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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 names] et al.
Electronics Technician (ATCALS)
Airfield Systems Maintenance Flight
[number] Operations Support Squadron
[number] Test Wing
Air Force Materiel Command
U.S. Department of the Air Force
[geographic location]
Electronics Technician
(parenthetical at agency discretion)

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



As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which 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).

Decision sent to:

[Appellant and HR office addresses]


On June 27, 2012, the OPM’s Atlanta Oversight office (now Atlanta Agency Compliance and Evaluation (ACE)) accepted a classification appeal from [appellants’ names].  The appellants occupy identical additional positions (hereinafter referred to as position) currently classified as Electronics Technician (Air Traffic Control and Landing Systems (ATCALS)), GS-856-11, which they believe should be classified at the GS-12 grade level.  The appellants’ position is assigned to the Airfield Systems Maintenance Flight, [number] Operations Support Squadron, [number] Test Wing, Air Force Materiel Command, U.S. Department of the Air Force (AF), at [geographic location].  We received the complete agency’s administrative report on March 5, 2013.  Due to program workload considerations, the appeal was transferred to Dallas ACE for adjudication.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

On August 25, 2011, the servicing human resources (HR) office reviewed the work performed under the appellants’ official position description (PD), number [number], at the request of the appellants.  The HR office determined the position was appropriately classified as Electronics Technician (ATCALS), GS-856-11.  The appellants then filed a classification appeal with the Department of Defense (DOD) Civilian Personnel Advisory Service (CPAS).  Their November 23, 2011, decision sustained the evaluation of the HR office.

The appellants state they perform work similar to other positions assigned to airbases with ATCALS equal to or less complex than the AFB’s but classified at the GS-12 grade level.  By law, we must classify positions solely by comparing their 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 appellants’ current duties to other positions, which may or may not be classified properly, as the basis for deciding their appeal.

The appellants ask OPM to task the DOD with a classification consistency review of ATCALS technician positions (the request states, “[s]everal positions in the U.S. Army, U.S. Navy and U.S. Marine Corps are classified inconsistently with the positions here at [geographic location] and across the U.S. Air Force.).  They state their position requires proficiency in the areas of ground radar, ground radio, and meteorological/navigation while, in contrast, similar positions with the Army and U.S. Marine Corps (USMC) typically split the disciplines with ground radar separate from the combined ground radio and meteorological/navigation fields and are classified at the GS-12 grade level.

Like OPM, the appellants’ agency must classify positions based on comparison to OPM PCSs and guidelines.  However, the agency also has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions.  The appellant forwarded 16 PDs for GS-856-12 electronics technician positions, one from USMC and 15 from Army.  In reviewing the PDs, we noted significant differences between the appellants’ and the USMC’s PD; the latter position functions as a lead technician for a maintenance crew, assigning and overseeing maintenance related activities and evaluating ongoing progress of trainees.  We conclude the GS-12 PD describes duties and responsibilities materially different from those performed by the appellants and, thus, may support a different classification.

The remaining Army PDs appear to describe duties and responsibilities similar to the appellants’ position.  Positions which may on the surface appear similar may include significantly different duties and responsibilities that affect the classification.  Several of the GS-12 Army PDs appear to describe positions, unlike the appellants’, with responsibility for supervising employees; serving as a project manager; procuring research-grade, experimental, and prototypical electronic/computer systems; or a combination of such work.  Like with the USMC PD, we conclude these PDs describe duties and responsibilities substantially different from those performed by the appellants and, thus, may support a different classification.

Regardless, we found at least 7 of the 15 Army PDs describe duties similar to the appellants’ with no discernible differences in the major duties described and/or performed at a base with ATCALS equal to or less complex than the AFB’s (the PDs provided by the appellants for ATCALS technicians at Fort Lewis, Washington; Fort Bliss, Texas; Fort Hood, Texas; Fort Huachuca, Arizona; Fort Sill, Oklahoma; Fort Stewart, Georgia; and Fort Rucker, Alabama).  However, we found 11 of the PDs cite and/or base their classification on the application of obsolete PCSs, including the Department of Transportation Position Classification Guide for Electronics Technician Positions, GS-0856, dated December 1972 and revised in 1984, which was specifically canceled for use in evaluating 0856 positions by the Job Family Standard (JFS) for Technical Work in the Engineering and Architecture Group, 0800 (0800T JFS).  One PD (Fort Shafter) was classified in 2005, prior to issuance of the 0800T JFS in 2007.  We also found no evidence to confirm that the Army PDs have been classified and certified by the agency and that the PDs are actively used with employees assigned to them.  Thus, we lack sufficient information to warrant our tasking a classification consistency report on the positions cited by the appellants.

By law, agencies must classify positions consistently with published classification standards and in accordance with the principle of equal pay for substantially equal work.  Under 5 CFR 511.612, agencies must review their own classification decisions for identical, similar, or related positions to ensure consistency with OPM certificates.  The DOD CPAS has primary responsibility for ensuring classification consistency within the military departments and other DOD components.  By separate letter, we are apprising CPAS of our classification consistency concerns including inconsistencies in the evaluation of the similarly described duties and responsibilities, e.g., we found similarly described work environments, considered under Factor 9, credited at Level 1, 2, and 3 and inadequate explanations for factor-level assignments (e.g., we found Level 9-3 credited based on:  “Work is performed inside and outside on fixed station equipment.  Technician is exposed to shock hazards.  Occasionally required to work outside during inclement weather.”).  We have asked CPAS to review and respond to our concerns and provide a copy of that response to the appellants.

Position information

The AFB is delegated responsibility by the Federal Aviation Administration (FAA) to control military and civilian air traffic within assigned airspace of the National Airspace System (NAS).  With more than 400,000 square miles of airspace, the AFB maintains a radar control facility and two air traffic control towers.  The primary purpose of the appellants’ position is to provide technical expertise in the maintenance and certification of the ATCALS assigned to the AFB and its auxiliary fields.  The appellants are assigned to one of three crews with work schedules staggered from 6 a.m. to 5 p.m.  Each crew is under the direction of a Supervisory Electronics Technician (a GS-856-12 position), who is supervised by the Flight Chief (a GS-301-13 position).

The appellants indicate the percentages of time devoted to various tasks are, in general, consistent with those documented in the PD.  They estimate spending 60 percent of their time on certifying assigned systems and sub-systems to ensure compliance with the established standards and safety requirements of the AF and FAA.  The appellants’ work entails installing, modifying, testing, repairing, overhauling, calibrating, maintaining, evaluating, and certifying to the performance of the AFB’s complex integrated and interfacing electronic systems, subsystems, and components.  The following is a list of the AFB’s systems and complexity level (FAA classifies systems in three categories with category III considered the most complex):

Automation System

AN/FSQ-204 Standard Terminal Automation Replacement System (STARS) (Category III)

AN/FSC-127 Enhanced Terminal Voice Switch (Category III)

Remote Tower Display Workstation (Category II)

Local Tower Display Workstation (Category II)

Flight Data Input/Output System (Category I)

Communication System

Ultra high frequency and very high frequency (VHF) transmitters, receivers, and transceivers

Digital Voice Recorder (Category I)

Surveillance System

AN/GPN-30 Digital Airport Surveillance Radar includes:

            Primary Surveillance Radar (Category II)

            Monopulse Secondary Surveillance Radar (Category II)

            Remote Site Monitor System (Category I)

Weather System

AN/Weather System Radar, 88 Doppler Next Generation Radar (NEXRAD) (Category II)

Digital Ionospheric Sounding System

AN/FMQ-19 Automatic Meteorological System (Category II)

The appellants participate in the installation, modification, and testing of new ATCALS and weather equipment as directed by headquarters or other higher authority.  The work may involve designing and building test products and research for replacement or improvement of components and circuit design.  Preventative maintenance inspection (PMI) schedules are maintained to check the condition of ATCALS components with the intent of preventing or identifying problems before it escalating to a major problem.  The appellants are assigned daily PMI tasks to be completed.  The work may involve, for example, analyzing the historical records and reports of equipment or using stand-alone test equipment or built-in test equipment to investigate, test, calibrate, analyze, isolate, and correct the malfunctions identified with the AFB’s integrated systems and subsystems.

The appellants state they spend 15 percent of their time on troubleshooting equipment duties, determining if malfunctions warrant shutdown by identifying the cause of the breakdown or failure through knowledge and application of electronic theory, system analyses, mathematical analysis, schematics, wiring diagrams, test equipment, etc.  Throughout the shift, the appellants answer, respond to, and resolve telephone calls from air traffic controllers and other customers reporting equipment failures and issues via the Flight’s job control line.  They also rotate on-call job control duties after-duty hours, carrying a cell phone to take emergency calls in the event of an ATCALS failure or problem.  The appellants determine whether the systems are operationally acceptable and safe within the air traffic control and air navigation standards and tolerances.

They devote another 15 percent of their time providing on-the-job training and technical guidance to each other on all equipment maintenance tasks.  The goal is to obtain proficiency in over 860 individual and specialized tasks covering the ground radar, ground radio, and meteorological/navigation fields.  Formal Air Education and Training Command-approved training opportunities are infrequent (usually one or two opportunities annually), and the Flight offsets the shortage by relying on the appellants’ experience to provide in-house training covering specialized task areas.

The appellants spend the remaining 10 percent of the time cleaning equipment, sweeping, straightening, and other housekeeping tasks at the shop, in addition to other responsibilities associated with maintaining a safe and clean work environment.

The appellants’ PD and other material of record furnish much more information about their duties and responsibilities, and how they are performed.  The appellants and supervisors certified to the accuracy of the duties described in the official PD, number [number].  During the telephone audits, we determined the description of major duties and responsibilities accurately reflects the appellants’ assignments and we incorporate the PD by reference into this decision.

To help decide this appeal, we conducted telephone audits with the appellants on April 10 and 17, 2013, in addition to follow-up telephone conversations.  We conducted separate telephone interviews with each of the first-level supervisors on May 8, 2013, and with the second-level supervisor on May 9, 2013.  In reaching our classification decision, we carefully considered all of the information gained from these interviews, as well as the written information furnished by the appellants and agency.

Series, title, and standard determination

The agency assigned the appellants’ position to the GS-856 Electronics Technical Series.  The appellants do not disagree and, after careful review of the record, we concur.  We applied the grading criteria in the 0800T JFS.  The authorized title for positions in the GS-856 series is Electronics Technician.  The agency supplemented the authorized title with an ATCALS parenthetical.  The 0800T JFS does not prescribe any authorized specializations for the GS-856 series, but the agency may supplement official titles with parenthetical titles as provided for in the Introduction.

Grade determination

The 0800T JFS 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 JFS.  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 aspects and still not be credited at a higher level.

The appellants only disagree with the agency’s evaluation of Factors 5, 6, 8, and 9.  We reviewed the agency’s determination for Factors 1, 2, 3, 4, and 7, concur, and have credited the position accordingly.  Our evaluation will focus on the remaining factors.

Factor 5, Scope and Effect

This factor covers the relationship between the nature of the work (i.e., purpose, breadth, and depth of the assignment) and the effect of work products or services both inside and outside the organization.

At Level 5-3, work requires applying a considerable number of different basic but established methods, procedures, and techniques.  Work affects the design or operation of systems, programs, processes, or equipment; and the timeliness and economy of operations, services, or equipment.

At Level 5-4, work involves establishing criteria, formulating projects, assessing program effectiveness, or analyzing a variety of unusual conditions, problems, or questions.  Work affects a wide range of agency activities, industrial concerns, or the operation of other agencies.

The appellants’ position fully meets Level 5-3.  Their work involves installing, modifying, testing, repairing, overhauling, calibrating, maintaining, evaluating, and certifying to the performance of complex integrated and interfacing electronic systems and sub-systems.  The appellants perform test and analysis work to determine the operating status of approximately 200 “end items” or systems at the AFB.  In dealing with a combination of older and newer equipment and methods, they resolve associated issues when connecting digital to analog equipment.  For example, they encountered various problems while installing, aligning, and testing new terminal controller workstation monitors to the AFB’s STARS system with its first-generation processor.  In connecting the old with the new, the light emitting diode monitor produced a flickering on the screen’s image.  The appellants worked with the FAA’s STARS Central Support Complex (SCSC) at the William J. Hughes Technical Center (which serves as the national scientific test base for research and development, test and evaluation, and verification and validation in air traffic control, communications, navigation, airports, etc.) to test, troubleshoot, and repair the problem by developing an alignment procedure usable for first-generation STARS systems.  The alignment procedure resulted in cost savings by avoiding the expense of additional parts.  This and other work involves applying a considerable number of different established methods, procedures, and techniques affecting the design or operation of the AFB’s systems, programs, processes, and equipment; in addition to the timeliness and economy of operations, services, and equipment as described at Level 5-3.

The appellants seek to credit the position at Level 5-4, stating the work involves analyzing a variety of unusual conditions, problems, or questions affecting a wide variety of agencies and their operations.  They specifically cite their work on state-of-the-art equipment with established standards either lacking or continually changing, in addition to work in collaborating with FAA and others to establish the processes and procedures of maintenance handbooks and other guidelines (e.g., the FAA forwards proposed schematics to appellants, who review and redline procedures with suggested changes).  They also said their work’s effect meets Level 5-4, as the AFB controls airspace within the NAS and provides air traffic control for three DOD components.

The scope of the appellants’ work approaches Level 5-4, where duties and responsibilities involve the analysis of a variety of unusual conditions, problems, or questions.  The primary purpose of their work is to ensure continuous and reliable operation of the AFB’s existing air traffic control, landing, communication, and weather systems and equipment.  For example, when a STARS “fault” is identified, the appellants analyze and diagnose the fault by initiating the automatic fault isolation function to distinguish likely causes.  If, after testing each approach, the fault remains, they employ external, sophisticated test equipment to identify and resolve the deficiency.  This and other work illustrates the appellants’ work on existing complex electronic systems.  However, with the Flight’s combining the ground radar, radio, and meteorological fields, the expectation of the appellants’ position is to be proficient in over 860 specialized tasks in the disciplines to be considered a mission-ready technician.  The first- and second-level supervisors agree it is rare, when hiring an individual to encumber the appealed position, to find a candidate with experience in all fields.  The selectee is typically the individual most knowledgeable in one of the disciplines with aptitude to learn the others.  As a result, the appellants regularly conduct on-the-job training in the discipline and on the tasks consistent with their background while attending training in other areas.  Due to its location on the [general location], the AFB is also often the first to test the operability of new systems or equipment in an [specific type] environment and report on any problems or issues.  We found the Flight’s merging of career fields and its periodic role as ‘testers’ of the newest procured ATCALS equipment to have a positive impact on the purpose, breadth, and depth of the appellants’ assignments.

However, the effect of the appellants’ work falls short of Level 5-4, where work affects a wide range of agency activities, industrial concerns, or the operation of other agencies.  Their PD and our interviews confirm the primary purpose of the position is to provide technical expertise to maintain and certify the AFB’s ATCALS.  The work entails ensuring systems operate at peak efficiency, executing tasks and fixes timely and within established codes, directives, and specifications in an active airfield environment.  The appellants’ work immediately and significantly affects the operations of the AFB’s air traffic operations (i.e., the direct effect of the position).  The actions of the air traffic controllers, in turn, provide for the safe, orderly, and expeditious air traffic control support and services to aircraft in the AFB’s NAS airspace (i.e., the indirect effect of the position).  Furthermore, the appellants can shut down ATCALS equipment in a fire, flood, or similar emergency situation but must notify the first-level supervisor immediately.  In other situations, the second-level supervisor confirms the appellants advise on the equipment’s operability to the Watch Supervisor, the air traffic controller responsible for control operations, who makes the decision whether to use equipment at a reduced capacity.  If so, the Watch Supervisor assumes full legal liability.  The appellants’ work does not affect a wide range of agency activities, the operation of other agencies, or industrial concerns as expected at Level 5-4.  Their work involves designing and building test products, conducting research and replacement of improvements of components and circuit design, etc.  The direct effect of this and other work is a match for the Level 5-3 description of positions affecting the design or operation of systems, programs, processes, and equipment.  That the appellants seek out the assistance of FAA or other organizations to effectively perform their duties does not change the primary activity-level focus and purpose of their work.    

Level 5-3 is credited for 150 points.

Factor 6, Personal Contacts

This factor includes face-to-face and telephone contacts with persons not in the supervisory chain.  Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place.

The agency credited the appellants’ position at Level 2, but we found the position exceeds this level where contacts are with employees and managers in the same agency, both inside and outside of the immediate office or related units, as well as members of the general public, in a moderately structured setting.  Level 2 contacts with employees and managers may be from various levels within the agency, such as headquarters, regions, districts, field offices, or other operating offices at the same location.

We found the appellants’ position meets Level 3, where contacts are with individuals or groups from outside the agency, including consultants, contractors, vendors, or representatives of professional associations, in moderately unstructured settings.  The purpose and extent of each is different.  This level may also include contacts with agency officials who are several managerial levels removed from the employee when such contacts occur on an ad hoc basis.  The employee must recognize or learn the role and authority of each party during the course of the meeting.

The appellants are responsible for the full range of activities necessary to maintain, repair, and certify complex, complete electronic equipment and systems.  The ATCALS can present unique problems resulting from connecting to and communicating with other equipment and systems.  Diagnosing problems may be complicated by the requirement to perform analyses to determine the specific piece of equipment, part, or connection, which may geographically be in another location or is the responsibility of an organization outside the appellants’, causing the malfunction.  They work with a variety of digital and analog audio and data circuits providing telecommunications, radar data, and weather information.  When circuit and other issues occur, this entails working with the National Weather Service’s Radar Operations Center; the FAA’s Terminal Radar Approach Control Facilities in [city, state]; and various AF and non-AF organizations at the different circuit ends.  For example, in troubleshooting an issue with a transceiver’s overlapping frequency, the appellants communicated with [name] Air Logistics Center and [name] Army Depot when they detected a radio module caused the transmitter to communicate out of the band which led to problems with closely assigned radio frequencies.

The appellants also regularly communicate with FAA engineers and AFB civil engineering staff on various ATCALS issues; e.g., in detecting “noise” from VHF interference, they identified a power line was generating the noise when wind speeds exceed 10 miles per hour within a quarter mile of the receiver.  After discussions with FAA engineers, the appellants communicated with AFB civil engineering staff to eliminate VHF interference by repairing poles.  Consistent with Level 3, this and other contacts are with individuals at all organizational levels inside and outside the AF with competing objectives (e.g., when the organization denies being the source of the problem and resists fixing the problem).  In addition to advising air traffic controllers on the operability of the AFB’s ATCALS, the appellants’ regular contacts are with technical staff at the AF’s system program offices and second-level engineering staff at FAA’s Technical Center and other facilities.

Also similar to Level 3, the appellants’ position requires regular and recurring contact with contractors, vendors, communications service providers, and other private industry representatives (e.g., Raytheon, Coast Com, InDyne, AT&T, Sprint, Winstream, Coastal Environmental Systems, and Centel Corporation) when participating in the installation, modification, and final testing of ATCALS and weather equipment; diagnosing causes of equipment degradation and malfunctions; completing PMI tasks; etc.  For example, the System Interface Unit component of the air traffic control radar was no longer procurable.  To install the Longport replacement unit, the appellants communicated with the FAA’s second-level engineering staff and the Sunhillo Corporation, the unit’s provider, to tailor, maintain, configure, and test the component in the AFB’s specific environment while maintaining the reliability of STARS data.  This and other contacts occur in a moderately unstructured setting, where their contacts (which are described by the second-level supervisor as “most definitely a requirement of the job”) are not established on a routine basis, the purpose and extent of each contact varies, and the role and authority of each party is identified and developed during the course of the contact as described at Level 3.  The appellants’ position meets but does not exceed Level 3, the highest level described in the JFS.

Factors 6 and 7 are interdependent.  The contacts selected for crediting Factor 6 are used to evaluate Factor 7, and the appropriate level for personal contacts and the corresponding level for purpose of contacts are determined by applying the point assignment chart for Factors 6 and 7.  We agree with the agency’s crediting Factor 7 at Level b.  Consequently, Level 3-b is credited for 110 points.

Factor 8, Physical Demands

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

At Level 8-2, work requires some physical exertion such as long periods of standing; walking over rough, uneven, rocky, or slippery surfaces; recurring bending, crouching, stooping, stretching, climbing, or similar activities; recurring lifting of light to moderately heavy items weighing less than 50 pounds, such as testing or measuring equipment; and/or regular visits to construction, industrial, marine, or outdoor sites.

At Level 8-3, work requires considerable and strenuous physical exertion such as frequent climbing of tall ladders, staging, or scaffolding in dry-dock and vessel areas; working in areas where footing can be treacherous (e.g., on rocky banks of bodies of fast-water, slippery docks, or steep hillsides); lifting heavy objects weighing 50 pounds or more; and frequent crouching or crawling in restricted areas.

The appellants’ position meets Level 8-2.  Comparable to this level, their work requires long periods of standing; walking over the rough, uneven, and slippery surfaces of the airfield and shop environment; recurring bending, crouching, stooping, and stretching; crawling and squeezing into tight places; recurring lifting of equipment and tools weighing less than 50 pounds; climbing in, out, and on and around machinery; and regular visits to outdoor airfield sites.

The appellants seek to credit the position at Level 8-3, stating the work involves climbing tall ladders and towers, lifting heavy objects weighing more than 50 pounds, and frequent crouching or crawling in restricted areas.  They state, for example, that the work requires climbing up to 100 feet to access towers and antennas; agility and dexterity when working in tight spaces such as changing a STARS processor or in the closed-hatched NEXRAD with the rotating antenna; and lifting, carrying, or moving heavy objects such as central processing units weighing 70 pounds, spectrum analyzers and other test equipment weighing 40 pounds, etc.  The record shows that for safety reasons two-person lifts are necessary to move objects weighing 75 pounds or more with dollies or other heavy-lift devices available to move such items when practicable.  The appellants occasionally climb up to 20 feet on a ladder with a 40-pound motor approximately three to five times a year when one of the NEXRAD’s two motors fails.

The first- and second-level supervisors agree the appellants must be in good physical condition to perform the physically demanding work.  According to the supervisors, reasons for the physical rigor required of the position vary but include:  prolonged standing in outdoor conditions; driving for long periods of time; sustaining awkward positions like squatting and stooping when running wires; and occasional climbing and heavy lifting.  However, the appellants’ work does not meet Level 8-3 where duties require regular and prolonged periods of considerable and strenuous physical exertion.  Their PMI and other tasks require bursts of strength when lifting heavy objects, working in tight spaces, or climbing, but this and other work do not require sustaining strenuous physical exertion on a regular basis and for a protracted period of time as described at Level 8-3.  Such physically demanding tasks do not occur with sufficient frequency to control the evaluation of this factor for purposes of the position classification process.

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.  Additionally, any safety regulations related to the work assigned are considered.

At Level 9-2, work involves regular and recurring exposure to moderate risks and discomforts such as:  dust, strong odors, or fumes from fuels, chemicals, or engine exhaust; high levels of noise and vibration, dust, grease, electrical hazards, uncovered moving parts of machinery, moving machinery; or outdoor conditions involving moderate exposure to rain, cold/hot weather, etc.  At Level 9-2, the work environment requires staying alert continually and taking special safety precautions including wearing special protective clothing items.

At Level 9-3, the work environment involves high risks of exposure to potentially dangerous situations or unusual environmental stress requiring a range of safety and other precautions where conditions cannot be controlled (e.g., working at great heights under extreme outdoor weather conditions.

The appellants’ position meets Level 9-2.  Similar to this level, their work involves exposure to moderate risk situations and discomforts such as dust, odors, or fumes; high levels of electrical hazards, grease, dust, uncovered moving parts of machinery, moving machinery; and adverse weather conditions including hot, cold, dry, humid, and wet.  Also at this level, their work on and near active airfields exposes them to loud noises, fumes, and moving propellers and other machinery.  The appellants’ airfield and shop work requires taking safety precautions including wearing boots, ear protection, safety goggles, gloves, face masks, hard hat, and other special protective items as expected at Level 9-2.

The appellants seek to credit Level 9-3, citing their position’s working on the NEXRAD with voltages up to 60,000 and other high-voltage equipment and requiring certification to climb 75- to 100-foot towers and antennas in various weather conditions.  The first- and second-level supervisors estimate the appellants climb at least once annually to maintain certification requirements but three times on average with a precise number varying depending on an individual’s interest in climbing.  The supervisors said the risks associated with the position are high and plentiful but have been mitigated by established safety protocols to ensure dangers to the appellants are moderated and manageable.  Safety precautions include:  personnel are summoned inside if lightning is sighted within a five-mile radius; lockout/tagout safety procedures are required to ensure dangerous equipment is properly shut and remain off until completion of maintenance or servicing; jobs are worked, when possible, as a two- or more person team to guarantee a safety observer presence.  The record shows the appellants perform work on electronic systems, sub-systems, and equipment, thus risking exposure to potential mechanical and electrical hazards.  Their work also requires being vigilant of snakes, black widow and brown recluse spiders, and other potentially dangerous wildlife natural to that habitat.

However, the appellants’ work environment does not rise to Level 9-3, at which the work involves regular and recurring exposure to potentially dangerous situations where conditions cannot be controlled  Occurring only occasionally, their climbing duties do not involve regular and recurring periods of working at great heights under extreme outdoor weather conditions as described at Level 9-3.  They do not perform regular and recurring work in an environment where conditions cannot be controlled such as working at great heights under extreme weather conditions, working directly with unstable explosives as part of the testing process, and/or similar situations where the potentially dangerous conditions cannot be controlled as expected at Level 9-3.  The safety precautions adopted and applied by the appellants are no more extensive than that described at Level 9-2.

Level 9-2 is credited for 20 points.

Factor Level Points
1.  Knowledge Required by the Position 1-7 1250
2.  Supervisory Controls 2-4 450
3.  Guidelines 3-4 450
4.  Complexity 4-4 225
5.  Scope and Effect 5-3 150
6. & 7.  Personal Contacts and Purpose of Contacts 3-b 110
8.  Physical Demands 8-2 20
9.  Work Environment 9-2 20
Total 2,675


A total of 2,675 points falls within the GS-11 range (2,355 to 2,750) on the grade conversion table in the JFS.


The position is properly classified as Electronics Technician (parenthetical title at agency’s discretion), GS-856-11.

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