Washington DC

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

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Damon B. Ford
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


04/29/2019

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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).
 
Introduction

The appellant’s position is currently classified as Supply Clerk, GS-2005-4, but he believes it should be classified at the GS-7 grade level.[1]   The position is assigned to the Mechanized Packing Branch (BE), Light Distribution Division (Division), Defense Logistics Agency (DLA) Distribution San Joaquin, California (DDJC), DLA, in Tracy, California.  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 initially filed a classification appeal with the Defense Civilian Personnel Advisory Service, U.S. Department of Defense.  Their May 3, 2018, decision determined the position was appropriately classified as Supply Clerk, GS-2005-4.  The appellant subsequently filed a classification appeal with the Office of Personnel Management (OPM).

The appellant mentions performing work we are unable to confirm by review of his official position description (PD) or interviews with his supervisors (e.g., conducting distribution studies, trend analysis, and oral briefings, and developing flow charts and formal reports).  The authority to assign work to positions is statutorily vested in agency management.  See 5 U.S.C. 302.  Therefore, agency decisions concerning the assignment of work are not reviewable under the classification appeals process and we will only consider duties officially assigned by management.

The appellant’s rationale for a higher grade is based, in part, on duties he no longer performs.  Under 5 U.S.C. 5112, we can only consider current duties and responsibilities in classifying positions.  Our analysis focuses on the current work assigned by management and performed by the appellant based on the entire record, including information obtained from telephone interviews with the appellant and supervisors.

The appellant compares his position to similar but higher graded positions within DLA.  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 standards 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 other positions, which may or may not be classified correctly, as a basis for deciding his appeal.

Like OPM, the appellant’s agency must classify positions based on comparison to OPM’s position classification standards (PCS) and guidelines.  The agency also has primary responsibility for ensuring that its positions are classified consistently with OPM appeal decisions.  If the appellant considers his position so similar to others that they all warrant the same classification, he may pursue the matter by writing to his agency’s human resources office.  In doing so, he should specify the precise organizational location, classification, duties and responsibilities of the positions in question.  If the positions are found to be basically the same as his, the agency must correct their classification to be consistent with this appeal decision.  Otherwise, the agency should explain to him the differences between his position and the others.  

The appellant mentions the volume of work he performs, as well as awards and letters of appreciation received due to the quality of his work.  However, volume and quality of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5)

Position information

As the Department of Defense’s primary distribution point to the Western United States, Pacific, and Indian Ocean regions, the DDJC provides what warfighters require by storing and stocking over 415,000 different stock numbers valued at over $7 billion dollars.  The DDJC is the second largest of DLA’s distribution centers.  Specifically, the appellant’s position is assigned to the BE and supervised directly by the Branch Chief, a WS-6901-9 Distribution Process Worker Supervisor position.

The appellant estimates spending 60 percent of his time on placing orders for supplies required to perform the work of Division staff and its branches including BE, Bin Selection, and Foreign Military Sales.  In total, the Division operates seven warehouses.  Typical supplies required include, but are not limited to, paper, envelopes, boxes, tape, labels, ribbon, pens, pencils, and plastic bags.  The appellant’s work requires maintaining adequate supply levels to prevent warehouse stoppages while avoiding an overflow in the limited space available for work supplies.  After conducting an inventory of their work supplies, warehouse leaders and supervisors complete the weekly inventory sheets forwarded to the appellant to generate supply order lists.  To track supplies being used, he maintains inventory spreadsheets with various fields including National Stock Number and unit of issue, quantity, pallets on hand, daily usage, status (e.g., ordered), minimum level, and maximum level.  Based on his experience, current inventory sheets generated by warehouse staff, and inventory spreadsheets, the appellant identifies the replenishment point and determines the supply orders, quantities, and scheduling.  To place an order, he selects the appropriate order form, completes it based on form instructions, and forwards it for review, approval, and signature to appropriate management officials.  All orders are then submitted to the Base Supply Section (BSS) of the DDJC’s Resource Management Group.  Prior to placing the order, BSS staff reviews all requests for adequacy and appropriateness.  The appellant tracks all supply orders, following up with any outstanding orders when necessary.

The appellant estimates spending the remaining 40 percent of his time on monitoring, searching, and locating open materiel release orders (MRO), i.e., the orders placed by warfighters and fulfilled by the Division and its branches.  After an order is placed by the warfighter, a ticket is issued in DLA’s Distribution Standard System (DSS), an automated information system managing all functional business processes of warehouse operations including receiving, storage, consolidation, packing, and shipping.  The appellant regularly pulls reports on open MROs (or open lines), focusing on lines that have stalled in DSS and are past due on delivery.  The appellant conducts searches for the open line, including reviewing screens in DSS to identify the last known location of the MRO.  He contacts warehouse supervisors to check possible locations in their staging area for the lost item.  If his search is unsuccessful, he coordinates with the Transportation Division of the DDJC’s Distribution and Specialized Missions Group for their further action.

The appellant and supervisor certified to the accuracy of the duties described in his official PD number H1U7258.  We find the PD is adequate for classification purposes, and incorporate it by reference into this decision.  To help decide this appeal, we conducted telephone audits with the appellant and a joint telephone interview with his first- and second-level supervisors.  In reaching our classification decision, we considered all information gained from these interviews, as well as the written information furnished by the appellant and his agency.

Series, title, and standard determination

The agency classified the appellant’s position in the Supply Clerical and Technician Series, GS-2005, titling it “Supply Clerk.”  The appellant does not disagree and, after careful review, we concur.  Positions in the GS-2005 series are evaluated by application of the grading criteria in the PCS.  Our evaluation by application of the criteria follows.  

Grade determination

The GS-2005 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 points assigned are converted to a grade level by use of a grade conversion table 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 the deficiency is balanced by an equally important aspect that meets a higher level.

The appellant only disagrees with the agency’s evaluation of Factor 2 (Supervisory Controls); Factor 3 (Guidelines), Factor 4 (Complexity), Factor 5 (Scope and Effect) and Factors 6 and 7 (Personal Contacts/Purpose of Contacts).  We have reviewed the agency’s crediting of Level 1-3 for Factor 1, Knowledge Required for the Position, Level 8-1 for Factor 8, Physical Demands, and Level 9-1 for Factor 9, Work Environment, and concur and have credited the position accordingly.  Therefore, our evaluation focuses on the factors contested by the appellant.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s level of independence and personal responsibility, and how the work is reviewed or controlled.

At Level 2-2, the work is performed under technical guidance of a supply technician, supply specialist, or supervisor who issues general work assignments, controls flow of day-to-day work, and explains major changes in regulations or procedures.  The supervisor or higher grade employee provides additional specific instructions for new, difficult, or unusual assignments including suggested work methods or advice on source material available.  The employee uses initiative in carrying out recurring assignments independently without specific instruction, but refers deviations, problems, and unfamiliar situations not covered by instructions to the supervisor or higher grade employee for decision or help.  The supervisor assures that finished work and methods used are technically accurate and in compliance with instructions or established procedures.  Review of the work increases with more difficult assignments if the employee has not previously performed similar assignments.

At Level 2-3, the supervisor makes assignments by defining objectives, priorities, and deadlines; and assists the employee with unusual situations which do not have clear precedents.  In some circumstances, the employee works independently from the supervisor or specialist in a remote location.  Contact with the supervisor is infrequent, although usually available by telephone and periodic on-site visits.  Continuing assignments are usually performed with considerable independence.  The employee plans and carries out the successive steps and handles problems and deviations in the work assignment in accordance with instructions, policies, previous training, or accepted practices in the occupation.  When the employee assists a supply specialist in performing segments of more complex technical operations, the work may be subject to closer technical guidance and control.  Completed work is usually evaluated for technical soundness, appropriateness, and conformity to policy and requirement.  The methods used in arriving at the end results are not usually reviewed in detail.

The appellant’s position fully meets Level 2-2.  He works under the technical guidance and supervision of the BE and Division Chiefs.  Although his immediate supervisor does not assign and control the flow of the appellant’s day-to-day work, his assignments are of a regular and recurring nature, e.g., ordering supplies and searching open lines.  He uses initiative in carrying out these assignments independently, and refers deviations, unfamiliar situations, and problems (e.g., late supply orders or unresolved open lines) to his supervisors, Transportation Division, BSS, or other employees.  His immediate supervisor walks through the supply area three to four times a week to ensure the adequacy of supply orders and also regularly monitors any influx in unresolved open lines.  Similar to Level 2-2, the supervisor reviews completed work for technical accuracy and compliance with instructions or established procedures.

The appellant’s position does not meet Level 2-3.  Because his work is assigned in terms of functional responsibilities rather than as individual assignments, he carries out the majority of his work independently, without supervisory assistance, in accordance with established laws, regulations, and policies.  His work (e.g., ordering supplies, researching vendors, and searching open lines) is routinely performed within the boundaries of the existing supply system and other established procedures.  His supervisor is not required to define his objectives, priorities, or deadlines as a result of the recurring nature of the appellant’s work.  Although the appellant performs his work with considerable independence, the routine nature of the work combined with the limits on his discretion imposed by the established procedures preclude him from planning and carrying out work and handling problems and deviations in work assignments characteristic of Level 2-3.  His first- and second-level supervisors maintain daily personal contact with the appellant by email, phone, or face-to-face.  Unlike Level 2-3, the supervisor must review and approve all supply order forms, and the appellant’s work is subjected to a more detailed review than for technical soundness, appropriateness, and conformity to policy and requirements.

Level 2-2 is credited for 125 points.

Factor 3, Guidelines

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

At Level 3-2, procedures for doing work have been established and a number of specific guidelines are available in the form of supply regulations, policies, and procedures.  The number and similarity of guidelines and work situations require the employee to use some judgment in locating and selecting the most appropriate guidelines, references, and procedures for application and in making minor deviations to adapt the guidelines in specific cases.  At this level, the employee may also determine which of several established alternatives to use.  Situations to which the existing guidelines cannot be applied, or significant proposed deviations from the guidelines are referred to the supervisor.

At Level 3-3, guidelines are similar to the next lower level but because of the problem solving or case nature of the assignments, they are not completely applicable or have gaps in specificity.  The employee uses judgment in interpreting and adapting guidelines such as policies, regulations, precedents, and work directions for application to specific cases or problems.  The employee analyzes the results of applying guidelines and recommends changes.

The appellant’s guidelines meet Level 3-2.  He follows established and specific guidelines when ordering supplies and searching open lines, including supply regulations, instructions, and policies; stock fund catalogs; desk guides; and instructions for processing open MROs.  Similar to Level 3-2, he uses judgment in locating and selecting appropriate guidelines for application.

The appellant’s guidelines do not meet Level 3-3.  Unlike this level, his guidelines are relatively clear cut and complete, and do not require interpretation or adaptation as described at Level 3-3.  DLA- and BSS-issued guidelines include various instructions and desk guides on completing general purchase card request, requirements justification for acquisition, and stock fund ordering forms depending on the purchase type; determining required approving officials; and searching and selecting products from portals such as FedMall and GSA Advantage.  When questions arise regarding interpretation of guidelines or policy changes, the appellant, through his supervisor, contacts BSS staff for clarification.  Other guidelines include instructions for processing open/unconfirmed MROs.  Unlike Level 3-3, he is not required to analyze the results of applying these guidelines or recommend changes to established guidelines.

Level 3-2 is credited for 125 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 4-2, work consists of duties that involve related steps, processes, or methods, including work such as performing routine aspects of technical supply management functions in support of a specialist.  The employee decides what to do by recognizing the existence of and differences between a few easily recognizable situations and conditions, and choosing a course of action from among options related to the specific assignment.  At Level 4-2, actions to be taken by the employee or responses to be made differ in such things as the source of information, the kind of transactions or entries, or other differences of a factual nature.

At Level 4-3, work involves unusually complicated or difficult technical duties involving one or more aspects of supply management or operations.  The work at this level is difficult because it involves actions that are not standardized or prescribed; deviations from established procedures; new or changing situations; or matters for which only general provision can be made in regulations or procedures.  This typically involves supply transactions which experienced employees at lower grades have been unable to process or resolve, or which involve special program requirements for urgent, critical shortage items requiring specialized procedures and efforts to obtain.  At Level 4-3, the employee decides what needs to be done depending on the analysis of the subject, phase, or issues involved in each assignment, and the chosen course of action may have to be selected from many alternatives.  Decisions are based largely on the employee’s experience, precedent actions, and the priority assigned for resolving the particular problem.  The methods and procedures used to resolve each issue vary based on the circumstances of each individual case.  The work involves conditions and elements that the employee must identify and analyze to discern interrelationships with other actions, related supply programs, and alternative approaches.

The appellant’s position meets Level 4-2.  Similar to this level, his duties involve related steps, processes, or methods that require he consider the differing procedures to follow for the task at hand, the information he has to give or obtain to perform the work, the objectives he is required to meet, and the actions necessary to accomplish the work.  His supply ordering work requires preparing appropriate order forms accurately and completely, filling out required fields including requestor’s name, make/model and unit of issue, quantity, unit price, total price, and justification.  Completed order forms are forwarded to management officials for review and approval.  Like Level 4-2, this and other work requires choosing a course of action that generally follows established procedures and instructions and only a few options are available for him to choose to resolve the problem or situation.

The appellant’s position does not meet Level 4-3.  In contrast to this level, he does not perform unusually complicated or difficult technical duties involving different and unrelated processes and methods.  His supply-related work requires making decisions based on historical data and other established procedures, for example, processing 4,000 lines a day requires a specific number of boxes on hand.  When resolving supply-related issues such as backordered items, he recommends alternative solutions (e.g., order similarly sized boxes) for the supervisor’s consideration.  The appellant also provides management with updates on the status of current orders and total dollars spent on supplies.  He must be able to apply various supply procedures, but such actions do not require him to understand the reasons behind the actions, consider alternative courses of actions to be selected from many alternatives, or identify and analyze interrelationships with other actions as expected at Level 4-3.  In addition, the appellant conducts open line searches for his Division and its branches, which process approximately 4,000 to 5,000 lines daily.  He reviews open MRO queries, noting the tickets flagged with particular material movement or status codes in DSS, for example, the P21 code showing item pick was completed and C31 code showing item arrived for pre-pack.  He contacts warehouse supervisors to check for missing or lost MROs in possible locations in their staging areas.  Occasionally, an item is shipped to a customer without it being scanned.  Customers are required to acknowledge receipt of MROs.  When conducting an open line search, the appellant checks Web Visual Logistics Information Processing System to confirm if the customer acknowledged MRO receipt.  If he determines an item was shipped, un-scanned, and received by the customer, he notifies the Transportation Department so the ticket may be closed out in DSS.  The appellant states he also checks the Enterprise Business System for the order date and other information concerning the initial order.  However, unlike Level 4-3, the preceding tasks and related work do not involve deviations from established procedures, situations that are new and changing, or matters covered by only general regulatory provisions.

Level 4-2 is credited for 75 points.

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work; i.e., the purpose, breadth, and depth of the assignments, and the effect of work products or services both within and outside the organization.

At Level 5-2, the work involves the execution of specific rules, regulations, or procedures and typically comprises a complete segment of an assignment or project of broader scope, such as when assisting a higher grade employee.  The work or supply service at Level 5-2 affects the accuracy, reliability, or acceptability of further processes or services in meeting customer requirements in supported organizations and other supply units.

At Level 5-3, work involves dealing with a variety of problem situations either independently or as part of a broader problem solving effort under the control of a specialist.  Problems encountered require extensive fact finding, review of information to coordinate requirements, and recommendations to resolve conditions or change procedures.  The employee performs the work in conformance with prescribed procedures and methods.  At Level 5-3, the results of the work affect the adequacy of local supply support operations, or they contribute to improved procedures in support of supply programs and operations.

The appellant’s position meets Level 5-2.  As at this level, his work and decisions require applying specific and established procedures, regulations, and processes comprising a complete segment of an assignment.  He maintains effective relationships with the organizations supported in addition to BSS, Transportation Division, and other DDJC staff to resolve supply- and open lines-related actions or discrepancies.  Similar to Level 5-2, the appellant’s work products and services directly affect the accuracy, reliability, and acceptability of work performed by personnel of serviced units.

The appellant’s position does not meet Level 5-3.  Although he is responsible for the full range of actions required to order supplies and search open lines, unlike this level he applies specific rules and procedures to his work tasks.  For example, he conducts product searches on FedMall, GSA Advantage, and other portals when a product is requested by staff.  Based on his search, he identifies product numbers, prices, descriptions, etc., forwarding the various options he identified to the requestor for selection.  Once a selection is made, the appellant completes the appropriate order form and forwards it for review and signature to management officials, who will if necessary forward it when additional approvals are required (e.g., from safety officials).  In addition, once he has exhausted his established search methods for locating open lines, he emails the Transportation Division for their further action.  The appellant’s responses to the typical problems he encounters are limited given that his actions are constrained by parameters established by the work processes and procedures; for example, management is delegated authority to approve all purchase actions and the tiered approach to resolving open lines requires forwarding more difficult issues to others for research and resolution.  His position thus does not regularly resolve the variety of problems or situations requiring extensive fact-finding, broad problem solving situations, and making of recommendations to resolve conditions or change procedures characteristic of Level 5-3.  Also unlike Level 5-3, the results of the appellant’s work do not affect the adequacy of local supply support (i.e., BSS) operations, nor does he contribute to improved procedures in support of supply programs and operations.

Level 5-2 is credited for 75 points.

Factors 6 and 7, Personal contacts and Purpose of contacts

Personal contacts include 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.  These factors are interdependent.  The same contacts selected for crediting Factor 6 must be used to evaluate Factor 7.  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.

    Personal contacts

At Level 2, contacts are with employees in the same agency but outside the immediate organization.  Persons contacted generally are engaged in different functions, missions, and kinds of work, such as representatives from various levels within the agency or from other operating offices in the immediate installation.

At Level 3, contacts are with individuals from outside the employing agency 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 and developed during the course of the contact).  Typical of contacts at this level are supply employees in other departments or agencies, inventory item managers, contractors, or manufacturers.

The appellant’s personal contacts meet Level 2 in that his contacts are with employees at the DDJC, both inside and outside his immediate organization.  His contacts are with persons engaged in different functions and kinds of work (e.g., supply, transportation, inventory, warehouse, and customer service) but are established in a structured setting.  

The appellant’s personal contacts do not meet Level 3.  While he has contact with individuals outside the agency (e.g., vendors), in contrast to Level 3 these contacts are highly structured in that they involve obtaining information about item availability, price, or product description.  These contacts do not meet Level 3 in that they do not occur in moderately unstructured settings where the purpose and extent of each contact is different and the role and authority of each party is identified and developed during the course of the contact.

    Purpose of contacts

The agency credited the appellant’s position at Level a, which describes the purpose of contacts as to obtain, clarify, or exchange facts or information ranging from easily understood to highly technical.  We find his contacts exceed the information sharing purposes described at Level a, and instead fully meets the description at Level b.  At Level b, the purpose of contacts is to plan, coordinate, or advise on work efforts or to resolve operating problems by clarifying discrepancies in information submitted by serviced organizations, resolving automated system problems causing erroneous transaction records, or seeking cooperation from others to resolve complicated supply actions.

Similar to Level b, the purpose of the appellant’s contacts is to plan, coordinate, or advise on work efforts.  For example, when BE staff reported complaints that the tape from a new vendor continually stuck in machines, the appellant worked with packing workers to determine that the weight and size differences of the new tape was incompatible with the calibration of the machines.  While keeping his supervisors informed, the appellant contacted the supply specialist at BSS to advise on this and other product issues and recommend resolutions (e.g., purchase tape from previous vendor while resolving problems with the product from the new vendor).  In addition, if there is a backorder on an item critical to the work of the Division and its branches, he will contact other warehouse operations at the DJCC to make arrangements to “borrow” an item.  When researching open lines, he regularly coordinates with warehouse operations staff to locate misplaced or forgotten MROs.  After identifying the last known location of an item, the appellant advises warehouse supervisors and leaders to check areas for overages.  If unable to resolve the ticket, he coordinates with Transportation Division staff by identifying the efforts he took to locate the item so that staff can continue without duplicating the same search efforts.  After elevating unresolved MROs to others for resolution, he continues monitoring and following up, when necessary, on tickets to ensure they are subsequently resolved and closed out.  Therefore, the purpose of the appellant’s contacts regularly involves planning, coordinating, or advising on work efforts as described at Level b.
By application of the point conversion chart in the PCS for Factors 6 and 7, the combined factors are evaluated at Level 2b and 75 points are credited.

Summary
Factors	Level	Points
Knowledge Required	1-3	350
Supervisory Controls	2-2	125
Guidelines	3-2	125
Complexity	4-2	75
Scope and Effect	5-2	75
Personal Contacts and Purpose of Contacts	2-b	75
Physical Demands	8-1	5
Work  Environment	9-1	5
Total		835

This point total falls within the GS-4 range (655-850) on the grade conversion table provided in the GS-2005 PCS.

Decision

The appellant’s position is properly classified as Supply Clerk, GS-2005-4.

[1] Although he identified the GS-2030 Distribution Facilities and Storage Management Series as the requested classification in his appeal request, the appellant stated during his telephone audit with OPM that, because agency management subsequently removed duties he had been performing from his position, he does not disagree with the classification of his position to the GS-2005 series.

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