Washington, D.C.
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
Tropical Agriculture Research Station
U.S. Department of Agriculture
Mayaguez, Puerto Rico
Kimberly A. Steide, DPA
Principal Deputy Associate Director
Agency Compliance and Evaluation
Merit System Accountability and Compliance
12/17/2025
Date
Finality of Decision
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right to further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
Since this decision changes the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702. As discussed in this decision, our findings also show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E of the Introduction. Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings. The human resources office must submit a compliance report containing the corrected PD 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 to the Office of Personnel Management (OPM), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.
Introduction
The appellant’s position is classified as a Chemist, GS-1320-07, but he believes it should be classified at the GS-11 grade level. The position is assigned to the Agriculture Research Service, Tropical Agriculture Research Service, U.S. Department of Agriculture (hereafter referred to as “agency” or “USDA”) in Mayaguez, Puerto Rico. We have accepted and decided this appeal under section 5112(b) of title 5, United States Code (U.S.C.).
General issues
The appellant makes various statements about the classification of his current position by his agency. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of this position. By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Therefore, we have considered the appellant’s statements only insofar as they are relevant to making that comparison. Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding the agency’s classification review process are not germane to the classification appeal process.
The appellant does not state that his current position description (PD#3A8319) is accurate. Rather, he states that the PD is too general and does not properly explain his Safety Officer duties (collateral). The appellant makes assertions that the Safety Officer duties are much more important and time-consuming than the way they are presented in the PD. As a Safety Officer (collateral duties), the appellant is responsible for the disposal of chemical and hazardous materials at his work location. He is an Occupational Safety and Health Administration (OSHA) coordinator and as such he is required to perform safety and occupational duties in his day-to-day work activities. For example, if an employee is injured or becomes ill, the appellant is required to report this information. He is also responsible for communicating safety standards to his fellow employees. The appellant states that these duties account for more than 20 percent of his official duty time and his PD should include an expanded explanation of these duties in the Major Duty section.
A PD is the official record of the duties and responsibilities assigned to a position by an official with the authority to assign work. A position is the duties and responsibilities that make up the work performed by the employee. Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on a review of the actual duties and responsibilities currently assigned by management and performed by the employee. An OPM appeal decision classifies a real operating position, and not simply a PD. This decision is based on the actual work currently assigned to and performed by the appellant. Based on our fact-finding, we agree the appellant’s PD is inaccurate regarding the inclusion of the additional safety and health occupational duties.
In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position. By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be classified correctly, as a basis for deciding his appeal.
Position information
The appellant is assigned as a Chemist at the Tropical Crops and Germplasm Research Station, Tropical Agriculture Research Station, Agriculture Research Service, U.S. Department of Agriculture in Mayaguez, Puerto Rico. The Agriculture Research Service is a scientific research agency dedicated to finding solutions to agricultural problems that impact Americans each day from field to table. Likewise, the Tropical Agriculture Research Station performs scientific research to address common agricultural challenges by conducting studies and projects on the germplasm found within various tropical plants and fruits. Germplasm refers to the living genetic resources found within a plant that may serve as a marker of heredity. The researchers plant and collect a variety of different produce samples to extract and analyze the plant’s germplasm. By analyzing the plant’s germplasm, researchers gain a better understanding of the benefits and values of the crops cultivated by the Agriculture Research Service. With this information, scientists may describe and share their results with other scholars and researchers. In addition, the scientists at the Tropical Crops and Germplasm Research Station use this information to provide recommendations to growers on what cultivars they should harvest. Growers receive information on a plant’s yield, sweetness content, and nutritional value. The farmers then accept the recommendations and include the cultivars in their harvests. The result of this work is the production of high-quality produce bought and consumed by the American public.
The appellant independently conducts experiments, frequently modifying sample handling, preparation, and methodologies and/or experimental protocols to improve the experiment’s efficiency and to meet program objectives. The appellant is responsible for the evaluation and analysis of several types of produce such as cacao, red fruit, dragon fruit, and other various types of tropical fruits and legumes. He analyzes the leaves, stems, soil, and other parts of the plant through the retrieval of biological samples that reveal the germplasm within the crop. He also analyzes the plant’s macro and micronutrients, as well as other elements. To perform these experiments, the appellant uses several types of complex equipment such as the Inductively Coupled Plasma Optical Emission Spectrometer (ICP-OES), a Microwave Assisted Sample Digestion, as well as an Atomic Absorption Spectrometer.
The appellant also independently cares for and maintains the laboratory instruments, such as the Kjeldahl digestion block, ultraviolet-visible spectrometer, and the ICP-OES. When necessary, the appellant will modify, adjust, and calibrate the instruments to achieve clear and accurate results. After completion of an experiment, the appellant documents his findings in Excel and Access. The appellant is also tasked with writing scientific reports on his findings, which are often included in research articles and journals. The appellant is the coauthor of several publications and the independent author of one publication to date. As the sole Chemist located at the Tropical Crops and Germplasm Research Station in Mayaguez, the appellant maintains the laboratory’s stock inventories for the various chemicals and supplies required to complete their experiments.
The appellant works with other Tropical Agriculture Research Station staff, such as researchers, technicians, and administrative officers. He often communicates and interfaces with research students, safety officials, as well as outside stakeholders such as University professors, non-USDA research scientists, and equipment technicians. His communications are generally collaborative and for the purpose of the coordination and execution of scientific tasks. His interaction with equipment technicians is related to the recalibration, maintenance, and repair of laboratory equipment. As Safety Officer (collateral duties), the appellant provides guidance on OSHA standards that the research station is required to follow.
In reaching our classification decision, we carefully considered all information provided by the appellant and his agency including his official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to gain more information about his work, we conducted a telephone interview with both the appellant and his first-line supervisor.
Series, title, and standard determination
The agency has classified the appellant’s position in the Chemistry Series, GS-1320, titling it Chemist, and the appellant does not disagree. We concur with the agency’s title and series determination. Positions in the GS-1320 series are graded by application of the Job Family Position Classification Standard (JFS) for Professional Work in the Physical Science Group, GS-1300. Therefore, we have applied the grading criteria in the GS-1300 JFS in the evaluation that follows.
Grade determination
The GS-1300 JFS describes, in a narrative format, grade-level criteria for evaluating non-supervisory positions from GS-5 through GS-15. Work at various grade levels of professional physical scientist positions is described in terms of the typical types of assignments and level of responsibility. Work illustrations at each grade level are provided to show the nature of assignments and responsibility in specific occupations and work situations.
Physical Scientists at the GS-07 level perform a variety of technical tasks, such as selecting samples, interpolating missing data, uncovering clear discrepancies, solving minor problems, and performing scientific analyses in support of projects assigned to higher level scientists. This is the grade for advanced trainee positions in physical science professions. Advanced trainees receive assignments in terms of general instructions regarding work to be accomplished, quality and quantity expected, limitations, and suggested approaches. They exercise judgment in locating and selecting the most appropriate guides and references to apply, make routine decisions, and refer situations requiring significant deviation to the supervisor or a higher graded specialist.
Physical Scientists at the GS-09 level plan and carry out routine work. This is the “first full performance” grade for professional positions in the physical sciences. That is, grades GS-5 and GS-7 are intended to cover work that is performed within strict limits and under relatively detailed supervision and, for professional positions, these grades are intended as training levels only. They select and make minor adaptations to procedures and accepted practices and handle unexpected conditions arising in the normal course of the work. For recurring assignments, GS-09 scientists are responsible for organizing the work, following prescribed methods and guidelines, and recognizing conditions and results that may affect the findings. By comparison, GS-07’s is held accountable primarily for the accurate application of standard methods, techniques, and procedures.
Physical scientists at the GS-11 level plan and execute complex studies, which usually involve intensive investigations into one or more recognized phenomena. The work typically involves conventional methods and techniques, though going beyond clear precedents, and requires adapting methods to the problems at hand and interpreting findings in terms of their scientific significance. Finished products are reviewed for adequacy of conclusions and soundness of the procedures and methods used. Assignments generally do not involve radical departures from past practices or require the development of new, novel or innovative approaches, methods or techniques.
A work illustration of a chemist at the GS-11 level describes serving as a specialist in the area of spectroscopy and the analysis of metals, metal alloys, and related products in an installation’s quality assurance laboratory, where the primary activities are ship maintenance, repair and overhaul, including the manufacture of metal parts and equipment. The employee independently plans and completes the work, analyzing difficult, complex, and unusual chemical samples received in the laboratory, and modifies established methods and practices as necessary to complete the work. Work is reviewed from an overall standpoint for feasibility and effectiveness in meeting the requirements of assignments.
The appellant’s position exceeds the GS-07 level. Unlike the GS-07, the appellant works well beyond the advanced trainee level. For instance, the appellant’s work requires him to make significant modifications and adaptations to established procedures, techniques, and equipment to obtain an accurate result. Moreover, unlike the GS-07, the appellant is responsible for the planning and execution of scientific projects and experiments. For example, when the appellant receives organic samples from the field, he must determine, based on the plant’s physical composition and other factors, how to best prepare the sample for analysis. This is often a complex aspect of the appellant’s work, as he must determine the proper manner to disintegrate a sample, as well as choose the correct equipment to process the sample through to obtain a result. Also, unlike the GS-07, the appellant does not receive assignments in terms of their general instructions, but rather, is tasked to meet an overall objective or scientific goal (i.e., analyzing cultivars for specific mineral concentrations). Like the GS-07, the appellant selects the most appropriate guides and references to apply to his work. However, unlike the GS-07, the appellant uses independent judgement to modify and adapt guidelines, as well as deviate from established guidelines when he finds it necessary, without requiring the permission or guidance of his supervisor or another higher graded scientist.
The appellant also exceeds the GS-09 level. Similar to the GS-09, the appellant works autonomously and is solely responsible for using the various laboratory equipment to process samples. However, unlike the GS-09, the appellant’s work with the equipment often requires him to modify and adapt the technology to achieve the desired results. In addition, the appellant’s projects are often larger in scale and require the use of more complex equipment. Like the GS-09, the appellant organizes, plans, and carries out his work, however, the appellant will make major adaptations to procedures and accepted practices to handle unexpected conditions arising in the normal course of his experiments. Also, unlike the GS-09, the appellant is not required to follow prescribed methods and guidelines to achieve the necessary results. Rather, he will use his own judgement based on his work experience to choose and apply the proper methods, techniques, or procedures to complete his assignments.
The appellant’s position meets the GS-11 level. Like this level, he spends the majority of his time analyzing the macro and micronutrients and other organic elements found within a plant’s leaves, stem, roots, and soil. He retrieves the biological material or sample, dries it, weighs it, grinds it, puts it through a sieve to create a powder, and then digests it through the Microwave Assisted Sample Digestion. From here, he applies conventional scientific methods and techniques such as quantitative chemical analysis to analyze the macro and micronutrients found in the organic sample. Overall, the retrieval of the various elements requires the use of different protocols, which the appellant uses independent judgement to select and apply. Further, throughout the experimentation process, the appellant is often required to modify and adapt methods, procedures, techniques, and equipment to resolve a variety of laboratory and field work problems. For example, the appellant needed to alter the pH of a certain tree crop’s soil to retrieve an accurate result. In this instance, the appellant used independent judgement and chose to apply acids to the field’s soil to successfully modify the pH.
Unlike the GS-07 and GS-09 levels, the appellant interprets scientific findings by comparing his work to past data or existing results derived from other samples collected and analyzed throughout the previous year. He also compares his work to that of other scientists whose work he references in available scientific articles and journals. This comparison allows the appellant to determine the soundness and consistency of his results, as well as their scientific significance. If the work contains scientific value, the appellant, either independently or in collaboration with his supervisor and other lead scientists, will publish their findings in scientific literature. The appellant’s work product is submitted and reviewed for the adequacy of conclusions, consistency, and soundness of procedures and methods used. Often, the appellant applies statistical analysis to his work to extract and hone an interpretation. He then either submits his findings to his supervisor or other lead scientists, or he and the scientist he is currently working with will meet and discuss his interpretation. Although the work does not require a radical departure from past practices or requires the development of new, novel, or innovative approaches, the appellant often modifies and adapts methods, equipment, and procedures to attain a more accurate and scientifically significant result.
The appellant has coauthored several published scientific articles that are used throughout the scientific community. The material is used by scientists to better know and understand a particular plant’s germplasm, including its benefits and value. The research center also provides external scientists and researchers with their analysis of various cultivars, which are plants that have been selectively bred for specific traits and are maintained through cultivation. With this information, scientists, stakeholders, and the agricultural community gain insight into the work being performed by the Tropical Agriculture Research Station and use this information in their future research, project planning, grant approval, as well as the physical cultivation of the fruit, which often is bought and consumed by everyday Americans.
Like the GS-11 level, the appellant performs his assignments with wide latitude. He uses independent judgement to perform work that is considerably complex and difficult. The appellant’s supervisor and other lead scientists set the work priorities and goals; however, the appellant carries out his duties under minimal supervision and self-sufficiently modifies and adapts scientific methods and procedures. His work has also required him to obtain higher-level, formal education to include a bachelor’s degree and a master’s degree.
Based on the preceding analysis, we find that the appellant’s position is properly graded at the GS-11 level.
Decision
The appellant’s position is properly classified as Chemist, GS-1320-11.