Washington, D.C.

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

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Kimberly A. Steide
Principal Deputy Associate Director
Agency Compliance and Evaluation
Merit System Accountability and Compliance

11/21/2025

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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).

As discussed in this decision, our findings 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 within 30 days of the date of this decision to the Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office. The servicing human resources offices may submit the compliance report via email to FEDCLASS_APPEALS.INTERNET@opm.gov.

Introduction

The appellant’s position is currently classified as Safety and Occupational Health Manager, GS-0018-11, but he believes the position should be classified as Safety and Occupational Health Manager, GS-0018-12. He is currently assigned to the Pacific Southwest Region, Region 5, Cleveland National Forest, U.S. Forest Service (hereafter referred to as “agency” or “Forest Service”), U.S. Department of Agriculture (USDA), in Alpine, California. 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 the classification review process conducted by Forest Service. The appellant does not state that his current position description (PD#FS2744) is accurate. Rather, he states that the PD is missing several additional duties that, in his estimation, are grade impacting. The additional responsibilities include “duties associated with” the Continuity of Operations Manager, the Check In/Out Program, the Ergonomics Program, the Employee Assistance Program, the Automated External Defibrillator Program, Hospital Liaison, Emergency Medical Services (EMS) Program, the Casualty Assistance Program/Critical Incident Stress Management (CAP/CISM) Program. The appellant also mentions additional duties and responsibilities related to the Coronavirus Disease 2019 (coronavirus).

The appellant specifically points out that the EMS and CAP/CISM programs would be categorized as major duties, while the additional duties listed above would be considered minor duties. The appellant requests that OPM consider these additional duties and make a determination as to the proper grade level of the position. Based on the information provided, it is clear that the additional duties and responsibilities describe the overall function of the safety and occupational health program. None of the duties listed deviate from the purpose of the program, which is to offer services related to safety and occupational health for employees and visitors of the Cleveland National Forest. Therefore, while not grade impacting, we agree the appellant’s PD is inaccurate regarding the exclusion of the above-listed duties.

Given the PD inaccuracy described above, the appellant’s PD 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. A PD is the official record of the 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 a review of 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 actual work currently assigned to and performed by the appellant.

Position information

The appellant works as a Safety and Occupational Health Manager in the Supervisor’s Office of the Pacific Southwest Region, Region 5, Cleveland National Forest, U.S. Forest Service in Alpine, California. The Cleveland National Forest is one of eighteen forests in Region 5. It is comprised of three districts: the Descanso, Palomar, and Trabuco districts. The districts are located within San Diego, Riverside, and Orange County. The Cleveland National Forest encompasses approximately 450,000 acres and is the southernmost national forest in California, located within 5 miles of the Mexico border. The Pacific Southwest Region (Region 5) manages 20 million acres of land of national forests in California, as well as assists state and private forest landowners in California, Hawaii, and the U.S. Pacific Islands. Its national forests encompass California’s North Coast, the Cascade and Sierra Nevada Mountain ranges, as well as the Big Sur.

The appellant is responsible for planning, managing, organizing, budgeting, and directing the Cleveland National Forest’s safety and occupational health program. He ensures the proper application and adherence to Occupational Safety and Health Administration (OSHA) standards, as well as other Federal and State mandated safety and occupational health regulations, standards, or policies. In addition, the appellant organizes regular meetings, trainings, and information sessions with other safety specialists and Forest staff.

The appellant serves as a subject matter expert (SME) for all safety and occupational health programs under his purview. He administers programs on subjects such as respiratory protection, blood borne pathogens, confined spaces, and personal protective equipment. In addition, he is responsible for conducting safety training, actively promoting the safety program, emergency action planning, facility inspections, record keeping, and accident investigations. The appellant is also tasked with performing duties associated with employee wellness, hazardous material reporting, office ergonomic assessments, and defensive driving.

The appellant works with Forest Service employees, supervisors, program managers, and line officers. He also communicates and interfaces with the forest visitors, contractors, as well as outside private, state, and federal stakeholders. He frequently participates in federal, state, and local safety committees. His communication with these groups is generally cooperative and geared towards encouraging and influencing involved parties to work together to generate, adhere to, and address safety solutions and concerns. As the safety and occupational health SME, the appellant provides professional advice and serves as mediator in situations where disagreement exists in regard to changes in work practices.

In reaching our classification decision, we carefully considered all information provided by the appellant and his agency including his official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to gain more information about his work, we conducted a telephone interview with the appellant and interviewed his first-line supervisor.

Series, title, and standard determination

The agency has classified the appellant’s position in the Safety and Occupational Health Management Series, GS-0018, titling it Safety and Occupational Health Manager, and evaluated it using the Position Classification Standard (PCS) for Safety and Occupational Health Management Series, GS-0018 and the appellant does not disagree. We concur with the agency’s title, series, and standard determination. The GS-0018 PCS contains grading criteria which must be applied to positions in that series. Therefore, our evaluation of the grade of the position by application of the GS-0018 grading criteria follows.

Grade determination

The GS-0018 PCS uses the Factor Evaluation System (FES), which employs nine factors. Under the FES, each factor level description in a standard describes 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 aspects and still not be credited at a higher level. Each factor level has a corresponding point value. The total points assigned are converted to a grade by use of the grade conversion table in the standard.
The appellant disagrees with his agency’s assignment using the GS-0018 PCS of Level 3-3 (Guidelines), Level 4-4 (Complexity), and Level 5-3 (Scope and Effect). He concurs with his agency’s assignment of Levels 1-7, 2-4, 6-3, 7-3, 8-2, and 9-2. After careful review, we concur with the agency’s assignment of the preceding levels and thus have not specifically addressed them in our discussion that follows. Therefore, our evaluation discusses only those factor-levels in dispute.

Factor 3, Guidelines

This factor covers the nature and extent of guidelines for performing the work and the judgment needed to apply them.

At Level 3-3, the Safety and Occupational Health Manager has available for application public laws, Executive orders, State and municipal codes, OSHA standards, agency manuals, procurement contract clauses, safety council reports, national safety association publications, and manufacturing association criteria. The work assignment typically requires 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, the 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 (e.g., Forest Service Manual 6700 – Safety and Health Program), OSHA safety and health standards, State and local laws such as those pertaining to fire codes, procurement contract clauses, safety council reports and other recognized standards (e.g., the American National Standards Institute). Comparable to level 3-3, the appellant independently interprets and applies guidelines to specific hazardous situations (e.g., local wildfires, hazardous spills, heat related injuries, etc.) He also modifies, adapts, and develops local safety supplemental guidelines that apply to local circumstances within the Cleveland National Forest. For example, he developed guidelines and safety protocols to prevent the spread of the coronavirus at the forest’s fire dispatch center. Specifically, he recommended the implementation of the Center for Disease Control guidelines along with additional protocols such as restricting entry, performing employee temperature checks prior to entering the building, and partitioning workspaces within the building. Similar to this level, the appellant uses judgement in applying standard hazard control or elimination practices to varying situations.

The appellant’s position does not meet Level 3-4. Unlike this level, the guidelines used by the appellant are more definitive and specific than those described at Level 3-4. Unlike Level 3-4, 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). Although the appellant may frequently encounter situations where he must source from various safety standards and regulations to properly abate a hazardous situation, 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 conducts safety reporting and analyzes events to identify trends for the purpose of creating standard operating procedures or provide technical guidance to Forest staff.

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 evaluate 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 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 or specialist 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 (e.g., the forest experienced 59 local wildlands fires in July 2025). Like Level 4-4, through safety inspections, surveys, and investigations the appellant evaluates a variety of complex, interrelated physical conditions, operating practices, and serious mishaps involving falling trees, wildland fires, exposure to hazardous chemical fumes, and heat stress from individuals recreating and 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, during the Coronavirus Disease outbreak of 2019, the appellant had to determine the safety implications of the use of a disinfectant at their forest fire dispatch center. The product had previously been unknown to him and although faced with the uncertainty of accepted control and abatement methods available to him, the appellant researched the product’s use and effectiveness, eventually deciding to use the disinfectant at the dispatch center. Comparable to Level 4-4, due to the nature and variety of hazards encountered at Cleveland National 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.

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 Cleveland National Forest, unlike Level 4-5 they are recurring and not constantly changing (though diverse and varied), and mitigation processes are generally available or in-place to deal with them. However, these hazardous situations may present serious conflicts between meeting the timeliness of mission accomplishment and the need to take measures to reduce a particular safety risk. The appellant is also confronted with diverse hazardous work processes and environmental conditions throughout the Cleveland National Forest’s geographic area, however, 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 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, the appellant implements 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 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 manager or specialist plan 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. At this level, 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 the completion of job hazard analysis or a risk assessment tool to evaluate hazards and provide risk mitigation solutions for high-risk work environments such as those experienced in fire operations. Like Level 5-3, the appellant’s work efforts affect the quality of surveys, inspections, fire incidents, and resource risk assessments conducted, as well as 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 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 determines success in meeting local objectives. The appellant’s work directly impacts safe work operations at the forest as he must ensure that hazards are properly identified and mitigated. His work also requires him to report and analyze hazardous events to identify trends within the work environment. If a serious injury were to occur, the appellant coordinates with the region to report the incident to Forest Service headquarters and OSHA. Further, the appellant does plan alternative courses of specialized action as intended at this level to resolve hazardous conditions and unsafe working practices by developing risk assessments and implementing the proper mitigations to the identified hazards. In addition, the appellant has provided valuable input to Forest Service by joining a team of safety professionals to assist in updating the Forest Service Manual 6700 – Safety and Health Program. However, unlike Level 5-4 his work does not involve the development of safety and occupational health criteria and procedures for major agency activities. Although his input may impact safety standards at the bureau-level (Forest Service), it does not impact major agency activities at the USDA. His assignments involve the application of well-developed safety and occupational health, fire safety and risk management criteria and program objectives for the Cleveland National Forest.

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

Summary

Table 1 Grade Determination

Factor	Level	Points
Knowledge required by the position	1-7	1250
Supervisory Controls	2-4	450
Guidelines	3-3	275
Complexity	4-4	225
Scope and Effect	5-3	150
Personal Contacts	6-3	60
Purpose of Contacts	7-3	120
Physical Demands	8-2	20
Work Environment	9-2	20
Total Points		2570

A total of 2570 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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