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

As discussed in this decision, our findings show the appellants’ 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 appellants’ PD to reflect our findings.  The servicing human resources (HR) 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 U.S. Office of Personnel Management (OPM), Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellants’ position is currently classified as Supply Technician, GS-2005.  However, they believe their position should be covered under the Federal Wage System (FWS) and classified as a Materials Handler, WG-6907.  The position is assigned to the Inventory Management Branch (IMB), Supply and Services Division (SSD), 404th Logistics Readiness Center (LRC) (Joint Base Lewis-McChord (JBLM)), 404th Army Field Support Brigade, Army Sustainment Command, U.S. Department of the Army (Army) at JBLM, Washington.  We have accepted and decided this appeal under section 5103 of title 5, United States Code.

General issues

The appellants make various statements about the agency’s classification review process and compare their General Schedule (GS) position to FWS jobs within their facility.   In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellants’ position.  By law, we must make that decision 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 PCSs is the exclusive method for classifying positions, we cannot compare the appellants’ position to others that may or may not be properly classified, as a basis for deciding their appeal.  Because our decision sets aside all previous agency decisions, the appellants’ concerns regarding their agency’s classification review process are not germane to this decision.

The appellants state their PD of record number EU467970 is not accurate, but initially the appellants’ first and second-level supervisors certified to its accuracy.  However, our review found that certain duties described in the official PD are not performed by the appellants. Specifically, the PD states the appellants maintain automated records to reflect all items of property, repair parts, and components received, issued, or otherwise disposed.  It also states the appellants receive a variety of assets as excess items, stores excess items in appropriate locations, and prepares documentation to properly process these items to disposal agencies.  However, although the appellants are responsible for maintaining automated records of items and material which enter and leave the issue point (IP), they are not responsible for processing, recording, or tracking items, material, and property slated for disposal.  Instead, the Return Materials Department (RTM) is responsible for determining the serviceability of return items (e.g., equipment, parts); the most appropriate way to dispose of non-serviceable items; and maintaining all electronic and hard-copy records of disposed items, material, and property.

The PD also states the appellants prepare turn-in documents, issue documents, and other transaction documents for expendable, non-expendable, and durable property.  However, the appellants are not responsible for documenting turn-ins.  This responsibility rests with RTM.

In addition, the PD states the appellant’s process receipt transactions for material being received by contract, local purchase, and other means. Furthermore, they compare packing lists, receiving documents, bills of lading, inspection reports, and other documents with contracts, purchase orders, or requisitions to verify accuracy of stock identification, quantity, cost, and other pertinent data.  However, although the appellants perform a variety of general clerical supply support processes for all customer-ordered items and materials entering the IP (e.g., review items against the bill of lading; process DD Form 1348’s; perform prescribed G-Army entries (i.e., electronic supply and material tracking system), they are not responsible for processing receipt transactions for items and materials being received by customers from entities outside the facility’s warehouse (e.g., contract purchases, local purchases) nor are they responsible for performing detailed comparisons of contract-order items and materials to various receiving documents (e.g., packing lists, purchase orders) for the purpose of verifying receipt of the appropriate type, amount, quality, and condition of contract-order items for the customer.  Instead, these responsibilities rests primarily with the customer’s designated representative.

During our analysis, we found certain other duties stated in the PD are also performed by the customer’s designated representative and not by the appellants and they include: the authority to accept or reject items and material; call to the attention of the Stock Record Accountability Officer any discrepancies disclosed by physical inventory; warehouse refusals; transfer of material between accounts; location changes; condition code changes; receiving and inspecting a wide variety of assets and rejecting those which are damaged or incomplete.

The PD states the appellants use their knowledge of the organization’s automated supply system (i.e. G-Army) to perform searches for specific information and reconstruction of transaction processes.  However, although the appellants are trained to perform search for specific information in order to reconstruct transactions associated with items and material received by customers through the IP, the primary responsibility for tracking and reconstructing transactions associated with customer’s items and material received through the IP rests with the customer’s designated representative.

The PD states the appellants operate a motor vehicle, up to 5-ton truck.  However, although the appellants operate a fork lift and a hand-operate hydraulic pallet jacks, they do not operate over-the-road freight delivery vehicles (e.g., pickup trucks, delivery vans, freight trucks) with capacities up to 5-tons.  This responsibility rests with other facility personnel and private and commercial freight lines.

A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that make up the work performed by the employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal 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 a job description. This decision is based on the work currently assigned and performed by the appellants.  Based on our analysis above, we found that the PD did not meet the standard of adequacy addressed on pages 10-11. Therefore, because PDs must meet the standard of adequacy addressed on pages 10-11 of the Introduction, the agency must revise the PD to reflect our findings.

Position information

The 404th LRC (JBLM) is a modular training and mobilization center designed to provide services and logistics support to Army expeditionary forces.  The IP is an approximately 16,000 square-foot temporary holding area which adjoins the SSD Stock Control Branch’s warehouse.  The IP services 360 military and Federal civilian customers and receives thousands individual pieces of inventory each year valued at millions of dollars

Our review concluded the appellants spend approximately 40 percent of their time recording and tracking items and material received by and issued from the IP.  They are responsible for receiving customer-ordered items from the facility’s warehouse and other sources (e.g., off-base contracted vendors); storing items and material in customer-specific bins or secure storage areas within IP; ensuring the security of all customer-ordered items and materials stored within the IP; informing customers when their orders have arrived; and maintaining hard-copy and electronic records of all items and materials entering and leaving the IP such as G-Army (i.e., automated supply and equipment tracking system), DD Form 1348’s (i.e., Issue Release/Receipt Document used to track movement of items and material from point of origin to final destination), etc.  The appellants are also responsible for ensuring all required electronic and hard-copy documents are completed before allowing customers to remove items and materials from the IP.

The appellants perform scheduled and unscheduled reviews of IP inventory, which typically consists of comparing records of items and material listed in G-Army and other available documents (e.g., DD Form 1348’s, bills of lading) to the items and material which are physically present within IP.  The appellants bring any discrepancies to the attention of the customer, their supervisor, and/or other higher-graded SSD personnel and, when requested, help customers resolve discrepancies associated with ordered items and materials.

The appellants provide assistance to customers having difficulty accessing G-Army (e.g., lack the required G-Army training and/or certification, extended deployment) for the purpose of processing and recording the receipt of items and material held for them at the IP.  They also assist customers with identifying and resolving a variety of discrepancies (e.g., inconsistencies with physical inventory, warehouse refusals, transfer of material between accounts, location changes) by performing a review of G-Army records on behalf of the customer or by referring the customer’s issue to a higher-graded employee within SSD such as Supply Technicians, Supply Management Specialists, etc.

Our review also concluded the appellants spend approximately 60 percent of their time performing a variety of manual-labor tasks, such as, operating forklifts and hydraulic pallet jacks, distributing received items into bins and storage areas, physically lifting and moving items and material, etc.

Pay system determination

The agency classified the appellants’ position in the Supply Clerical and Technician Series, GS-2005, titling it Supply Technician.  However, the appellants assert their position should be classified in the FWS pay system because they perform a variety of “warehouse” duties including moving, storing, and issuing items and material; operating a forklift, hydraulic pallet jack, and hand truck, etc.  However, for the reasons discussed below, we find the appellants’ position is properly allocated to the GS.

Section 5102 of 5 U.S.C. requires that a pay category determination be made as the first step in the position classification process.

Section 5102(c)(7) exempts from the GS employees in recognized trades or crafts, or other skilled mechanical crafts, or unskilled, semiskilled, or skilled manual labor occupations, and other employees in positions having trade, craft, or laboring experience and knowledge as the paramount requirement. 

Section IV (A) (2) of the Introduction defines paramount requirement as the essential, prerequisite knowledge, skills, and abilities needed to perform the primary duty or responsibility for which the position has been established. Whether particular types of positions are trades, crafts, or manual labor occupations within the meaning of title 5 depends primarily on the most important requirement for the performance of a primary duty or responsibility for which the position exists.  If a position clearly requires trade, craft, or laboring experience and knowledge as a requirement for the performance of its primary duty, the position is under the FWS regardless of its organizational location or the nature of the activity in which it exists.  The Introduction goes on to say that "A position is exempt from the General Schedule if its primary duty involves the performance of physical work which requires knowledge or experience of a trade, craft, or manual labor nature," and that "A position is subject to the General Schedule, even if it requires physical work, if its primary duty requires knowledge or experience of an administrative, clerical, scientific, artistic, or technical nature not related to trade, craft, or manual labor work."

Section IV(B)(1) of the Introduction  states that in cases where the proper pay category cannot easily be determined by direct application of the law or by OPM classification standards and guidance, it is necessary to evaluate such factors as (a) the nature of work products or services of the organization, (b) working relationships with other positions in the organization, (c) normal lines of career progression, (d) equitable pay relationships with other positions in the immediate organization, and (e) management's intent or purpose in creating the position. If the analysis of the position points toward trade, craft, or manual-labor knowledge and experience as being of paramount importance in performing the primary duty of the position, it is proper to classify it under a prevailing rate system. If not, the position is subject to the General Schedule.

As previously stated, the appellants believe their position should be allocated to the FWS because they spend the majority of their time receiving, moving and storing items and materials; performing manual-labor (e.g., lifting, stacking); and operating forklifts, pallet jacks, and hand trucks.  However, pay category determinations are not based on the percentage of time spent performing certain types of work but is determined by the paramount knowledge requirement(s) to perform the primary duties of the job or position (5 U.S.C. 5102(c)(7)).  Therefore, in order to determine the pay category of the appellants’ work, we must first determine whether the position’s FWS work (i.e., warehouse/materials handler work) or its GS work (i.e., supply clerical support work) constitutes the primary duties of the position and identify the paramount knowledge and skills needed to perform that primary duty for which the job/position was established.

The Federal Wage System Job Grading Standard For Materials Handling, 6907, covers nonsupervisory FWS work involved in receiving, storing, and assembling for issue, shipment, and distribution, a wide variety of bin and bulk supplies, materials, equipment, and commodities using mechanized, automated, and manual material moving equipment, devices, and systems.  The work requires general knowledge of the methods used in processing, handling, and storing of materials and equipment through a supply facility; the ability to log receipt, storage, and shipment data; and the ability to use manual or mechanized equipment to move, stack, bin, and position materials and equipment.  The work also requires the ability to organize, arrange, and remove stock in storage areas in accordance with established procedures to prevent damage, deterioration, and loss.  Most work requires the incidental or regular use of fork lifts and motor vehicles.

The Position Classification Standard (PCS) for the Supply Clerical and Technician Series, GS-2005, includes GS positions involved in supervising or performing clerical or technical supply support work necessary to ensure the effective operation of ongoing supply activities.  It requires knowledge of supply operations and program requirements and the ability to apply established supply policies, day-to-day servicing techniques, regulations, or procedures.

The appellants’ position requires them to perform a variety of 6907 manual-labor duties and responsibilities including receiving customer-ordered items and materials from inside and outside JBLM LRC’s warehouse; using fork lifts, hydraulic pallet jacks, and hand trucks to unload and place items and materials in appropriate areas within the IP (e.g., customer-specific bins, secure storage); and ensuring the physical security of all items and materials within IP.  However, although these FWS duties take up a significant portion of the appellants’ work time, we find they are not the primary duties of the position nor do they reflect the paramount knowledge and skill needed to perform the primary duties (i.e., providing technical supply support as discussed below), which are directly related to the principal purpose of the IP.

The IP is a short-term holding area where thousands of individual pieces of inventory worth millions of dollars are processed, and recorded by the appellants each year.  The principal purpose of the appellants’ position is to ensure that each piece of inventory which enters and leaves the IP has been accounted.  As discussed in the “Position information” section of this decision, the appellants receive, secure, track, account for and store customer items, and perform periodic inventories to ensure electronic records accurately reflect items on-hand.  In order to perform these duties, the appellants apply knowledge of a variety of technical supply systems and processes used in the IP, IMB, and Stock Control Branch including current supply and administrative guidelines governing the agency’s supply operations; knowledge and skill in the use of the agency’s automated supply systems (e.g., G-Army) to account for, and report on, all items and materials entering and leaving the IP and ensuring proper inventory and security measures are carried out; knowledge of the facility and agency supply processes and procedures; and a working relationship with both internal and external organizations (e.g., JBLM 404th LRC’s warehouse, military contractors, warehouse managers, supply administrative personnel and freight company staff) sufficient to resolve a variety of discrepancies associated with customer-ordered items and materials such as inaccurate quantities, poor condition, and late deliveries.  In addition, both the appellants’ first and second-level supervisor certify that the technical supply support duties and responsibilities (i.e., GS-2005 work), performed by the appellants approximately 40 percent of the time, represent the primary purpose for the position and the paramount knowledge required when recruiting for the position.

Therefore, although the appellants perform manual-labor duties and responsibilities (i.e., FWS 6907 work) approximately 60 percent of the time, the FWS 6907 work is incidental to the GS-2005 work which represents the primary purpose of the position.

Decision

The appellants’ position is properly covered by the GS pay system.