U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeals and FLSA Programs Atlanta Oversight Division 75 Spring Street, SW., Suite 972 Atlanta, GA 30303-3109 Job Grading Appeal Decision Under section 5346 of title 5, United States Code Appellant: [Appellants] Agency classification: Housekeeping Aid WG-3566-2 Organization: [Installation] Department of Veterans Affairs [Location] OPM decision: Housekeeping Aid WG-3566-2 OPM decision number: C-3566-02-01 /s/ _____________________________ Timothy P. Heath Classification Appeals Officer March 29, 2001 _____________________________ Date 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 and time limits specified in section 532.705(f) of title 5, Code of Federal Regulations (address provided in the Introduction to the Position Classification Standards, appendix 4, section H). Decision sent to: [Appellants] [Union Representative] Deputy Assistant Secretary for Human Resources Management (05) Department of Veterans Affairs 810 Vermont Avenue, NW, Room 206 Washington, DC 20420 Chief, Human Resources Management Service - 05 Medical Center Department of Veterans Affairs 1670 Clairmont Road Decatur, GA 30033 Human Resources Supervisor – 05 [Installation] [Location] Introduction On September 1, 2000, the Atlanta Oversight Division, Office of Personnel Management (OPM), accepted a group appeal for the job of Housekeeping Aid, WG-3566-2, [Installation], Department of Veterans Affairs (VA), in [Location]. The appellants are requesting that their jobs be changed to Housekeeping Aid, WG-3566-3. The appeal has been accepted and processed under section 5346 of title 5, United States Code (U.S.C.). This is the final administrative decision on the classification of the job subject to discretionary review only under the limited conditions and time outlined in part 532, subpart G, of title 5, Code of Federal Regulations (CFR). General issues The appellants state that the Federal Wage System (FWS) Job Grading Standard (JGS) for Custodial Work, 3566, dated September 1968, does not mention certain of their duties. Standards do not try to describe every work assignment of each position in an occupation covered. The standards identify and describe key characteristics of occupations that are significant for distinguishing different levels of work. In addition, the content of standards is not appealable (5 CFR 532.701). The appellants compare their jobs to other WG-3 Housekeeping Aid jobs at the [Installation] and other VA hospitals. By law, we must grade jobs solely by comparing their current duties and responsibilities to OPM standards and guidelines (5 USC 5346). Since comparison to standards is the exclusive method for grading a job, we cannot compare the appellants’ jobs to others as a basis for deciding this appeal. Like OPM, the appellants’ 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. If the appellants consider their jobs so similar to others that they all warrant the same classification, the appellants may pursue the matter by writing to their human resources office. In doing so, the appellants should specify the precise organizational location, classification, duties, and responsibilities of the jobs in question. If the jobs are found to be basically the same as the appellants’, the agency must correct their classification to be consistent with this appeal decision. Otherwise, the agency should explain to the appellants the differences between their jobs and the others. The appellants believe that their handling of biohazardous waste warrants a higher grade. When employees are exposed to conditions of an unusually hazardous nature, they are compensated by means of environmental pay differentials rather than job grading. However, if exposure to conditions of an unusual nature is regular and recurring, any related skill and knowledge, and responsibility should be taken into account in grading the jobs. This appeal decision is based on the job description of record, as well as information obtained from the appellants, the Operation Service Line Manager, and the supervisor. Job information The appellants are assigned to job description number [Number]. The appellants, Operations Service Line Manager, and the supervisor agreed during telephone interviews that the job description accurately depicts the appellants’ work. The appellants perform the full range of housekeeping duties in assigned areas of the hospital. Duties include dusting, dust mopping, wet mopping, and vacuuming; scrubbing floors; handling soiled linens; removing sharp containers and bags of general and biohazardous waste; loading and operating an automatic steam sterilizer to treat biohazardous waste; cleaning elevators, restrooms, drinking fountains, furniture, walls, and windows; replenishing dispensers of tissues, paper towels, and toilet paper; cleaning and storing the equipment they use; and requesting and storing their supplies. The appellants receive direction from a housekeeping supervisor who provides general instructions and assigns specific tasks or work areas. Regular cleaning duties are performed independently without instructions, although special assignments may require additional directions. The appellants have an Employees’ Handbook that explains in detail what to do and how to do it. Unusual or unexpected situations are referred to the housekeeping supervisor. The housekeeping supervisor spot-checks work to ensure completion of daily assignments. Standard determination FWS JGS for Custodial Worker, 3566, dated September 1968. Occupation and title determination The agency determined that the appellants’ jobs fall within the scope of the Custodial Worker series, WG-3566, and elected to use the title Housekeeping Aid, which was approved by OPM for use in the VA on November 26, 1968. The appellants do not contest the agency determination of their occupational series and title. The JGS for the WG-3566 occupation covers jobs involving a variety of janitorial and custodial duties including the operation of heavy industrial type power equipment. The appellants’ primary duties consist of cleaning assigned areas of the hospital. We agree that the WG-3566 series best describes the nature of the appellants’ duties and responsibilities. The appellants’ jobs are properly titled and coded as Housekeeping Aid, WG-3566. Grade determination The WG-3566 JGS uses four factors common to all FWS occupations in establishing the grade of jobs: skill and knowledge, responsibility, physical effort, and working conditions. The JGS for the WG-3566 occupation describes jobs at the grade 1 and 2 levels. Grade 1 custodial workers do a variety of cleaning tasks that require light physical effort and involve the use of hand or lightweight powered cleaning equipment. Specific instructions are provided on what to clean and the methods to use. Grade 2 Custodial Workers do work which involves higher levels of skills, knowledges, responsibility, physical effort, or working conditions than those described at the grade 1 level of this standard. In most cases, positions must exceed several of the work requirements described at grade 1 to be classified at the grade 2 level. However, it is possible for a major difference in a single factor to affect the overall level of the whole job. The appellants’ jobs generally compare to situation 2 of the grade 2 level where the work involves the full range of cleaning duties in an assigned area such as a hospital ward. Employees use various preparations to clean and maintain linoleum, wood, marble, and various kinds of floor, wall, and ceiling surfaces. They remove stains using chemicals and cleaning solutions; run powered cleaning equipment; clean and oil equipment; and change brushes and accessories. The appellants’ jobs are evaluated as follows: Skill and Knowledge This factor covers the nature and level of skill, knowledge, and mental application required in performing assigned work. Jobs vary in such ways as the kind, amount, and depth of skill and knowledge needed, as well as in the manner, frequency, and extent to which they are used. At grade 1, the job involves a variety of cleaning tasks that require light physical effort using lightweight powered cleaning equipment. Specific instructions are provided on what to clean and the methods to use. The work requires basic abilities and knowledges that generally require no job training or previous work experience. The employee must be able to use common cleaning tools, vacuums, powered waxers, and buffers that require a short training period. At the grade 2 level, employees must be able to perform all cleaning duties on their own without instruction. They must know the proper use of a variety of cleaning and sanitizing solutions and be able to remove different kinds of stains from a variety of surfaces. The appellants’ jobs exceed the grade 1 level definition and meet the grade 2 level. The appellants use industrial type equipment (i.e., scrubbers and vacuums) to perform assigned cleaning tasks such as dust mopping and wet mopping floors; washing walls, windows, and drinking fountains; cleaning restrooms and elevators; dusting furniture; collecting and removing sharp containers and waste; and replenishing paper products such as toilet tissue, facial tissue, and hand towels. All housekeeping aids handle biohazardous waste, but the appellants are the only ones who load and operate an automated sterilizer that treats the waste before it is placed in the facility trash compactor. They are also required to clean the equipment they use. This, however, does not exceed the grade 2 level. There is no indication that any of the work assigned to the appellants exceeds the work described at grade 2. This factor is evaluated at WG-2. Responsibility This factor covers the nature and degree of responsibility involved in performing work. Jobs vary in responsibility in such ways as the complexity and scope of work assigned, the difficulty and frequency of judgments and decisions made, the kind of supervisory controls, and the nature of work instructions and technical guides used. At grade 1, workers receive specific instructions for each new task. They are not usually required to use judgment since their work is scheduled for them and checked upon completion. At grade 2, situation 2, workers do the full range of cleaning, receiving only general instructions and general supervision. The appellants’ jobs exceed the grade 1 level and are comparable to the grade 2 level. Although the supervisor is available and the appellants may consult their Employees’ Handbook, the appellants work under general directions. Their supervisor only spot-checks their work by making routine walk-throughs. There is no indication in the appeal record that the appellants’ jobs exceed the grade 2 level. This factor is evaluated at WG-2. Physical Effort This factor covers the physical effort exerted in performing assigned work. Jobs vary in such ways as the nature, degree, frequency, and duration of muscular effort or physical strain experienced in work performance. The work at the grade 1 level involves light physical effort, such as that involved in using vacuum cleaners and running lightweight powered scrubbers; continually standing, bending, stooping, and reaching; frequently lifting and emptying wastebaskets; frequently pushing carts loaded with dirty laundry or waste paper; and occasionally lifting and carrying items weighing up to about 20 pounds. At the grade 2 level, moderately heavy effort is used occasionally in moving, setting up, and working from ladders. Use of heavy powered equipment is required but not on a continuous basis. The appellants exceed grade 1 and meet grade 2. The Operations Service Line Manager and the housekeeping supervisor indicated that the appellants might use heavy powered cleaning equipment but not on a continual basis. The appellants must handle soiled linens and bags of general and biohazardous waste frequently weighing up to 50 pounds and occasionally over 50 pounds. They exert moderate physical effort during the course of a day by pushing and maneuvering carts to transport soiled linens and bags of waste, bending, lifting, stooping, and climbing. There is no indication in the appeal record that the appellants’ jobs exceed the grade 2 level. This factor is evaluated at WG-2. Working Conditions This factor covers the hazards, physical hardships, and working conditions to which workers are exposed in performing work. Grade 1 custodial workers work indoors in areas which normally have adequate heat, light and ventilation. They are exposed to dirt and disagreeable odors. Normally, there is a chance only of minor injuries such as cuts and bruises. At the grade 2 level, the employee usually works indoors in areas that normally have adequate heat, light, and ventilation. Occasionally the employee is exposed to skin irritations from strong cleaning solutions used in stripping floors, etc., and to serious injuries (e.g., broken bones) from falls from ladders or scaffolds. The appellants exceed grade 1 and meet grade 2. Information from the Operations Service Line Manager, the housekeeping supervisor, and the appellants indicate that working conditions generally meet this level and involve the typical occupational hazards of working in a hospital environment. The appellants emphasized their handling of sharp containers and bags of biohazardous waste and their loading and operation of the sterilizer. The Operations Service Line Manager and the housekeeping supervisor stated that biohazardous waste handled by the appellants is double-bagged, and that the failure of both bags is rare. In addition, all housekeeping aids at the facility handle these items, take appropriate precautions, and are required to wear rubber gloves and other protective clothing. Although the appellants are the only housekeeping aids that load the bags of biohazardous waste into the sterilizer, the equipment is automated, not complicated to operate, and requires no increased skill. The appellants also wear heat-insulated gloves when loading the waste into the sterilizer. The intent of the grade 2 level is met. This factor is evaluated at WG-2. Decision This job is properly classified as Housekeeping Aid, WG-3566-2.