U.S. Office of Personnel Management Office of Merit Systems Oversight and Effectiveness Classification Appeal and FLSA Programs Philadelphia Oversight Division 600 Arch Street, Room 3400 Philadelphia, PA 19106-1596 Job Grading Appeal Decision Under section 5346 of title 5, United States Code Appellant: [appellant's name], et al Agency classification: Materials Handler WG-6907-5 Organization: Warehousing Division, [acronym] [activity name] [higher-level activity name] Defense Logistics Agency [location]a OPM decision: Materials Handler WG-6907-5 OPM decision number: C-6907-05-01 /s/ Robert D. Hendler _____________________________ Robert D. Hendler Classification Appeals Officer 5/30/01 _____________________________ Date As provided in section S7-8 of the Operating Manual: Federal Wage System (FWS), 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: PERSONAL [appellants' names] [activity name] Warehousing Division, [acronym] [address] [location] [representative's name]y 1st Vice President American Federation of Government Employees, AFL-CIO P.O. Box [number] [location] [name] Director, Personnel and Administration [activity name] [address] [location] Ms. Pamela M. Creek Executive Director, Human Resources Defense Logistics Agency 8725 John J. Kingman Road, Suite 3630 Fort Belvoir, VA 22060-6221 Ms. Janice W. Cooper Chief, Classification Appeals Adjudication Section Department of Defense Civilian Personnel Management Service 1400 Key Boulevard, Suite B-200 Arlington, VA 22209-5144 Introduction On February 8, 2001, the Philadelphia Oversight Division of the U.S. Office of Personnel Management (OPM) accepted a job grading appeal from [representative's name] on behalf of [appellant's name]. In a February 9, 2001, letter designating [representative's name] as their representative, 22 co-workers occupying identical additional Materials Handler, WG-6907-5, jobs joined the appeal. They believe the job should be Materials Handler, WG-6907, or Packer, WG-7002, at the grade 6 level. They work in the Warehousing Division, [acronym], [activity name], [higher-level activity name], Defense Logistics Agency, [location]. We accepted and decided this appeal under section 5346 of title 5, United States Code (U.S.C.). General issues The appellants believe that their materials handling and packing duties are of equal importance and both meet the grade 6 level. Their appeal rationale states that they use an in-depth knowledge of the overall warehousing plan, documentation requirements, and accepted warehousing methods, procedures, and techniques. They custom pack materials; cut heavy cardboard tubing to the length required for an item; cut down and modify cartons and multi- walled containers to custom fit materials; and block and brace material. The appellants repair damaged wooden containers if feasible. Packing is based on the item type, size, type of protection required, shipment requirements and specifications, and the level of protection required to insure shipments are not damaged. In his March 13, 2001, letter, the representative cited an Unfair Labor Practice settlement with the agency that acknowledged that packing duties previously performed by grade 6 Packers had been redistributed to the appellants. Our job grading decisions must be based solely upon a comparison between the actual duties and responsibilities of the job and the appropriate job grading standards (JGS's) (5 U.S.C. 5346). Other methods or factors of evaluation may not be used in the job grading process. These include comparing the appellants' jobs with other jobs that may or may not be graded correctly, such as the grade 6 Packers cited by the representative, or the grading of the jobs previously occupied by the appellants. Therefore, our evaluation of the appellants' packing work will be based on our independent application of the appropriate JGS's to those duties and responsibilities. The appellants’ rationale relies on the description of work in the position description (PD # [number]) of record. A PD is the official record of the major duties and responsibilities assigned to a position or job by an official with the authority to assign work. A position or 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 PD. Therefore, this decision is based on the actual work assigned to and performed by the appellants and sets aside any previous agency decision. We conducted an on-site audit with Messrs. [four appellant names] selected by the group to represent them. At [appellant's name]'s request, we interviewed a co-worker, [name], who did not sign the February 9, 2001, designation of representative letter. On May 22 and 23, respectively, we conducted telephone interviews with the appellants' immediate supervisors, [supervisor's names]. In deciding this appeal, we fully considered the audit findings and all information of record furnished by the appellants and their activity. We find that the PD of record contains the major duties and responsibilities assigned to and performed by the appellants and we incorporate it by reference into this decision. Job information The appellants’ facility consists of a large mechanized facility, approximately 16 outside warehouses, 9 sheds, and open storage areas. They work in the outside warehouse, shed, and/or open storage areas. They pick, pack and load a wide variety of materials that are boxed, palletized or loose. The appellants verify destination, national stock number, quantity and other data against storage documentation. They process and complete storage and shipping documentation ensuring the correctness of quantities, identification criteria and/or labeling, and report overages, shortages and condition code discrepancies. They use materials handling equipment to move material and perform preventive operator maintenance on the equipment. The appellants operate automated equipment such as computer keyboards, radio frequency scanner guns, bar code wands, stretch wrap machines, and scales. They input and extract information from the computerized supply system regarding stored items or groups of stored items and their designated storage locations. When packing items, they decide on the size and type of container to uses based on the item type, size, type of protection required, shipment requirements and specifications. The appellants take measurements and modify or cut the carton or skid. They determine the need for and apply blocking, bracing, strapping, taping, stretch wrapping and bagging. The appellants stencil or mark the containers based on packing requirements and customers requests. The appellants receive general instructions from a leader or supervisor and work independently. They follow established guidelines as to methods, techniques and procedures. The appellants interpret manuals, instructions and regulatory requirements when packing. They are responsible and accountable for inventory. The appellants refer unique or unusual problems to a higher graded worker or supervisor. Series, title, and standard determination The agency allocated the job as Materials Handler, WG-6907, finding the Packer, WG-7002, duties were secondary. The appellants request allocation to either series. Based on the analysis that follows, we find the job is allocated properly as Materials Handler, WG-6907. The packing work is secondary to the overall materials handling functions. The materials handling duties are covered by the 6907 JGS and the packing duties are covered by the 7002 JGS. Grade determination During the on-site audit, the appellants stressed the fact that they perform a greater variety of work than when they only carried out materials handling duties. In the FWS, mixed jobs that perform work in two or more occupations are graded based on the highest level of regular and recurring work performed. If a job involves regular and recurring work at the same grade level in two or more occupations, such a mixed job is graded at that same level. Evaluation using 6907 JGS This JGS covers nonsupervisory 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. Most work requires the incidental or regular use of forklifts and motor vehicles. The JGS uses four factors to determine grade level: Skill and Knowledge; Responsibility; Physical Effort; and, Working Conditions. Skill and Knowledge As journey-level workers, the appellants perform a wide variety and range of duties requiring a specialized knowledge of warehouse plans, methods, procedures, and techniques of materials handling typical of the grade 5 level. They operate mechanized equipment including standard size forklifts, and use remote computer terminals to receive and transmit storage, inventory, and requisition data. The appellants use this level of skill and knowledge to: (1) query the supply system (exclusion file) and reroute items erroneously sent to their assigned warehouse to the correct warehouse; (2) calculate weight and cube, and apply dimensional limitations in planning vehicle loads; and (3) prepare shipments based on carrier weights, packing material, and dimensional limitations. They independently process and complete shipping and receiving documents, insuring correctness of quantities, identification criteria, and labeling. If packing limitations prevent shipping by the established method, they change the method in the system. For example, if FEDEX or UPS will not accept the required packing, they ship the item by freight. Typical of the grade 5 level, the appellants place new items based on established space assignment practices. For example, they may put slow moving items in the back of the warehouse and faster moving items in the front near the loading dock. As permitted by the supervisor, they may assign a temporary location for items that, based on pending material release orders (MRO's), will be shipped shortly after receipt. Working within established procedures, the appellants consolidate stock as floor space is cleared. In the bin warehouses, the appellants move items misidentified by size into smaller or larger bins as needed and put the new location into the automated system. They use automated equipment, including optical readers, scanners and computer keyboards to develop computerized inventory data, access materials and fill item requisitions based on established procedures, e.g., foreign military sale MRO's are filled with the newest rather than the oldest stock. As at the grade 5 level, the appellants are skilled in stacking, moving, and arranging items on pallets and must consider height, weight, and special handling requirements to prevent damage in storage or in transit, e.g., loading heavy shoe track in the center of the truck bed. The appellants point to language in their PD that, as at the grade 6 level, they must have an in- depth knowledge of the overall warehousing plan, documentation requirements, and accepted warehousing methods, procedures, and techniques. However, they do not use this knowledge in the manner described in the JGS. Each appellant is not a senior worker with functional responsibilities for a major commodity segment or equipment group in a larger warehouse, or the primary materials handler in a small warehouse that does not have a resident work leader or supervisor. In that capacity, grade 6 level materials handlers lay out storage space and establish item and material locations in accordance with agency regulations; prepare inventory and production reports; screen and identify shipping and receiving documents for discrepancies; and direct shipments to shipping or storage areas. In that role, they determine sequences for loading materials and organize incoming shipments for maximum space utilization, safety considerations, and damage protection. They also may operate the larger material moving equipment and vehicles inside the warehouse, and forklifts and related vehicles in outside holding areas on unpaved, unimproved, or difficult terrain. The appellants stress that their storage and work control decisions meet the grade 6 level. Their rationale states that there are no standard operating procedures and there are no specific restrictions on their use of storage space in any warehouse. The appellants are not delegated authority or responsibility for grade 6 level work control and storage decisions. None of the appellants function in a senior worker capacity over the average of two employees assigned to each warehouse. Working within the depot master storage plan, division Supply Technicians, GS-2005-7 (PD #[number]), are responsible for maximizing space utilization and material flow on the basis of commodities and stock characteristics, handling problems, stock turnover, location of loading and unloading points and care preservation. In addition to the appellants' supervisors, the Supply Technicians oversee daily work operations; distribute and balance workload among team members; monitor the progress of work and make adjustments to meet goals; and provide technical instructions and assistance to employees when necessary. Therefore, this factor is credited at the grade 5 level. Responsibility The appellants' rationale states that they function at the grade 6 level because they: (1) screen shipping documents for discrepancies and direct shipments to shipping or storage areas; (2) make decisions on storage space; and (3) are evaluated based on results achieved. Grade 6 level responsibility is based on performing a full range of senior materials handler functions as discussed previously. These responsibilities include receiving, locating, storing, shipping, and rewarehousing materials, commodities, or equipment in accordance with established procedures and operating requirements, determining the sequences of loading and unloading, developing space utilization plans, and implementing the movement of materials from dock to bin or from storage to shipping. They guide lower level workers in accessing and using remote computer terminals and equipment to verify inventory levels, fill orders, place stock, and develop the necessary computerized documentation, and in making determinations as to the placement, unloading, timing, and general movement of materials within assigned areas. In smaller warehouses and storage facilities, they may be responsible for the movement of the stock as well as the maintenance of stock level inventories. In larger warehouses, they may have responsibility for a segment of the warehouse stock, insuring adherence to established documentation, safety, material movement, and preservation procedures and requirements. Grade 6 materials handlers perform this range of functions under the general direction of a supervisor or facility supervisor. Because of the recurring nature of the appellants' work assignments, supervisory contact is limited. Our fact-finding disclosed that their work is spot-checked typical of the grade 5 level. Unless they are given special instructions by the supervisor or the Supply Technician, the appellants plan and perform their work based on oral instructions and the normal flow of work. For example, high priority Super 1 and 2 MRO's, dedicated truck shipments (truck waiting), and unloading waiting trucks have high priority. This meets the grade 5 level where employees receive work assignments from their supervisor and are responsible for document processing and verification of the quantity and condition of materials and equipment handled. Typical of this level, the appellants complete their work without guidance on methods, procedures, or techniques. They contact their supervisor or a Supply Technician on issues that require intervention. For example, they seek guidance on whether items labeled as hazardous are and must be referred to that area of the depot. Their work is reviewed for compliance with general guidelines and results achieved. As at the grade 5 level, they follow established methods and procedures, operate forklift trucks and may operate tugs and similar storage and retrieval vehicles. Because the appellants do not operate as senior materials handlers as discussed previously, they do not deal with the variety of issues and do not exercise the greater judgment and independent action on work control and storage found at the grade 6 level. They also do not provide guidance to lower graded employees typical of the grade 6 level. Therefore, this factor is credited at the grade 5 level. Physical Effort and Working Conditions are the same at both grades level. Because they do not have grade level impact, and the appellants' work meets the levels described in the JGS, we will credit both factors as being met and will not address them further. In summary, the appellants' materials handling work is credited at the grade 5 level. Evaluation using the 7002 JGS This JGS covers nonsupervisory work involved in preserving and/or packing and repacking equipment, parts, tools, materials, and other items in various types of containers to protect them from damage, deterioration, or corrosion during shipment and storage. Most work requires the incidental use of a variety of trade practices associated with related or support occupations such as forklift operating, wood working, mechanical equipment assembly, and materials handling. The JGS uses four factors to determine grade level: Skill and Knowledge; Responsibility; Physical Effort; and, Working Conditions. Skill and Knowledge The appellants' rationale states that they perform grade 6 level custom packing of materials by cutting down cardboard tubes, and modifying cartons and multi-walled containers to custom fit material. They pack based on item type, size, protection required, shipment requirements and specifications. They block and brace to secure material, and repair damaged wooden containers if economically feasible. The appellants apply a detailed knowledge of different types of standard packing containers, protective devices, and cushioning and packing materials typical of the grade 5 level. They apply their knowledge of agency, Federal, and international regulatory requirements to store, pack, and ship items within the United States and overseas. Typical of this level, they have skill to fabricate and/or assemble containers such as tri-wall reinforced fiberboard boxes. As at the grade 5 level, they apply knowledge of woodworking techniques and procedures sufficient to construct or modify standard shipping or storage containers, e.g., modifying skids and pallets to fit items to be shipped and repairing damaged wooden crates. As at the grade 5 level, they secure irregularly shaped items, e.g., copper tubing. Typical of the grade 5 level, they use computerized equipment to access regulatory and shipping databases for instructions regarding packing, shipping, and labeling of national and international shipments, e.g., MILSTD 129. They have general knowledge of specialized shipping requirements and are able to research packaging data files to determine requirements for packing requirements for specific items or pieces of equipment. Packers at this level have skill in the use of barrier wraps with internal cushioning to prepare items such as small arms, engine accessories, and mechanical parts for shipping or storage. They may also partially disassemble mechanical items requiring preservation. The appellants apply similar skills in recycling containers and packing materials to ship irregularly shaped vehicle parts, construction materials and other industrial materials. The appellants perform more limited materials disassembly when breaking down shoe track. Typical of the grade 5 level, they brace some sensitive materials and equipment within containers for shipment. They do not use a wide variety of packing and preservation materials and packing techniques such as "foam-in-place," electro-sensitive discharge, and procedures to protect sensitive electronic equipment, mechanical devices, and precision parts typical at this level. However, their ad hoc use of recycled packing materials to secure and protect shipped items offsets these weaknesses. This work does not require applying an in-depth knowledge of a wide variety of preservation processing methods and techniques and/or an in-depth knowledge of a wide variety of standard packing methods and techniques found at the grade 6 level. Unlike the grade 6 level, the appellants do not routinely pack and ship hazardous materials and do not prepare and verify shipping documents for correct safety and destination coding, classifications, and hazardous materials handling criteria. The items that they handle are not of the fragility to require the construction of cradling and protective forms from illustrations and specifications. While the appellants pack some large items, the work does not routinely require determining weight support points and fabricating supporting bracing and blocking to prevent shifting or breakage to the extent found at the grade 6 level. Their work with large items consists of preventing shifting on standard pallets and skids, and loading items in trucks to prevent shifting. More complex blocking and bracing is performed by another depot organization. Unlike the grade 6 level, they do not set up and operate carton-making equipment, construct complete wooden crates, or fabricate protective framing to the extent envisioned at the grade 6 level. Based on the preceding analysis, we find that the appellants’ work meets the grade 5 level threshold. Responsibility The appellants' rationale is based on their freedom from supervision. However, grade 6 level responsibility is based on independence in determining the methods and techniques to preserve and/or pack a wide variety of standard and non-standard items handled at the grade 6 level. They provide technical guidance to lower level workers in preserving and packing specialized and sensitive equipment, including hazardous material packing. Because the appellants do not perform grade 6 level packing duties and do not provide technical guidance to lower graded workers on grade 6 level work, this factor cannot be credited at the grade 6 level. As at the grade 5 level, the appellants receive supervision from their immediate supervisor who gives instructions on new or changed policies and procedures. The supervisor or Supply Technician provides technical guidance to resolve difficult or unusual problems. Typical of the grade 5 level, the appellants perform most tasks independently, using their knowledge and skill in packing to interpret manuals, instructions, and regulatory requirements. The supervisor provides technical direction on new or unusual assignments. Completed work is spot checked by the supervisor for compliance with instructions, standard operating procedures, and quality of work and timeliness. Therefore, this factor is credited at the grade 5 level. Physical Effort and Working Conditions are the same at both grades level. Because they do not have grade level impact, and the appellants' work meets the levels described in the JGS, we will credit both factors as being met and will not address them further. In summary, we find that the appellants’ packing duties meet the grade 5 level. Decision The appealed job is properly graded as Materials Handler, WG-6907-5.