Washington, DC

U.S. Office of Personnel Management
Job Grading Appeal Decision
Under section 5346 of title 5, United States Code

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


09/01/2023

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Date

Finality of Decision

As provided in section S7-8 of the Operating Manual: Federal Wage System, this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. There is no right of further appeal. This decision is subject to discretionary review only under conditions specified in section 532.705(f) of title 5, Code of Federal Regulations (addresses provided in the Introduction to the Position Classification Standards, appendix 4, section H).

Introduction

The appellant’s job is currently graded as Aircraft Electrician, WG-2892-10, but he believes it should be graded at the WG-11 level based on application of the Federal Wage System (FWS) Job Grading Standard (JGS) for Inspectors and titled Aircraft Electrician Inspector. The appellant works in the Electrical Environmental Repair Section (Section), Accessories Flight, 3^rd Maintenance Squadron, Joint Base Elmendorf-Richardson (JBER), Pacific Air Forces, in Anchorage, Alaska. We have accepted and decided this appeal under section 5346 of title 5, United States Code.

Job Information

Both the appellant and his supervisor have certified to the accuracy of the appellant’s Standard Core Personnel Document (SCPD) number 9M9W210. The appellant’s Section is comprised of approximately 12 aircraft electricians including two civilian, WG-2892-10, jobs and 10 slots designated for active-duty military personnel. The Section is overseen by the Noncommissioned Officer in Charge, i.e., a Technical Sergeant and the appellant’s first-level supervisor.

The Section’s aircraft electricians work primarily on C-17s, in addition to repairing, charging, and inspecting aircraft batteries on E-3s. The Section is responsible for conducting a Home Station Check (HSC) of the electrical and environmental systems and components on C-17s. The JBER’s eight C-17s undergo HSCs, which are isochronal inspections of aircraft based on flying hour utilization rates, every 180 days. Every aircraft is scheduled for a different 180-day timeframe, and the staggered inspections allow for the identification and repair of discrepancies to allow planes to always be prepared to fly. The assessments are divided into four types, where HSC 1 is considered the most comprehensive and extensive check and involves approximately 54 different work inspections to verify the integrity of the aircraft’s electrical and environmental systems and components. The Section’s work leader distributes work assignments to the aircraft electricians. The appellant works independently to troubleshoot, modify, repair, inspect, and test electronic, electrical, pneumatic, and mechanical functions of systems, components, accessories, and support equipment. He is responsible for on- and off-equipment electrical and environmental systems maintenance. For example, the appellant performs maintenance, testing, and troubleshooting work on the liquid oxygen, gaseous oxygen, and gaseous nitrogen servicing carts. He also ensures aircraft and equipment forms are properly documented.

The appellant is certified to perform an In Progress Inspection (IPI), which is an inspection at a critical point in the installation, assembly, or reassembly of a system, subsystem, or component. As authorized by Technical Order 00-20-1, Technical Manual: Aerospace Equipment Maintenance Inspection, Documentation, Policies, and Procedures, IPIs are to be accomplished by an IPI inspector other than the technician performing the task. In addition, the appellant is certified to clear Red X discrepancies, which represent the most serious possible condition and indicates the aerospace vehicle is considered unsafe or unserviceable and cannot be flown or used until the unsatisfactory condition is corrected or cleared. When a Red X symbol is used on maintenance documents to notate a serious condition, only maintenance personnel, like the appellant, are authorized to clear a Red X condition after inspecting the work performed and validating that all related discrepancies are resolved and accurate.

In reaching our job grading decision, we have carefully reviewed all information furnished by the appellant and his agency, including the SCPD which we find to be sufficient for purposes of describing the work performed and have incorporated it by reference into this decision. To help decide this appeal, we conducted a telephone audit with the appellant and telephone interview with his immediate supervisor.

Occupational code, title, and standard determination

The agency classified the appellant’s job as Aircraft Electrician, WG-2892, and graded his work using the FWS JGS for Aircraft Electrician, 2892. While the appellant believes that the title “Inspector” should be added to the prescribed Aircraft Electrician title, he agrees with assignment of the 2892 occupational code. We concur with the agency on its selection of the 2892 occupational code. The 2892 JGS contains appropriate titling and grading criteria which we have applied to the appellant’s job later in this decision.

The appellant asserts that the inspections work he performs should be graded at the WG-11 level based on application of the JGS for Inspectors. All aspects of the job grading criteria must be fully met for jobs to be evaluated under the JGS for Inspectors. Appropriate application of the JGS requires full and careful analysis of all relevant factors. The JGS for Inspectors indicates it is used to grade nonsupervisory jobs that involve examining services, materials, and products that are processed, manufactured, or repaired by workers performing trade or craft work to determine that the physical and operating characteristics are within acceptable standards, specifications, or contractual requirements. Under a formal inspection program, FWS inspectors typically perform several different categories of inspections. Characteristic of the appellant’s work, inspectors performing quality verification inspections evaluate maintenance procedures, processes, or products to determine if they are being accomplished in accordance with standards, codes, technical orders, work specifications, drawings, and work control documents.

Prior to appealing to the Office of Personnel Management (OPM) the appellant filed a classification appeal with the Defense Civilian Personnel Advisory Service (DCPAS) of the Department of Defense. In its January 5, 2022, classification appeal decision DCPAS determined the appellant’s inspections work was excluded from coverage by the JGS for Inspectors. The agency explains that WG-10 aircraft electricians throughout the Department of the Air Force perform IPIs as a routine responsibility but that such work generally constitutes a small portion of an employee’s overall responsibilities. In addition to asserting that “[a]pplication of the Inspector JGS to positions in this type of scenario would have the illogical result of all positions being classified as “Inspectors,” the decision further states:

The [OPM] has addressed this issue in their Appeal Decision C-2892-10-01: “Red X inspections (severe problem) that can endanger flights are signed by equivalent Air Reserve Technicians in the same occupation. Although the appellant may check the work of other WG-10’s, the knowledges and skills required to perform this work do not differ substantially from those described at the WG-10 level. The appellant’s supervisor is available when needed. This responsibility does not warrant grading the position above the WG-10 level.”

The JGS for Inspectors provides a means to establish an appropriate pay relationship between the trade, craft, or laboring work performed and the difficulty and responsibility of the inspections function. We note FWS inspections work is addressed in OPM’s Digest of Significant Classification Decisions and Opinions, Number 21-08, June 1998. The Digest article amplifies the intent of the list of jobs in various occupational codes in the JGS for Inspectors Part II, Examples of Job Descriptions, which are representative of the additional demands placed on inspectors who inspect trades work products. These examples illustrate the additional knowledge and trade skills needed to inspect and correct trades and crafts work where that work does not meet the presecribed quality standards required in trade occupations.  We conclude that application of the JGS for Inspectors is necessary if it provides a means to establish a proper pay relationship to evaluate inspections work in the event that such a pay relationship cannot be established by application of the relevant trade standard. In other words, the JGS for Inspectors could be applied to the appellant’s job if its application identifies higher level knowedges, skills, and responsibilities thus yielding a higher grade level than that provided for by evaluation of the 2892 JGS.

As an inspector, the appellant validates and guarantees the work performed by other Section workers. Such work is part of a quality control system requiring the cross-check of work for critical repairs performed by his peers to ensure proper completion of work. Although he certifies the work of others, the knowledge, skills, and abilities required (including measurement standards, devices, and tools used) to perform this work requirement do not differ substantially from those required when he is performing his own checkout work to certify that he has completed his own tasks properly. We note the 2892 JGS describes the following responsibility, which we find analagous to the appellant’s inspections-related duties:

Grade 10 Aircraft electricans may be required to “sign off” or “self certify” that they have completed their work assignments properly and in accordance with specific engineering or technical specifications. They also are responsible for providing technical assistance to lower graded workers.

Because we find the appellant’s inspection duties similar to work described at the Grade 10 level by the 2892 JGS, application of the JGS for Inspectors would be appropriate if its use resulted in a grade higher than the WG-10 level. Therefore, our analysis by application of the JGS for Inspectors follows.

In his request to OPM, the appellant asserts his inspections work should be graded at the WG-11 level based on application of the JGS for Inspectors. He states his work should be credited as follows: Situation B for Factor 1 (Situation), Level 2 for Factor 2 (Responsibility), and Degree C for Factor 3 (Skill and Knowledge). Although we do not disagree with the appellant’s evaluation of Factors 1 and 2, our review determined a different level for Factor 3. To fully address the appellant’s concerns regarding his inspections work, we provide our evaluation of Factor 3. This factor determines the skill and knowledge needed to inspect in relation to the complexity of the product inspected and the nature and variety of inspection techniques that are applied. The JGS for Inspectors instructs that Factor 3 is used according to the situation previously selected in Factor 1. Therefore, in the appellant’s case because Situation B is selected under Factor 1, Situation B is utilized under Factor 3 to determine the appropriate degree level of the appellant’s skill and knowledge as follows:

At Degree B, inspectors apply a variety of difficult techniques to examine complicated and interconnecting components such as engines, transmissions, carburetors, and ignition systems, and machinery that are manufactured or repaired to close tolerances and rigid specifications, using standard inspection and measuring devices such as feeler gauges, micrometers, circuit testers, dwell meters, and a variety of dial indicators.

At Degree C, inspectors apply a wide variety of complex inspection techniques to examine complete assemblies such as general purpose vehicles, ordnance and heavy artillery, aircraft and ship assemblies, and other mechanical equipment using special inspection and measuring devices such as chassis dynamometers, torque wrenches, surface finish analyzers, audio tube testers, oscilloscopes, calipers, and screw-pitch gauges.

We find the appellant’s inspections work comparable to Degree B. The JBER Commander delegated him with the responsibility to perform IPIs and clear Red X discrepancies. As a certified inspector, the appellant performs inspections on work performed by the Section’s aircraft electricians, who work on automatic flight controls, landing gear, antiskid, ignition, stall warning, power distribution, etc. Prior to conducting inspections work, the appellant reviews aircraft and equipment forms and other documents to ensure information is current, accurate, and complete. When conducting an IPI, e.g., of a battery installation, he verifies that parts and equipment are correct, as well as observes work to ensure the battery is installed properly and electrical lines are inputted into the device correctly. To perform inspections work, the appellant uses tools and equipment including hand and electrical test units, e.g., meters, bridges, meggers, harness testers, breakout boxes, test benches, signal generators, oscilloscopes, timing devices, calibrators, CO2 pumps, vacuum pumps, purge units, multiple function analyzers, and computerized multiple circuit analyzing equipment. He takes any necessary action if he identifies a discrepancy with the component, equipment, parts, safety, protocol, or process. The duration for completing IPIs and clearing Red X discrepancies varies from a couple minutes to hours depending on the task. The appellant ensures completion of IPIs and clearance of Red X discrepancies are properly documented. We find the appellant’s inspections work characteristic of Degree B, where inspections work involves a variety of difficult techniques to examine complicated and interconnecting components, using standard inspection and measuring devices.

The appellant’s inspections work does not meet Degree C. He completes IPIs and clears Red X discrepancies for specific tasks performed by the Section’s aircraft electricians. To perform such work, the primary inspection technique employed by the appellant is visual, standing closely to the work being performed and observing with a flashlight as electricity is powered off on the aircraft for safety reasons. Once work is completed on the aircraft by the Section (and other shops), a final acceptance inspection is performed by leadership of the 3rd Maintenance Squadron. Those inspectors conduct a document review and final operational inspection to certify that the aircraft is in either satisfactory or unsatisfactory operating condition. Unlike Degree C, we find no evidence the appellant employs a wide variety of complex inspection techniques or that he examines complete assemblies, instead of specific tasks, as expected at this level.

Based on our review of the grading criteria in the JGS for Inspectors, we determine the appellant’s inspections work is credited at Situation B for Factor 1, Level 2 for Factor 2, and Degree B of Situation B for Factor 3. According to the Grade Determination Charts in the JGS for Inspectors, the intersection point for that factor-level combination is the Grade 10 level. As previously discussed, we found the appellant’s inspections work similar to work described at the Grade 10 level by the 2892 JGS. As a result, because higher level knowledge and skills are not required, application of the JGS for Inspectors is unnecessary as its use does not yield a higher grade level than that provided for by the 2892 JGS. Furthermore, the apellant’s supervisor stated the appellant currently spends approximately 8 to 10 hours a week on performing inspections-related work. However, when the Section’s other recently-hired civilian WG-10 Aircraft Electrician is also certified to perform IPIs and clear Red X discrepancies, we anticipate the percentage of time spent by the appellant on inspections-related work to decrease as it becomes a shared responsibility. The outcome of applying the JGS for Inspectors to the appellant’s job would thus result in directing a change to job title that, by essentially highlighting a minor duty, would not communicate a meaningful description of the work performed nor reflect special knowledge and skills required to perform the work.

We find the proper occupational code and title for the appellant’s job is Aircraft Electrician, WG-2892. As previously noted, to evaluate the grade of the appellant’s job we have applied the job grading criteria in the 2892 JGS.

Grade determination

The 2892 JGS uses four factors to evaluate the proper grade of a job: Skill and Knowledge, Responsibility, Physical Effort, and Working Conditions. A job is graded as a whole against the level of demands found at different grades. As stated in the Introduction to the Federal Wage System Job Grading System, Section II, C,2.

1. “No one factor should be considered by itself. Care should be taken to avoid any tendency to overgrade a job on the basis of a predominant characteristic, or to undergrade it because it does not contain a particular element. Rather, all pertinent job facts related to the four factors should be analyzed including the possible relationships among the different elements of the job.” Thus, a job is allocated to the grade best representing the overall demands of the work.

The agency credited the appellant’s job at the Grade 10 level based on application of the 2892 JGS. The appellant does not disagree with the grade assigned by the agency based on its evaluation of the 2892 JGS, but we nonetheless briefly address his work below.

Skill and Knowledge

Grade 10 aircraft electricians apply a comprehensive knowledge of electrical theory, principles, and circuitry; a thorough knowledge of aircraft electrical systems and their interrelationships; and a working knowledge of electronic principles in order to troubleshoot, modify, repair, overhaul, and maintain complex electrical systems on fixed and rotary wing aircraft. They must apply a thorough knowledge of the interface of electrical systems with hydraulic, electronic armament, instrument, and mechanical systems and assemblies. Grade 10 aircraft electricians exercise skill, not only in testing, troubleshooting, analyzing, modifying, and repairing complex electrical systems and components, but also in tracing hard to locate and intermittent electrical defects and problems. They are skilled in wiring to facilitate the installation of conventional and nonconventional equipment, and in the assembly of a variety of locally developed test devices, utilizing switches, diodes, resistors, and other similar components. Grade 10 aircraft electricians apply skill in performing initial and final functional and operational checks on the entire aircraft electrical system. They must be able to assist engineering personnel in developing modifications and changes on electrical, electronic, instrument, and other integrated electrical systems. Skill is exercised in the setup and operation of computerized multiple circuit analyzing equipment in running existing and new diagnostic programs and must be able to work with or assist programming personnel in developing, debugging, or modifying such programs.

The skill and knowledge required by the appellant’s job matches that described at the Grade 10 level. He applies such skill and knowledge to troubleshoot, modify, repair, inspect, and test complex electronic, electrical, pneumatic, and mechanical functions of systems, components, accessories, and support equipment. He completes HSC assessments of the electrical and environmental systems and components of C-17s, and maintains and repairs liquid oxygen, gaseous oxygen, and gaseous nitrogen servicing carts and returns them to serviceable status. The appellant also repairs, charges, and inspects C-17 and E-3 aircraft batteries. To perform his work, he sets up and operates computerized multiple circuit analyzing equipment to run established and new diagnostic programs in various modes to test aircraft electrical circuitry and interconnecting cabling of the entire aircraft or individual system (e.g., radar, flight control, and navigational). He assembles a variety of test devices utilizing switches, diodes, resistors, relays, terminal boards, and other components. He calibrates and adjusts components such as amplifiers, proximity boxes, generators, and voltage regulators. He analyzes and interprets test symptoms given by test equipment, identifies the problem, and uses judgment to initiate proper corrective action. Similar to the Grade 10 level, the appellant performs functional and operational checks on the entire aircraft electrical systems, components, and accessories. Also at this level, he will assist programming personnel when necessary to develop, debug, or modify diagnostic programs by recommending changes and identifying contradictions between technical guides and test programs. The skill and knowledge required by the appellant’s job fully meets but does not exceed the Grade 10 level.

Responsibility

Grade 10 aircraft electricians receive work assignments from the supervisor in the form of written or oral instructions. Blueprints, schematics, or technical data may occasionally be incomplete or absent. Grade 10 aircraft electricians make independent decisions and judgments regarding troubleshooting techniques, modification, and repair procedures. They plan the sequence in which the work will be accomplished, select tools, and carry out all work assignments in accordance with technical and engineering specifications, and complete assignments using a variety of electrical processes and techniques. They determine the extent and nature of repairs necessary to correct electrical faults in the aircraft electrical system. Work at this level includes primary responsibility for checking out the complete aircraft wiring system and connections, and ensuring that all settings, calibrations, functional and operational checks are within specifications and conform to specific ranges and characteristics. The supervisor or a higher-graded worker is usually available to provide technical assistance on unusual or difficult problems relating to deviations from standard work practices. Grade 10 aircraft electricians may be required to “sign off” or “self certify” that they have completed their work assignments properly and in accordance with specific engineering or technical specifications. They are also responsible for providing technical assistance to lower graded workers.

The appellant’s job responsibilities meet but do not exceed the Grade 10 level. Similar to this level, he receives assignments from his work leader or supervisor either orally or in writing, along with necessary wiring diagrams, blueprints, technical manuals, etc. He independently troubleshoots problems and performs repairs, determining the extent and nature of repairs necessary to correct electrical faults in the aircraft electrical system. The appellant checks out the complete aircraft wiring system and connections, and ensures that all settings, calibrations, and functional and operational checks are within specifications and conform to specific ranges and characteristics. Equivalent to the Grade 10 level, he certifies the work of other aircraft electricians and provides technical assistance to others when necessary. He also provides on-the-job training to other aircraft electricians, providing instruction on techniques and procedures for aircraft electrical system repairs, battery shop operations, component repairs, etc.

Physical Effort

At the Grade 10 level physical effort is the same as that described at the Grade 8 level. Similar to that level, the appellant is frequently required to climb up and down ladders, stands, work platforms, scaffolding, and aircraft structures while making repairs or installations. His work requires long periods of standing and considerable kneeling, bending, stooping, and stretching. His work frequently requires making repairs or installations in hard-to-reach places requiring awkward and strained positions. The appellant’s work also requires lifting and carrying electrical lines, aircraft batteries, and other components weighing up to 20 pounds unassisted and 50 pounds with assistance from others.

Working Conditions

At the Grade 10 level working conditions are the same as those described at the Grade 8 level. Similar to that level, the appellant is subject to drafts, noise, and varying temperatures in hangars. He is exposed to dust, dirt, grease, oil, fumes, solvents, and other aircraft fluids while working on aircraft in various stages of repair or modification. The appellant is also exposed to the possibility of abrasions, cuts, burns, electrical shock, skin and eye irritation, and falls from elevated work areas.

Summary

By application of the four job grading factors in the 2892 JGS, the appellant’s job is graded at the WG-10 level. Because his job fully meets but does not exceed the Grade 10 level, the highest level described by the JGS, it is neither necessary nor appropriate to compare his job to other, higher graded standards.

Decision

The appellant’s job is properly graded as Aircraft Electrician, WG-2892-10.

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