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Classification & Qualifications Appeal Decisions

Washington, DC

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

[appellant's name]
Mission Support Specialist
GS-301-12
[name] Sector
[location] Border
Office of Border Patrol
Customs and Border Protection
U.S. Department of Homeland Security
[city, state]
Security Specialist
GS-080-11
C-0080-11-02

Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

08/20/2014


Date

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 lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of 5 CFR parts 351, 432, 536, and 752 must be followed in implementing the decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the revised position description and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action.

Decision sent to:

[Appellant and HR office addresses]

Introduction

On January 13, 2014, OPM’s Dallas Agency Compliance and Evaluation accepted a classification appeal from [appellant’s name].  The appellant’s position is currently classified as Mission Support Specialist, GS-301-12, but he believes it should be classified as Security Specialist, GS-080-13.  The position is assigned to the [name] Sector (Sector), [location] Border, Office of Border Patrol (BP), Customs and Border Protection (CBP), U.S. Department of Homeland Security (DHS), in [city, state].  We received the complete agency’s administrative report on March 31, 2014.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

The appellant’s April 1, 2013, desk audit request was forwarded by Sector management officials to the Position Management and Classification (PM&C) of the CBP’s Office of Human Resources Management.  As stated in a November 1, 2013, email to a Sector management official, the PM&C reviewed the classification of the appellant’s position and determined it was properly classified as GS-301-12.  In a December 9, 2013, memorandum to the appellant, the Sector’s Chief Patrol Agent explained that the PM&C office had concluded his position is properly classified at the GS-12 grade level because the “duties, responsibilities, and knowledge outlined in [his] position description and security information provided are of a mission support responsibility,” and that “they were an incidental function of the principal duties assigned to [his] official position.”  The appellant subsequently filed a classification appeal with OPM.

The appellant believes a change in classification is warranted, in part, because he performs work similar to that of a GS-080-13 position at the [name] Sector.  By law, we must classify positions solely by comparing their current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to the PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions, which may or may not be classified properly, as the basis for deciding his appeal.

Like OPM, CBP must classify positions based on comparison to OPM’s PCSs and guidelines.  Under 5 CFR 511.612, agencies are required to review their own classification decisions for identical, similar, or related positions to ensure consistency with OPM certificates.  Consequently, CBP has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions.  If the appellant believes his position is classified inconsistently with another, then he may pursue this matter by writing to the human resources office of his agency’s headquarters.  He should specify the precise organizational location, series, title, grade, and responsibilities of the position in question.  The agency should explain to him the differences between his position and the other, or classify the position in accordance with this appeal decision.

Position information

The Sector’s area of control includes 17,000 square miles with agents patrolling 320 river miles, 250 coastal miles, and 19 counties.  The Sector controls nine stations in [location], [location], [location], [location], [location], [location], [location], [location], and [location]; three checkpoints; air and marine operations; and an intelligence office.  The Sector employs over 3,000 uniformed and non-uniformed personnel across its main building (hereafter referred to as headquarters), stations, and other facilities though actual numbers fluctuate depending on workload.

The appellant’s position is assigned to the Office of Policy and Compliance, which ensures Sector-wide personnel follow all policies, procedures, and guidelines established by the DHS, CBP, and BP.  His position specifically falls under the security branch tasked with enforcing all security-related policies and procedures related to physical security, personnel security, badge and credentials, and passports.  The appellant’s position is directly supervised by the Supervisory Border Patrol Agent (Assistant Chief Patrol Agent), GS-1896-14.  We discuss his duties in more detail under the series determination section of this decision.

The appellant’s official position description (PD), number [number], is standardized and covers positions nationwide.  The immediate supervisor certified to the accuracy of the PD.  The appellant expresses concerns with his PD’s accuracy, explaining in his January 13, 2014, email to OPM:

The duties listed are vague and do not really address major duties.  The PD does have a small paragraph of security duties that can be assigned under the mission support classification; however, they are generalized and do not clearly identify the duties, to include the complexity of duties currently assigned to me…With that said, does my PD have a brief generalization of security duties, the answer is yes, however, it does not identify the independence, complexity, and other factors that are typically used to consider the classification and grade level.

A PD is the official record of the major duties and responsibilities assigned to a position or job by an official with authority to assign work.  OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed and proper classification can be make when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures.  Major duties are normally those occupying a significant portion of the employee’s time.  They should be only those currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time.

Based on the criteria above, we find the appellant’s PD inadequate for classification purposes.  We agree with the appellant’s statements that the major duties and responsibilities described by his PD are too generic to allow for proper classification of the position.  For instance, the PD describes his major duties as follows:  (1) provides senior level advice in an administrative specialty area(s) and participates in and makes contributions to management decisions, (2) applies wide range of concepts, laws, policies, practices, and analytical/diagnostic methods and techniques to address substantive technical issues or problems, (3) provides advisory and technical services on substantive organizational functions and work practices, (4) develops new or modified administrative program work methods, approaches, or procedures, and (5) develops and delivers briefings, project papers, status/staff reports, and correspondence to managers.

Duties such as advising senior management, making decisions, providing technical and advisory services, developing work methods and approaches, and developing briefings and other reports do not fall under the province of a specific grade level but rather may be found, to varying degrees, in positions at different grade levels of work.  The PD also includes an amendment listing the position’s functional specialties and knowledge associated with each field (i.e., budget, management analysis, human resources management, training, logistics/procurement, security, and safety).  Although the PD instructs the supervisor to mark the specialty or specialties applicable to the incumbent of the position, none were identified on the appellant’s PD.  Since it does not provide a clear picture of his day-to-day work nor does it include sufficient information so that proper classification (series and grade) can be made, the appellant’s PD must be revised to meet the standards of adequacy described in the Introduction.

Grouping together functional specialties is also problematic as two or more distinctly different kinds or levels of work in a single position, as found in a mixed series and/or mixed grade position, must be evaluated separately to determine the proper series and grade.  The appellant’s standardized PD combines budget, management analysis, security, and other specialties.  To appropriately classify positions to the GS-301 Miscellaneous Administration and Program Series, an incumbent must perform the work of more than one functional specialty and at least two kinds of that work must be evaluated at the same grade level.  If the distinctly different kinds of work are classifiable to different grade levels, the grade-controlling work dictates both series and grade of the position.  The agency’s application of the Administrative Analysis Grade Evaluation Guide (AAGEG) as sole PCS to grade the position is inappropriate.  While the AAGEG is applicable to evaluate management analysis work, the other “fields” listed in the PD are covered by directly applicable PCSs that must be used to evaluate those duties, such as the GS-200 Job Family Standard (JFS) for Administrative Work in the Human Resources Management Group for human resources management work, the GS-500 JFS for Professional and Administrative Work in the Accounting and Budget Group for budget work, and the GS-080 Security Administration Series PCS for security administration work.

Regardless, classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis 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 the PD.  This decision is based on the work currently assigned to and performed by the appellant.

To help decide this appeal, we conducted telephone audits with the appellant on June 6 and 9, 2014; an on-site audit with him on July 10, 2014; and a telephone interview with the first-level supervisor on July 22, 2014.  We also conducted a telephone interview on July 25, 2014, with a Senior Physical Security Specialist for the CBP’s Office of Internal Affairs (IA).  The IA is responsible for ensuring compliance with all CBP-wide programs and policies relating to physical security.  In deciding this appeal, we carefully considered the interviews and all other information of record furnished by the appellant and his agency.

Series, title, and standard determination

The appellant disagrees with his agency’s assignment of his position to the GS-301 series, which covers positions the duties of which are to perform, supervise, or manage two-grade interval administrative or program 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 appellant believes his work warrants classification to the GS-080 Security Administration Series, which covers positions the primary duties of which are analytical, planning, advisory, operational, or evaluative work that has as its principal purpose the development and implementation of policies, procedures, standards, training, and methods for identifying and protecting information, personnel, property, facilities, operations, or material from unauthorized disclosure, misuse, theft, assault, vandalism, espionage, sabotage, or loss.

To decide the proper series of the position, we considered the following duties and responsibilities performed by the appellant, as confirmed by his supervisor:

Physical Security.  The appellant estimates spending 40 percent of his time on physical security work.  He conducts annual physical security assessments at the headquarters, stations, and facilities, briefing the Patrol Agent in Charge or other appropriate management officials on his findings including possible security violations and recommendations for compliance with established security requirements.  He prepares evaluation reports outlining his findings, corrective measures, and recommendations.  When the Sector stands up a new checkpoint, detention facility, or other construction, the appellant participates in all meetings from pre- to post-construction along with representatives of IA and project managers from CBP’s Office of Administration, Facilities Management and Engineering Directorate, who are responsible for planning, designing, and acquiring the structure.  His work entails reviewing blueprints and other planning documents to identify, address, and resolve security concerns.  In addition, the appellant troubleshoots Sector-wide issues with gates, cameras, and other security devices and equipment.  He coordinates, when necessary, with maintenance, information technology, and other staff to resolve issues.  He also maintains and conducts an inventory of the Sector’s communication security equipment.

Personnel Security.  The appellant estimates spending 40 percent of his time on personnel security work.  He vets all contractors prior to entrance onto Sector property.  After receiving a list of contractor staff, he determines each individual’s suitability for access based on a search of the National Crime Information Center, [state] Crime Information Center, and other investigative databases.  Individuals with outstanding warrants, immigration, and other violations are denied access to facilities.  The appellant interviews contractor staff should the search result in derogatory but ambiguous information, for example, an individual physically resides at an address identified by law enforcement as the scene of prior criminal activity.  He conducts random onsite checks of contractors working at facilities to ensure proper vetting of personnel.  He assists in investigations by conducting similar record checks at the request of the intelligence, investigations, and other offices.  For employees sponsored by the Sector for clearance, the appellant prepares and submits requests for and verification of clearance.  The appellant maintains a database tracking the issuance, suspension, or revocation of clearances.  He ensures employees complete mandatory requirements associated with the top secret/sensitive compartmented information clearance level.  In addition, the appellant prepares and submits the country clearance requests (detailing travel dates, itinerary, and point of contact) to the U.S. Department of State on behalf of Sector personnel planning official visits outside the United States.

Other Duties.  The appellant estimates spending the remaining 20 percent of his time on functions such as Badge and Credential Officer; he issues and inventories badges and credentials, coordinating with the appropriate office on lost or stolen badges and credentials and other matters.  As the Personal Identify Verification (PIV) Centralized Issuing Facility Manager, he issues PIV cards for employees of all DHS components within the Sector’s area of control and ensures issuing officials assigned to stations are properly trained and certified.  As passport liaison, he stores passports for safekeeping.

The supervisor estimates the appellant spends 35 percent of his time on each physical and personnel security function and the remaining 30 percent on drafting local security policies and other duties.  We conclude the duties and responsibilities as performed by the appellant and assigned by management, in addition to his qualifications and experience (i.e., in security and law enforcement) which the supervisor describes as essential to an incumbent of the position, is consistent with the GS-080 series.  Like the appellant’s position, GS-080 work involves developing, evaluating, maintaining, and/or operating systems, policies, devices, procedures, and methods used for safeguarding information, property, personnel, operations, and materials.  He, like GS-080 specialists, interprets and defines policy guidelines, develops and implements specific guidelines to meet localized requirements, and monitors program effectiveness in facilities.

The appellant’s physical security work matches the occupational information provided by the GS-080 PCS.  Physical security is concerned with physical measures designed to safeguard personnel; to prevent unauthorized access to equipment, facilities, material, and documents; to prevent unauthorized access to equipment, facilities, material, and documents; and to safeguard them against espionage, sabotage, damage, and theft.  Similar to the appellant’s position, security specialists participate in program and project planning efforts to evaluate the need for security requirements and recommend equipment, methods, procedures, and systems.  To carry out physical security functions, GS-080 specialists perform work such as reviewing designs, inspecting facilities, evaluating the effectiveness of existing security practices, recommending appropriate action to correct deficiencies, and recommending the type of control requirements, procedures, and facilities needed.  Also similar to the appellant’s work, GS-080 security specialists determine or recommend the number and kind of safes, alarms, fences, and markings needed, balancing the costs of security systems between the ideal and what can be realistically accomplished.

His personnel security work also matches that described by the GS-080 PCS.  Personnel security assures the loyalty, reliability, suitability, and trustworthiness of applicants, employees, and others who work with, will work with, or have access to sensitive or classified information and material.  GS-080 specialists determine the suitability and security eligibility of individuals for entry and retention in sensitive and non-sensitive positions; they make security clearance determinations for employees or other persons for access to sensitive information, resources, material, or work sites.  Also like the appellant’s contractor vetting work, security specialists interview applicants to resolve questions concerning derogatory information developed during the investigation.

As his core physical and personnel security work is fully covered and addressed by the GS-080 series, the appellant’s position is properly classified to that series.  We applied the grading criteria in the GS-080 PCS to evaluate his work.  The authorized title for positions, like the appellant’s, performing work in two or more functional specialty areas is Security Specialist.

Grade determination

The GS-080 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.  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 aspect and still not be credited at a higher level.

Factor 1, Knowledge Required by the Position

This factor measures the nature and extent of information or facts the employee must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, regulations, and principles) and the nature and extent of the skills needed to apply the knowledge.

At Level 1-7, employees use knowledge, in addition to that at the lower levels, of a wide range of security concepts, principles, and practices to review independently, analyze, and resolve difficult and complex security problems.  Such work situations may involve, for example:  conflicting testimony or sources and degrees of significant information in clearance adjudication cases; overlapping and conflicting requirements within a single facility or for a geographic region; agreements with other organizations, agencies or with foreign governments for security resources and responsibility sharing; interpreting new policy issuances for application in a variety of environments and locations.  Other work may involve adjudicating complex personnel security clearances and/or developing guidelines for applying general criteria covering derogatory information that requires extensive experience and personal judgment to resolve; or planning and recommending the installation of multilayered security systems which may involve personnel access controls, physical protection devices, monitoring equipment, security forces, remote alarm equipment, and other measures.  At this level, employees often use knowledge of security program interrelationships to coordinate the objectives and plans of two or more specialized programs; make accommodations in study or survey recommendations to allow for differing program requirements; develop and/or implement procedures and practices to cover multiple security objectives; serve on inter-agency or inter-organization committees and groups to identify and resolve, or to assign responsibilities for resolving security issues; or to perform similar work.

Work at Level 1-7 requires knowledge of a broad range of security program relationships, or significant expertise and depth in one of the highly specialized areas of scrutiny.  Many employees use knowledge of a great variety of state-of-the-art security equipment and devices in planning and implementing protective methods and security procedures.  These include:  fencing variations; a variety of alarm and detection devices; closed circuit television systems; locking devices for doors, windows, vaults, and gates; shielding for cables carrying ADP, communications, and other electronic impulses that might be translatable or make a facility vulnerable to penetration; computer security software; personal control systems such as various visual and electronic badging systems; and other approaches that are designed for or applied to protecting personnel, equipment, facilities, information, processes, or signals.

At Level 1-8, employees, having mastered a major area of security specialization or demonstrated mastery of general security administration programs, use comprehensive knowledge of security policy requirements to function as technical authorities in assignments requiring the application of new theories and developments to security problems not susceptible to treatment by accepted security methods, technology, or procedures.  In addition to mastery of the specialty area, employees at this level use knowledge of other security specialties in resolving major conflicts in policy and program objectives.  Some employees use knowledge at this level to perform key decision-making and policy-developing responsibilities in very difficult assignments such as planning for significantly new or far-reaching security program requirements, or leading or participating as a technical expert in interagency study groups for resolving problems in existing security systems and programs requiring innovative solutions.  Also characteristic of positions at this level are duties such as advising top level agency security and subject-matter managers on new developments and advances in security techniques in the specialty area; planning, organizing, and directing studies to develop long range (e.g., 5 to 10 years) studies and forecasts; recommending methods for enhancing efficiency of security systems through modifications and applications of evolving technology; evaluating and making recommendations concerning overall plans and proposals for major agency and interagency security projects; and implementing national level guidance in agency standards, guidelines, or policies for major security programs.

The appellant seeks to credit his position at Level 1-7, stating in his desk audit request to the agency:

I apply current and wide range of security concepts using current policies and procedures for CBP and DHS.  I also had to familiarize myself with [General Services Administration] building requirements as well Army Corps of Engineers policies and procedures.  Vast knowledge of current security trends and policies is required.

We agree the appellant’s position is properly credited at Level 1-7.  Similar to this level, he performs a variety of analytical and administrative duties related to implementing and monitoring a well-defined security program for the Sector.  The appellant’s work requires applying knowledge of standardized security principles, concepts, and methodologies; laws and regulations; and the procedures, practices, and steps established by BP, CBP, and DHS relating to multiple security specialties.  As at Level 1-7, he advises Sector-wide personnel on the interpretation of existing and new security policy issuances and, when necessary, develops local procedures integrating processes unique to the Sector.  The appellant’s position also requires knowledge of a wide range of security concepts, principles, and practices, as at Level 1-7, to resolve difficult and complex security problems or issues.  For example, he recommends, plans, and sets up security equipment including personnel access controls, monitoring equipment, and remote alarm equipment.  When the Sector stands up a new checkpoint, detention facility, or other construction, he applies broad security knowledge to review blueprints and other proposals to identify potential vulnerabilities, ensure the efficiency and adequacy of security operations, and implement security and protective approaches for locking devices on doors and gates, fencing, alarm and detection devices, closed circuit television systems, etc.

The knowledge required by the appellant’s position does not meet Level 1-8.  Unlike this level, his position does not require applying new theories and developments to security problems not susceptible to resolution by accepted methods or procedures.  His work also does not require applying vast knowledge or mastery of security issues to resolve major conflicts in policy and program objectives.  The appellant is considered the local technical authority to interpret security policy and make decisions involving application of established methods and techniques.  In doing so, he adheres to BP, CBP, and DHS policies and guidelines to develop local Sector policies.  Working at an operating-level within BP, the appellant is not tasked with and not delegated authority to perform key decision-making and policy-developing responsibilities such as planning for significantly new or far-reaching security program requirements, or leading or participating as a technical expert in interagency study groups for resolving problems in existing security systems and programs requiring innovative solutions to resolve major conflicts in policy and program objectives, which are required for crediting Level 1-8.  Furthermore, his duties do not involve advising top level agency security and subject-matter managers on new developments and advances in security techniques in the specialty area; planning, organizing, and directing studies to develop long range studies and forecasts; implementing national level guidance in agency standards, guidelines, or policies for major security programs; or other work characteristic of Level 1-8.  These duties are performed by security personnel found at higher CBP and DHS program levels.

Level 1-7 is credited for 1,250 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s responsibility, and the review of completed work.

The appellant seeks to credit his position at Level 2-5, stating:

My work is done independently and with minimal to no supervision.  I self-initiate all my work based on evaluations, assessments and current sector and CBP policies.  I am only asked to provide tasks, accomplishments, recommendations, and future goals at the end of every week.

At Level 2-4, the supervisor sets the overall objectives and decides on the resources available.  The employee consults with the supervisor in determining which projects to initiate, develops deadlines, and identifies staff and other resources required to carry out an assignment.  The employee, having developed expertise in the particular security specialty area, is responsible for planning and carrying out the work, resolving most of the conflicts that arise, integrating and coordinating the work of others as necessary and interpreting policy in terms of established objectives.  The employee keeps the supervisor informed about progress, potentially controversial matters, or developing security conditions or requirements with far-reaching implications.  Completed work is reviewed from an overall standpoint in terms of feasibility, compatibility with other security program requirements, or effectiveness in meeting objectives and achieving expected results.

At Level 2-5, the supervisor provides broad administrative and policy direction through discussion of financial and program goals and national, agency, and local security policies affecting the direction of the security program.  The employee works under broad delegated authority for independently planning, scheduling, coordinating, carrying out, and monitoring the effectiveness of the operation of the security program(s).  In performing the work, the employee makes extensive un-reviewed technical judgments concerning the interpretation and implementation of existing security policy for the assigned specialty area(s) and in deciding which analytical and technical decisions lead to, or form the basis for, major security program policy and operational decisions by top management.  The employee is regarded as the leading technical authority for the employing organization in a security specialization or over a wide range of interrelated security programs.  The supervisor usually accepts the employee’s recommendations without change.  The employee’s actions, decisions, and recommendations are reviewed primarily for results obtained in achieving security goals and objectives, and in providing support for the attainment of the organization’s mission responsibilities.  The supervisor evaluates the employee’s recommendations for new or revised security policies, procedures, and controls in terms of impact on subject-matter program goals and objectives, and national security priorities.

The supervisory controls over the appellant’s position meet Level 2-4.  As at this level, he functions independently when planning his work, performing assignments, identifying needed resources, resolving conflicts, and interpreting policies in terms of established program objectives.  He provides guidance to Sector personnel by following standard security equipment and system requirements, procedures, and policies established by CBP and other agency levels.  The appellant’s rationale for crediting his supervisory controls at Level 2-5, as described above, do not exceed Level 2-4.  Similar to Level 2-4, he keeps the supervisor informed of his work tasks, progress, accomplishments, and need for additional resources through weekly and sometimes daily emails.  The supervisor reviews his work from an overall standpoint of meeting objectives and achieving results in a timely fashion.

The appellant’s position does not function under the broad level of delegated authority required for crediting Level 2-5.  As the Sector’s subject-matter expert on security issues, he functions with a high level of independence to draft local security policies.  Since his supervisor and other Sector management officials review and approve procedures prior to its dissemination and implementation, the appellant cannot make extensive un-reviewed technical judgments concerning the interpretation and implementation of existing security policy as expected at Level 2-5.  His program responsibilities are also restricted to the local operating level which functions within program parameters defined by BP, CBP, and DHS.  Focused as it is on the Sector, his programmatic functions do not involve the broad delegated authority at Level 2-5 which would impact the development of new or revised security policies, procedures, and controls in terms of impact on subject-matter program goals and objectives, and national security priorities.  Though the appellant is responsible for identifying additional staff or other resources required to carry out the work, his supervisor sets the overall objectives and decides what available resources may be used as he and other higher-level officials retain authority to make decisions on the need for additional personnel, funds required to repair or replace security equipment and devices, and other resource-related requests.  Since the broad delegated authority for independently planning, carrying out, and monitoring the effectiveness of the operations of the security program found at Level 2-5 are exercised and controlled at echelons above his, the appellant’s position does not meet the threshold for crediting Level 2-5.

Level 2-4 is credited for 450 points.

Factor 3, Guidelines

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

The appellant seeks to credit his position at Level 3-5, stating his guidelines involve “current policies and procedures identified by [IA], [Sector] policies, and developed and approved agreements with outside agencies.” 

At Level 3-3, guidelines available and regularly used in the work are in the form of agency policies and implementing directives, manuals, handbooks, and locally developed supplements to such guides, such as building plans, survey schedules, detailed work procedures, and directives that supplement agency directions.  The guidelines are not always applicable to specific conditions or there are gaps in specificity in application to specific security system requirements.  This level also includes work situations in which the employee must interpret and apply a number of subject-matter policies and regulations such as those that apply to access to and protection of classified information.  The employee uses judgment in interpreting, adapting, and applying guidelines, such as instructions for the application of security alarm and detection equipment; access barriers (badge and pass system, fences, guard posts, etc.); variations in security clearance levels required for portions of projects or facilities; document control systems and storage facilities where there is some overlap or conflict in the levels of security required and the number and clearance levels of persons with access to a facility; and other conditions requiring the employee to analyze and develop security plans within the intent of available guidelines.  The employee independently resolves gaps in specificity or conflicts in guidelines, consistent with stated security program objectives.  The employee analyzes the applicability of guidelines to specific circumstances and proposes regulatory or procedural changes designed to improve the effectiveness or efficiency of security controls within the intent of directions concerning the level of security required.

At Level 3-4, guidelines provide a general outline of the concepts, methods, and goals of security programs.  The guidelines regularly applied at this level consist of broad security guidance, such as directives issued by national security agencies; general agency policy statements and objectives; interagency security program policy proposals requiring refinement and coordination; or others that are not specific in how they are to be defined, implemented, and monitored.  Where guidelines for performing the work are scarce or of limited use, the employee develops guides to be followed by security specialists at the same and lower levels in the organization, including facilities and programs in various geographical regions.  Typically, departmental guidelines available to the employee at this level are purposely left open to some local interpretation in order to allow accommodation to variations in local and remote environmental conditions that affect the nature of security systems designed to satisfy overall policy direction.  Due to the lack of specificity, the guidelines are often insufficient to accomplish specific objectives.  The employee must deviate from traditional methods and develop new methods, criteria, or proposed new policies.

Examples of work situations involving guidelines at Level 3-4 include:  preparation of implementing instructions for a region, major military command, or comparable level of organization based on general national level directives, statements of policy, and program needs; or working with program officials to anticipate security requirements and prepare general operating instructions.  The work at this level may also include interpretation and preparation of implementing procedures and instructions at field levels based on general agency policy statements.  The specialist establishes and monitors operating security programs to meet specific needs (e.g., for organizations covering a number of locations or a variety of security program situations involving classified information, facilities, devices, industrial or scientific processes, etc.).  Such work typically involves security requirements that require tailoring of programs to meet special circumstances.  The employee uses initiative and resourcefulness in researching and implementing new and improved security methods and procedures within the employing organization.  The employee establishes criteria for identifying and analyzing trends in security violations and other lapses in security, and in measuring organizational effectiveness in achieving security objectives and goals.  At this level, the employee exercises a great deal of personal judgment and discretion with broad latitude for interpreting and applying guidelines across the organization.  Also included at this level is the interpretation and application of guidelines of more than one Federal agency or department which apply to security programs and organizations involved in joint responsibility control, and operations, or discrete projects at a single facility.

The guidelines used by the appellant meet Level 3-3.  As at this level, he uses guidelines in the form of agency policies and implementing directives, manuals, and handbooks which are vast and cover nearly all aspects of work performed in multiple security administration disciplines.  Based on the multitude of guidelines available, he interprets, adapts, and applies existing guidelines to deal with Sector issues.  Similar to Level 3-3, the appellant is responsible for developing local instructions and procedures to supplement agency guidelines.  For example, he drafted local policies on topics including the use of PIV cards, protection of classified material during emergencies, no picture taking at detention centers, and no piggybacking through gates.  He also developed local procedures for staff requesting record checks, establishing the deadline and minimum information required to initiate record checks (name, address, and other identifying information and reason for request).  All local policies and procedures must be in line with agency policies, directives, and requirements.  Like Level 3-3, some guidelines have gaps in specificity or overlap in their application to security system requirements.  The appellant communicates with IA officials and makes recommendations to resolve situations where BP and CBP establish separate but conflicting security requirements regarding fencing and other security guidelines.  Similar to Level 3-3, he resolves gaps in specificity when developing local instructions; for example, although CBP guidelines establish general security policies regarding no photography at facilities, he identifies and approves, on a case-by-case basis and in coordination with the senior CBP official onsite, whether television camera, motion picture, or other situation may be granted an exception to the general policy.  We note the appellant’s description of his guidelines do not exceed Level 3-3 involving agency policies and implementing directives, manuals, handbooks, and locally developed supplements to such guides.

The guidelines regularly used by appellant are not of the broad and general nature or lacking in specificity as to require refinement as envisioned at Level 3-4.  Instead, the guidelines he uses to perform his work specifically define the areas to be addressed, methods to be employed, and minimum requirements to be met when implementing the security program.  For example, the appellant’s guidelines include, but are not limited to, CBP Security Policy and Procedures Handbook (HB 1400.02B), BP Station Baseline Design Requirements, BP Checkpoint Baseline Design Requirements, CBP Personnel Security Handbook (HB 1400-07), DHS Instruction 121-01-011 (Administrative Security Program), DHS Instruction 121-01-010 (Physical Security), various manuals and instructions covering security equipment and devices, and instructions for conducting law enforcement database checks.  He develops local policies in response to an internal complaint, negative publicity, his observations, or at the request of his supervisor or other management official.  Draft policies are reviewed by his supervisor before forwarding to the Chief Patrol Agent for review and signature.  But unlike Level 3-4, the appellant’s guidelines are not often insufficient to accomplish his work as they cover most aspects of his physical and personnel security, clearance, and other work.

The appellant participated on a project, along with IA representatives and CBP project managers, to convert a warehouse into a detention facility.  To a certain extent, the project required adapting guidelines to fit or accommodate the rapid 90-day project deadline, unfavorable features of the warehouse (e.g., proximity to roads and neighboring businesses), and the care and wellbeing of minors.  Although HB 1400.02B and other guides do not provide for such situations, this and other work performed by the appellant does not involve developing new security methods, criteria, or proposed new policies as expected at Level 3-4.  Instead, his decisions made in the course of the warehouse project, as those made on other construction jobs, require identifying, addressing, and resolving security concerns while making recommendations concerning the security system, equipment, and other devices for installation.  The appellant’s work also does not require developing guidance to be followed by other security specialists as described at Level 3-4.  Higher organizational levels, like IA, are responsible for developing, deviating, and providing for the interpretation of security guidelines when needed.  Since we find the appellant’s position does not meet Level 3-4, we cannot compare his guidelines to Level 3-5 criteria.

Level 3-3 is credited for 275 points.

Factor 4, Complexity

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

At Level 4-4, employees perform assignments consisting of a variety of security duties involving many different and unrelated processes and methods relating to well-established areas of security planning and administration.  Typically, such assignments concern several broad security program areas or, in a specialty area, require analysis and testing of a variety of established techniques and methods to evaluate alternatives and arrive at decisions, conclusions, or recommendations.  Programs and projects may be funded by, or under the cognizance of, different organizations with differing security requirements or variations in ability to fund system implementation.  The implementation of established security policies, practices, procedures, and techniques may have to be varied for a number of locations or situations which differ in kind and level of security, complexity, and local conditions or circumstances requiring adjustment or modification in established approaches.  Implementation of the results of analysis may have to be coordinated with other organizations and security systems to assure compatibility with existing systems and demands on available resources.  In deciding what is to be done, the employee typically assesses situations complicated by conflicting or insufficient data, evidence, or testimony which must be analyzed to determine the applicability of established methods, the need to digress from normal methods and techniques, the need to waive security and investigative standards, or whether specific kinds of waivers can be justified.  Employees make many decisions involving the interpretation of considerable data; application of established security methods, equipment, techniques, and objectives to a variety of situations and variations in the level of security required; and ability to meet or exceed minimal acceptable levels.  The employee plans the work, develops recommendations, and refines the methods and techniques to be used.

At Level 4-5, employees perform assignments involving various projects, studies, or evaluations requiring the application of many different and unrelated processes, differing regulatory criteria and procedures, and significant departures from established practices, to reach decisions, or to develop and implement new methods and techniques that satisfy policy and operational requirements.  At this level, the employee makes recommendations for changes in basic policy issuances and for implementing instructions covering established security techniques, practices, and methods based on personal analysis of very general policy directives and objectives.  An example of work at this level would be interpretation and implementation of new directions for subordinate organizations and field units, when such directions stem from additions to, or changes in, national or agency policies and programs, or identification of deficiencies in established programs.  Decisions regarding what needs to be done are complicated by the number and nature of existing security programs or other regulatory guidance or circumstances, overlapping requirements, distinct local, environmental, or other considerations that have an impact on the ability to apply established methods.  Many other factors may require extensive analysis and coordination to implement security plans and programs, such as conflicting requirements or objectives that may be imposed by other agencies.  The employee must consider probable areas of future change in system designs, equipment developments, or comparable aspects of projects in order to prepare for later changes.  Usually, there are conflicting requirements, the problems are poorly defined or require projections based on variable information or technological development, or some degree of change must be anticipated in mission requirements, related security systems, or funding requirements.  The work involves originating new security techniques, establishing criteria, or developing new information and approaches to problem solutions.  Employees who develop and interpret broad security policies and regulations must consider the total range of existing policies, procedures, laws, and regulations and the program goals and objectives which are to be fulfilled.

The appellant’s position meets Level 4-4.  As at this level, his work consists of a variety of duties involving different and unrelated processes, methods, and steps related to the Sector’s well-established security program.  The appellant interprets and applies various established security guidelines, procedures, processes, and techniques to ensure existing security measures are proper and adequate.  When the Sector stands up a new checkpoint or other facility, he participates during the kick-off, design and planning, construction, post-construction, and all other phases of the project.  His work includes ensuring compliance with established security guidelines, identifying and resolving potential security issues (e.g., locating unsecured areas), and making recommendations such as ideal alarm system, number and placement of cameras, and adequate locks.  As it covers the personnel and physical security operations in place at Sector headquarters, stations, checkpoints, and other facilities, the appellant’s position requires making many decisions involving the interpretation of considerable data; application of established security methods, equipment, techniques, and objectives to various situations; and ability to meet or exceed minimal acceptable levels as expected at Level 4-4.  His security assessment work involves working with facility management to bring existing security measures into compliance if issues are identified.  The Sector’s facilities are classified with medium to high levels of risk as determined by the number of visitors, crime statistics, size, and other factors.  Each station has its own security system and issues relating to the kind and level of security required, size, complexity, and local circumstances, requiring the appellant to plan, develop recommendations, and apply and refine established security methods and approaches to the variety of situations he encounters as described at Level 4-4.  For example, after identifying one of the checkpoints as the entrance point for individuals illegally crossing the border on the roof of trucks, he attached a camera to the awning of the checkpoint to provide a roof-top view and avert illegal border crossings.

The appellant seeks to credit his position at Level 4-5, stating his work is “self-determined” and involves “intense knowledge of current security principles and continuous application of current policies and procedures set by DHS, CBP, and Border Patrol.”  We, however, previously considered his statements concerning the knowledge required of his position under Factor 1.  We find the appellant’s assignments do not require originating new security techniques, establishing criteria, or developing new information and approaches to develop solutions as expected at Level 4-5.  Also in contrast to this level, his position does not have authority to develop broad security policies and regulations requiring consideration of the total range of existing policies, procedures, laws, and regulations and the program goals and objectives to be fulfilled.  This authority to develop broad security policies and regulations, within the context of existing guidelines, is exercised and controlled by CBP’s IA office and other echelons above the appellant’s.  Consistent with Level 4-4, his contractor vetting work requires formulating questions to clarify an individual’s background when data is insufficient or too ambiguous for him to make a determination.  Based on the individual’s responses, he makes a determination if the candidate is eligible for access to Sector facilities.  However, this and other assignments do not involve making significant departures from established practices, or developing and implementing new methods and techniques satisfying policy and operational requirements as required for crediting Level 4-5.

Level 4-4 is credited for 225 points.

Factor 5, Scope and Effect

This factor measures the relationship between the nature of the work, as measured by the purpose, breadth, and depth of the assignment, and the effect of work products or services both within and outside the organization.

The appellant seeks to credit his position at Level 5-5, stating:

Job entailed identifying areas of concern, whether additional resources were required and coordinating with outside agencies, Addressing security related issues could have an immediate impact on the Sector, U.S. Border Patrol headquarters, DHS, and outside entities.  [sic.]

 At Level 5-3, the work involves resolving a variety of conventional security problems, questions, or situations, such as those where responsibility has been assigned for monitoring established security systems and programs or performing independent reviews and recommending actions involving well-established criteria, methods, techniques, and procedures.  The employee’s work products, advice, and assistance affect the effectiveness and efficiency of established security programs and contribute to the security effectiveness of newly introduced programs and facilities requiring such protective services.  The effect of the work is primarily local in nature, although some programs may be part of multi-facility or nationwide program operations with interlocking security requirements.

At Level 5-4, the work involves investigations and analyzing a variety of unusual security problems, questions, or conditions associated with general questions about security or in a specialty area, formulating projects or studies to alter existing security systems substantially, or establishing criteria in an assigned area of specialization (e.g., developing specifications for security programs in a number of data processing centers).  The work affects security system design, installation, and maintenance in a wide range of activities within the organization and in non-Government organizations, in providing solutions to security problems and questions, and in developing alternatives and options that are designed to meet requirements in a variety of physical and environmental circumstances.  Recommendations and technical interpretations affect the level of funding required to meet program objectives in conducting major substantive or administrative programs or services.  Program and project proposals frequently cut across component or geographic lines within the agency, and may also affect the budgets, programs, and interests of other Federal agencies or organizations, public organizations, and/or private industrial firms.

The appellant’s position meets Level 5-3.  Similar to this level, his work involves resolving conventional security problems, issues, and conditions related to implementing and monitoring a security program.  He monitors the implementation of the established security program for the Sector by vetting all contractors and visitors, conducting physical security assessments, coordinating and monitoring the physical security associated with the buildings and grounds within the Sector, serving as liaison for employee background clearances, ensuring the appropriate personnel sensitivity level designations are granted, and coordinating and administering the local PIV and badge and credential programs.  In addition, the appellant monitors employee activities relating to attempts to bypass or defeat access controls, identify noncompliance with building and other security procedures, and ensures employee access to information is limited to that related to the work performed (e.g., he makes sure employees, contractors, and visitors have access to the offices in the building and during the hours appropriate for the individual’s work).  Like Level 5-3, his work affects the effectiveness and efficiency of the Sector’s established security program.

In contrast to Level 5-4, the appellant’s work does not involve investigations and analyzing a variety of unusual security problems, questions, or conditions associated with general questions about security.  For example, his contractor vetting work entails completing record checks for children in the agency’s explorer program where participants are trained like border patrol agents.  Typical of Level 5-3, his record check may initially result in no negative information, but a further check shows the parent or guardian with questionable activity or affiliations.  The appellant will report negative record checks for children suspected of infiltrating the Sector to learn BP strategies and procedures.  He also makes a wide variety of recommendations.  His work on new construction involves reviewing blueprints and other designs at the 35, 65, 95, and 100 percent completion phase, and he ensures and promotes compliance with established security requirements typical of Level 5-3 by making recommendations on, e.g., the height of fences, gates, access control panels, monitors, install of bullet resistant glass, and the number, type, and placement of cameras.  Further, a warehouse was recently converted into a detention facility to accommodate the influx of individuals crossing the border illegally.  Within the 90-day deadline imposed by the agency, the appellant coordinated with IA officials, CBP project managers, and others to make the facility operational.  He identified possible security risks (e.g., proximity to the road and surrounding buildings); made recommendations relating to the security system, fences, gates, cameras, locks, and access control readers and panels; and worked with subcontractors on the installation of the security devices and equipment.  Two more projects to convert existing buildings to detention facilities are likely.

The appellant also completes assessments at Sector-wide facilities and grounds, observing and making recommendations to address signs of deterioration and other issues of noncompliance with established security requirements.  His other recommendations include asking for additional staff to accommodate spikes in the contractor vetting and other workload, revising and drafting local security procedures for signature by the Chief Patrol Agent, and requesting the replacement of security devices and equipment.  Lacking authority to approve purchases, the appellant devises and implements no-cost solutions to address issues of concern, for example, by replacing the broken with an old but working camera or mounting an old camera to the canopy of a traffic checkpoint to prevent illegal border crossings on the roof of trucks.  However, in contrast to Level 5-4, this and other work does not involve formulating projects or studies that result in the substantial alteration of security systems.  The appellant works with subcontractors to oversee the installation of cameras, monitors, and other security equipment.  Any outcome requiring a change order or modification to the scope of work must go through IA and project managers.  Although the appellant makes various recommendations to management, the projects and studies that result in significant impact on security programs as described at Level 5-4 are the responsibility of organizations at higher levels within the agency.

The Sector’s facilities are scattered throughout the area of control, most of which are separately fenced, guarded, or otherwise segregated due to the nature of the border patrol activities conducted there.  The size of the facilities, the nature of its terrain, and the multiplicity of its protected areas are prime concerns of the appellant’s position.  Although his work extends in impact beyond the immediate Sector headquarters like that depicted at Level 5-4, it has a lesser programmatic impact in that it does not regularly result in substantive additions or alterations to existing security systems or operations.  Since we find the appellant’s position does not meet Level 5-4, we cannot compare his work to criteria in Level 5-5.  

Level 5-3 is credited for 150 points.

Factor 6, Personal Contacts

This factor considers face-to-face and telephone contacts with people not in the supervisory chain.

The appellant’s personal contacts meet Level 6-3.  Contacts at Level 6-3 are with individuals from outside the agency who represent the security program interests of other Federal agencies, contractors, private business and financial interests, State and local Governments, foreign Governments, public and private institutions, or Congressional offices.  Contacts with applicants and potential contractors to discuss problems concerning the granting of security clearances are also included at this level.  At Level 6-3, contacts take place in a moderately unstructured setting (e.g., the contacts are not established on a routine basis, the purpose and extent of each contact is different, and the role and authority of each party is identified during the course of the contact).  This level also includes contacts with employees of other Federal organizations engaged in security functions which affect the budget of the employing organization, and contacts with representatives of private firms performing services for the Government which involve security considerations as a function of contractor performance.

Similarly, the appellant has contact with, in addition to Sector-wide management officials and staff, representatives of local law enforcement, local police and fire departments, and officials of other DHS components or Federal agencies such as the Transportation Security Administration (TSA), Federal Emergency Management Agency, Federal Bureau of Investigation (FBI), and Drug Enforcement Administration as described at Level 6-3.  Also at this level, his contractor vetting work requires questioning individuals to determine if he or she is allowed entrance to work at the Sector.  The appellant has contact with contractors engaged in building checkpoints and other facilities within the Sector.

The appellant’s position does not meet Level 6-4 where contacts involve face-to-face or telephone interaction with Members of Congress and/or top Presidential advisors; or comparable levels of officials from foreign Governments in highly unstructured settings.  Also unlike Level 6-4, his contacts do not include presidents of large national or international firms, internationally recognized representatives of the news media, presidents of national unions, State governors, or mayors of large cities.

Level 6-3 is credited for 60 points.

Factor 7, Purpose of Contacts

The purpose of contacts ranges from factual exchanges of information to situations involving significant or controversial issues and differing viewpoints, goals, or objectives.  Personal contacts serving as the basis for the level selected for this factor must be the same as the contacts serving as the basis for the level selected for Factor 6.

At Level 7-3, the purpose of contacts is to persuade program managers and other decision-making officials, with widely differing goals and interests, to follow a recommended course of action consistent with established security policies, objectives, and regulations.  This level is exemplified by contacts with managers, often in an advisory relationship, for the purpose of briefing them on program plans and levels of spending or to change program plans so that security systems may be applied to greater advantage.  Also covered at this level are contacts such as hearings and interviews to discuss and resolve derogatory or potentially derogatory information that may affect the ability to grant security clearances.  At this level, persuasion and negotiation are necessary due to the presence of conflicting security, budgetary, and program objectives which must be resolved.  Some employees present, explain, and defend controversial security policies and regulations at meetings and conferences with officials at higher levels of security program responsibility, and/or with officials from other agencies and private companies.

At Level 7-4, the purpose of contacts is to present, justify, and defend, before policy and organizational approving authorities, far-reaching security recommendations and actions such as:  proposed legislation; plans to combine, consolidate, or modify major security programs; or the redistribution of security program responsibilities among different departments and agencies.  Contacts at this level commonly involve negotiating and resolving controversial security program issues of considerable significance which are not susceptible to resolution at lower echelons in Government agencies.  Some employees act as advocates at the highest level of Government for agency and/or national security programs and policies.

The appellant’s position meets Level 7-3.  The purpose of his contacts includes exchanging information, resolving security operation problems, obtaining cooperation among organizational elements, and briefing management officials at headquarters and the stations on security concerns and vulnerabilities.  He regularly coordinates with local law enforcement and other emergency response personnel to conduct requisite drills and communicate the security procedures to be implemented at headquarters in the event of an emergency.  The appellant also briefs, in addition to local law enforcement, the FBI, TSA, and officials of other Federal agencies on security issues or incidents occurring at the Sector.  Similar to Level 7-3, his contacts involve persuading decision-making officials to follow a recommended course of action consistent with established security policies, objectives, and regulations.  This level is exemplified by contacts with headquarters and station management for the purpose of briefing them of findings from his assessments and recommendations to enhance the overall security operations.  Also like Level 7-3, the appellant’s contacts require persuasion and negotiation to overcome differing goals and interests when communicating with the general public who are onsite to protest the BP’s practices or dealing with individuals to discuss and resolve derogatory or potentially derogatory information that may impact their ability to work at the Sector.  The latter contact requires consideration of the security and protection of the Sector and preservation of privacy and reputation of individuals in potentially sensitive, delicate, or contentious situations.

The purpose of the appellant’s contacts does not meet Level 7-4.  In contrast to Level 7-4, his contacts do not require presenting, justifying, and defending far-reaching security recommendations and actions comparable to proposed legislation, plans for major security programs, or the redistribution of security program responsibilities among different departments and agencies.  The appellant’s position, situated as it is at the Sector level, does not involve significant controversial security program issues that cannot be resolved at lower echelons as described at Level 7-4.

Level 7-3 is credited for 120 points.

Factor 8, Physical Demands

This factor covers the requirements and physical demands placed on the employee by the work assignments.

The physical demands required of the appellant’s position meet but do not exceed Level 8-2, the highest level described by the PCS.  At Level 8-2, work requires regular and recurring physical exertion such as long periods of standing, walking, bending, stooping, reaching, crawling, and similar activities.  Security specialists engage in such exertions when, for example, they inspect office buildings or industrial facilities, large military complexes, or remote sites.  Performance of work may take place in attics, crawlspaces, walls, ceilings, and other limited access spaces, in rough terrain or in construction sites when planning and monitoring the installation of security systems as part of original construction.  The work may regularly involve lifting and carrying moderately heavy objects of 50 pounds or less when delivering or installing security devices.  The work may require some common characteristics of physical agility and dexterity to work in confined spaces and to move or lift moderately heavy objects.

The appellant’s contractor vetting and other personnel security work is sedentary and can be completed with no special physical effort as credited at Level 8-1.  However, the physical security duties, which he estimates occupying 35 percent of his time, and other work cannot be performed while comfortably seated at a desk or table as described at Level 8-1.  To illustrate, the appellant walks, bends, stoops, and climbs throughout routine inspections of facilities; moves and climbs ladders to troubleshoot issues with gates, mounted cameras, and other security equipment; walks rough terrain along perimeter fences, trails, and the river to assess conditions and observe paths commonly used for border crossings; and carries, moves, and transports objects such as PIV equipment, video surveillance equipment, and other objects he estimates to weigh a minimum of 50 pounds.  These and other physical demands typical of Level 8-2 are required when going to existing, new, or potential sites within the Sector’s area of control to conduct assessments, monitor progress at construction sites, survey sites for future projects, and troubleshoot gate and other security equipment problems.  His work at Sector headquarters also requires frequent walking to and from the PIV equipment, the security desk located at the front of the building, other offices to respond to internal alarms, and along the perimeter fencing and gate.  We conclude the nature of the appellant’s duties, combined with the size, number of facilities, and terrain within the Sector’s area of control, requires regular and recurring physical exertion such as long periods of standing, walking, bending, stooping, reaching, crawling, or similar activities as described at Level 8-2.

Level 8-2 is credited for 20 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings or the nature of the work assigned and the safety regulations required.

The appellant’s work environment fully meets Level 9-1 where work is primarily performed in an office-like setting involving the everyday risks or discomforts requiring normal safety precautions typical of such places as offices, meeting and training rooms, libraries, residences, and private or commercial vehicles, using safe work practices with office equipment, avoiding trips or falls, observing fire regulations and traffic signals, etc.  Similar to Level 9-1, the appellant’s work area is adequately lighted, heated, and ventilated.  Some outdoor activities are required when performing assessments and troubleshooting work.

The appellant’s work environment does not meet Level 9-2 where work is performed in settings in which there is regular and recurring exposure to moderate discomforts, such as high levels of noise in contractors’ plants, high temperatures in confined spaces, or adverse weather conditions at construction sites.  Employees at Level 9-2 may be required to use protective clothing or gear such as masks, gowns, coats, boots, goggles, gloves, or shields.  The appellant seeks to credit his position at Level 9-2, stating his assessment work in particular involves “a lot of walking through dirt, gravel and construction site” and where “high heat [is] also a factor.”  Occasionally he dons a hard hat when entering construction sites and performs outdoor activities in adverse weather conditions.  However, the full intent of Level 9-2 of work involving moderate safety risks or discomforts requiring special precautions is not met.  Although the appellant walks in dirt and gravel outdoors in high summer temperatures, Level 9-2 describes the more rigorous condition of working in high temperatures while in confined spaces.  His visits to construction sites, where structures are normally covered and enclosed, provide shelter rather than expose him to adverse weather conditions.  We find neither the frequency nor intensity of exposure equal to the discomforts described at Level 9-2 to be present in the appellant’s position.

Level 9-1 is credited for 5 points.

Summary
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 6-3 60
7.  Purpose of Contacts 7-3 120
8.  Physical Demands 8-2 20
9.  Work Environment 9-1 5
Total 2,555

 

A total of 2,555 points falls within the GS-11 range (2,355 to 2,750) on the grade conversion table in the PCS.

Decision

The appellant’s position is properly classified as Security Specialist, GS-080-11.

 

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