Washington, DC

U.S. Office of Personnel Management
Job Grading Appeal Decision
Under sections 5103 and 5346(c) of title 5, United States Code

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Linda Kazinetz
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


04/10/2017

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Date

Introduction

The appellant’s job is currently graded as Housekeeping Aid, WG-3566-2.  However, he believes his working conditions, physical effort, and exposure to hazards warrant grading the job at the WG-3 level.  The appellant works in the Housekeeping Section, Environmental Management Service (EMS), Veterans Affairs (VA) Puget Sound Healthcare System, Veterans Health Administration, U.S. Department of Veterans Affairs, in Seattle, Washington.  We have accepted and decided this appeal under section 5346 of title 5, United States Code (U.S.C.). 

General issues

The appellant makes various statements about the timeliness and accuracy of his agency’s evaluation of his job, and compares his duties to other higher-graded Housekeeping Aid jobs at both his and other VA medical centers.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his job.  By law, we must make that decision solely by comparing his current duties and responsibilities to the appropriate Job Grading Standards (JGS) (5 U.S.C. 5346) and have considered the appellant’s statements only insofar as they are relevant to making that comparison.  Since comparison to JGSs is the exclusive method for grading jobs, we cannot compare the appellant’s job to others that may or may not be properly classified as a basis for deciding his appeal.  Because our decision sets aside all previous agency decisions, the appellant’s concerns regarding his agency’s job grading review process are not germane to this decision. 

Like OPM, the appellant’s agency must grade jobs based on comparison to OPM standards and guidelines.  However, the agency also has primary responsibility for ensuring that its jobs are graded consistently with OPM appeal decisions.  Information received from the appellant and his agency show that jobs at his medical center and others may be classified inconsistently with the appellant’s job.  Therefore, we have asked the agency to give us an intra-agency classification consistency report.  In making its report, the agency will review jobs that are identical, similar, or related to the appellant’s to ensure that they are classified consistently with this appeal decision.  The Introduction to the Position Classification Standards, Appendix 4, Section I, provides more information about such reports.  We have asked the agency to inform the appellant of the results of its consistency review.    

Although the appellant’s supervisors certified to the accuracy of the appellant’s standard job description (JD), number 40861-A, the appellant believes the JD is inaccurate because it fails to adequately address all his duties in cleaning the operating rooms, and the physical effort and hazardous working conditions associated with his job.  A JD is the official record of the major duties and responsibilities assigned to a position by a responsible management official with authority to assign work to a position.  A job is the duties and responsibilities that make up the work performed by an employee.  Job grading appeal regulations permit OPM to investigate or audit a job and decide an appeal on the basis of the actual duties and responsibilities assigned by management and performed by the employee.  An OPM appeal decision grades a real operating job and not simply the JD.  Therefore, this decision is based on the actual work assigned to and performed by the appellant and sets aside any previous agency decision. 

The appellant believes that his handling of bio-hazardous soiled materials (e.g., linens, towels, wipes) warrants a higher grade.  When employees are exposed to conditions of an unusually hazardous nature, they may be eligible for compensation by means of environmental pay differentials (5 U.S.C 5343(c)(4)) rather than job grading.  The employing agency determines whether an employee’s work exposure meets the requirements for awarding an environmental pay differential, so such matters are beyond the scope of the job grading appeals process. 

Job information

Under general supervision, the appellant is primarily assigned to clean, sanitize, and disinfect the Operating Room Suite at the VA Puget Sound Health Care System medical center.  The suite consists of eight operating rooms (OR) and a number of other rooms including offices, cytology clinic, procedure rooms, locker rooms, restrooms, equipment and supply storage areas, an employee lounge, hallways, and housekeeping closets.  During his regular shift (3:30 p.m. to midnight) he performs both “turnover” and “terminal” cleaning of the ORs and general cleaning of the other rooms.  Turnover cleaning is done between surgical procedures and takes about fifteen minutes to disinfect and wipe down principal areas and equipment in an OR.  Terminal cleaning is done when an OR is no longer being used for the evening and consists of a two and one-half hour detailed cleaning of the ceiling, walls, light fixtures, medical equipment, and floors.  Using primarily two pre-mixed liquid disinfecting cleaners (23L and bleach), the appellant wipes down ceilings, walls, equipment (e.g., surgical table and its components, X-ray machines, lighting fixtures), scrubs the floor using a heavy-duty power scrubber/buffer, and vacuums all the disinfecting cleaning solution off the floor with a water vacuum.  He collects all trash, removes and bags up all bio-hazard items (e.g., soiled cleaning cloths, towels, and linens) for contractor pickup, and assembles regular laundry for cleaning at the installation’s laundry.  He disposes of contaminated cleaning solutions from the wet vacuum and bodily fluids suctioned from patients during surgery, which are collected in the OR’s Durnoch suctioning machine.  Liquid contaminants are disposed of directly into the hospital sewer line.  Using a magnet, he occasionally collects any “sharps” such as needles and places them in the OR sharps container.  He also thoroughly and regularly cleans the other rooms of the OR suite listed above using the same disinfectants for the OR. 

In performing his work the appellant also uses mops, brooms, buckets, and disposable wipes and rags.  He moves carts, trash bins, and equipment on wheels.  In doing his work, he is required to wear scrubs, latex gloves, and a hair bonnet, and may wear a gown, dust mask, and eye protection as needed.  The appellant carries out his cleaning in accordance with agency and local installation instructions, e.g., Environmental Services Procedure Guide, hospital standard operating procedures (SOPs), and work checklists.  The appellant receives only general supervision during the course of his work, although the supervisor does a daily check each night on the quality of work. 

In reaching our decision, we carefully reviewed all information provided by the appellant and his agency including his official JD, which is incorporated by reference into this decision.  In addition, to help decide the appeal, we conducted separate telephone interviews with the appellant, his immediate supervisor, and the General Foreman of EMS.  

Occupation, title, and standard determination

The agency allocated the appellant’s job to the Custodial Working series, 3566, titling it Housekeeping Aid, which was approved by OPM for use in the VA on November 26, 1968, and the appellant does not disagree.  We concur with the agency’s title and series determination.  Jobs classified in the 3566 series are evaluated by reference to the Job Grading Standard (JGS) for Custodial Working.  The 3566 JGS uses four factors to establish the grade of jobs:  Skill and Knowledge, Responsibility, Physical Effort, and Working Conditions.  As discussed in the Introduction to the Federal Wage System Job Grading System, grading involves consideration of the total job to determine the most appropriate grade level, rather than a mechanical addition of individual factor judgments.  No one factor should be considered by itself, and all pertinent job facts related to the four factors should be analyzed including the possible relationships among the different elements of the job. 

Grade determination

The 3566 JGS describes work at the Grade 1 and 2 levels.  Grade 1 custodial workers clean offices, storerooms, corridors, stairways, hospital rooms and wards, and restrooms.  They mop, dust, and wax floors, empty trash, and sometimes operate lightweight floor scrubbers.  In addition to Grade 1 work, the JGS describes two work situations at the Grade 2 level (the highest grade described in the standard) which, when jointly considered, address most duties of the appellant’s job.  In Situation Number 1, the employee scrubs and strips floors with heavy (industrial-type) powered scrubbers and buffers; washes walls, vacuums floors, and adjusts machines, changing brushes, and other attachments.  The custodial worker washes ceiling fixtures using ladders to reach high surfaces and moves heavy furniture, supplies, and equipment.  In Situation Number 2, the employee does the full range of cleaning duties in an assigned area (building, hospital ward, etc.), following general instructions on the work to be done.  The custodial worker uses various preparations to clean and maintain linoleum, wood, marble, and various kinds of floors, walls, and ceiling surfaces.  The employee removes stains from a variety of surfaces, using chemical and cleaning solutions.  He/she occasionally works on ladders and scaffolds to change light bulbs, replace blinds, wash walls, etc., and runs powered cleaning equipment, cleans and oils it, and changes brushes and accessories.  The relevant factor levels as appropriate covering Grade 1 work, and those addressed under the two Grade 2 situations described above in the 3566 JGS, are compared below to the appellant’s job. 

Factor 1, Skill and Knowledge

This factor covers the nature and level of skill, knowledge, and mental application required in performing assigned work.

Grade 1 custodial workers need basic abilities and knowledge generally requiring no job training, but the ability to follow oral and written instructions and to lift and move lightweight objects.  They use common cleaning tools and lightweight vacuum cleaners, and sometimes powered buffers.  Assignments include sweeping, mopping, and scrubbing floors; washing walls, windows, and blinds; changing linens and collecting soiled linens and placing them at a pickup point; and cleaning and deodorizing lavatories, urinals, and toilet bowls.

Situation Number 1 describes Grade 2 skill and knowledge (in addition to that described at Grade 1) as requiring the physical ability to handle and control heavy powered equipment and do minor maintenance on it.  Situation Number2 describes Grade 2 custodial workers who work alone and must have skill and knowledge to do all cleaning duties on their own without instruction.  They must know the proper uses of a variety of special cleaning and sanitizing solutions, and must be able to remove different kinds of stains from a wide variety of surfaces.  In addition, they must be able to clean and make adjustments to powered cleaning equipment. 

In addition to meeting the full range of tasks, skill, and knowledge described at the Grade 1 level where the custodial worker uses basic abilities to clean areas using common tools (e.g., mops, brooms, lightweight vacuums), the appellant fully meets but does not exceed the Grade 2 level for this factor.  He applies skill and knowledge to handle and control heavy power equipment such as scrubbers, buffers, and water vacuums to clean operating room floors, and carries out all cleaning duties without supervisory instruction.  He cleans the OR suite from “top-to-bottom” including ceilings and light fixtures, walls, doors, frames and jams, heating and cooling vent cover plates, operating tables and their components, arm boards, IV poles, storage cabinets, exteriors of machinery, linen and trash hamper frames, wheeled carts, power outlet face plates, desks and chairs, power extension cords, and all flooring.  Like the Grade 2 level, in cleaning the OR suite the appellant must know how and when to use special cleaning and sanitizing pre-mixed solutions (e.g., general disinfectant 23-L, diluted bleach, alcohol) to wipe down all surfaces, and scrub and buff floors using a power scrubber.  Using prescribed disinfectants, he removes different kinds of stains (e.g., blood, urine, and other bodily fluids) from a variety of operating room surfaces, and uses, cleans, and adjusts powered cleaning equipment and attachments as necessary. 

This factor is evaluated at Grade 2.

Factor 2, Responsibility

This factor covers the nature and degree of responsibility involved in performing work.

Grade 2 custodial workers use heavy equipment safely, and those assigned to particular areas receive only general supervision and instructions on what is to be done. 

The appellant’s level of responsibility meets but does not exceed the Grade 2 level.  Like this level, he independently performs the full range of cleaning tasks with only general instructions on what is to be done.  However, per hospital procedures his work is inspected as part of a daily general inspection of the OR suite. 

This factor is evaluated at Grade 2.

Factor 3, Physical Effort

This factor covers the physical effort exerted in performing assigned work.

As described in Situation 1, Grade 2 custodial workers move and control heavy equipment, and carry, set up, and work from ladders and scaffolding.  They frequently lift and move objects weighing about 18 kilograms (40 pounds), and occasionally objects weighing over 23 kilograms (50 pounds).  As addressed in Situation 2, Grade 2 custodial workers occasionally exert moderately heavy physical effort in moving, setting up, and working from ladders and scaffolds.  Use of heavy powered cleaning equipment (industrial type buffers) is required, but not on a continual basis. 

The appellant’s overall physical effort fully meets but does not exceed the Grade 2 situations for this factor.  In cleaning the OR, he regularly moves and controls heavy powered cleaning equipment (i.e., scrubbers/ buffers) and moves and sets up ladders to clean ceilings and walls.  He frequently moves objects such as bags full of soiled linens, towels, rags, and bio-hazardous materials weighing from 25 to 40 pounds, and occasionally weighing up to 50 pounds.  Although the appellant states he lifts bags of soiled materials weighing up to 80 pounds, his supervisors indicated bags of soiled items would not exceed 50 pounds and normally weigh about 25 pounds.  Even if the appellant did lift items exceeding 50 pounds, as previously discussed in this decision job grading involves consideration of the total job to determine the most appropriate grade level; therefore, no one factor (or component of one factor) should be considered by itself in determining grade.  He also moves OR machinery mounted on wheels to clean behind and underneath them. 

This factor is evaluated at Grade 2.

Factor 4, Working Conditions

This factor covers the hazards, physical hardships, and working conditions to which workers are exposed in performing assigned work. 

Grade 2 custodial workers usually work indoors, in areas which normally have adequate heat, light, and ventilation.  They are exposed to vibration from heavy equipment, skin irritations from strong cleaning solutions, and serious injuries from falls from ladders and scaffolds. 

The appellant’s working conditions fully meet but do not exceed the Grade 2 levels for this factor described in the two work situations previously noted.  Like this level, he works indoors in the OR suite which has adequate heat, light, and ventilation.  When cleaning floors he is exposed to vibration from heavy scrubbers/buffers, and is regularly exposed to skin irritations from disinfectants and cleaning solutions.  He also risks serious injuries from falls from ladders while cleaning ceilings and walls.  Because the appellant works in the OR, to mitigate potential exposure to cleaning solutions and bio-hazardous materials he wears scrubs, latex gloves, and a hair bonnet, and may wear a gown, mask, and eye protection as needed.  

This factor is evaluated at Grade 2. 

Summary

By application of the four job grading factors in the 3566 JGS, the appellant’s job is graded at the Grade 2 level.  Because the appellant’s job fully meets but does not exceed the Grade 2 level, the highest level described in 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 Housekeeping Aid, WG-3566-2.

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