in a forest environment, comparable to Level 9-2 he is faced with regular and recurring exposure to hazards (e.g., falling trees, hazardous chemicals and fumes, rugged narrow roads, fires) while performing inspections and conducting risk assessments during fire incidents and resource operations. Similar to this level, the appellant is also regularly exposed to moving machinery during construction activities (e.g., complex trail project) and high noise levels from chainsaws and brush cutters. Further, he is exposed to working in adverse weather conditions (i.e., very cool in the summer and extremely cold in the winter) and high temperatures found in confined spaces. Similar to level 9-2, the appellant may be required to use PPE (e.g., hard hat, leather boots, gloves, eye and ear protection) in order to mitigate the risk of injury, or exposure to hazardous forest conditions.

This factor is credited at Level 9-2 and 20 points are assigned.

Summary

Table 1 Grade Determination

Factor	Level	Points
1.  Knowledge required by the position	1-7	1250
2.  Supervisory controls	2-4	450
3.  Guidelines	3-3	275
4.  Complexity	4-4	225
5.  Scope and effect	5-3	150
6.  Personal contacts	6-2	25
7.  Purpose of contacts	7-2	50
8.  Physical demands	8-2	20
9.  Work environment	9-2	20
Total		2465

A total of 2465 points falls in the GS-11 range (2355–2750) in accordance with the grade conversion table in the 0018 PCS. Therefore, the appellant’s position is graded at the GS-11 level.

Decision

The appellant’s position is properly classified as Safety and Occupational Health Specialist, GS- 0018-11.

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