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



12/18/2018

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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).

As indicated in this decision, our findings show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E. of the Introduction.  Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings.  The servicing human resources office must submit a compliance report containing the corrected PD within 30 days of the date of this decision to the U.S. Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.

 Introduction

The appellant’s position is currently classified as a Safety Technician, GS-0019-07.  The position is assigned to the Defense Logistics Agency (DLA) Distribution Norfolk Safety Office, Depot Operations Division, DLA Distribution Norfolk, Office of the Commander, DLA, in Norfolk, Virginia.  The appellant believes his position should be classified as a Safety and Occupational Health Specialist, GS-0018-11.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements about his agency’s evaluation of his position and compares his position to Safety and Occupational Health Specialist, GS-0018-11, positions in his organization.  In adjudicating this appeal, our responsibility is to make an independent decision on the proper classification of the appellant’s position.  By law, we must make that decision solely by comparing his current duties and responsibilities to OPM position classification standards (PCS) 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 others, which may or may not be classified correctly, as a basis for deciding his appeal.  Because our decision sets aside any previous agency decisions, the classification practices used by the appellant’s agency in classifying his position, are not germane to the classification appeal process. 

Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines.  However, 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 (HR) headquarters.  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 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 states his official PD number H1U3121 is not accurate because he does not “assist” anyone in the performance of his work as indicated in various parts of the PD, but rather independently and without supervision performs his work.  However, the appellant’s supervisor (Supervisory Safety and Occupational Health Specialist, GS-0018-12) certified to the accuracy of the appellant’s official PD.  A PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work.  A position is the duties and responsibilities that make up the work performed by the employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position and not simply a PD.  We have decided this appeal based on an assessment of the actual work currently assigned to and performed by the appellant.

Our review disclosed the appellant’s PD of record is not completely accurate in that it describes duties he does not perform.  Specifically, the appellant is not responsible for “developing, implementing, executing and tracking all elements of the command safety training programs,” and for “establishing, maintaining and collecting information and data for the purposes of tracking Voluntary Protection Program (VPP) key performance indicators, to include compiling data and preparing presentation and reports.”  He does not “serve as a VPP/OSHA subject matter expert in support of a wide variety of OSHA/VPP committees staffed by employees and managers.”  The appellant does not “independently facilitate VPP committee efforts when the committee charter has a limited technical scope and consists of less than 10 members.”  Further, he does not “maintain accurate training records, tracking information, and other documentation related to VPP committee efforts.”  The appellant is also not responsible for “collecting and compiling information and metrics related to Safety/VPP efforts, programs incidents, and inspections to enable a continuous evaluation of Safety/VPP performance in relation to established key performance indicators (KPIs) and regulatory standards.”  Additionally, he does not “gather and prepare charts and reports reflecting pertinent information, statistics, and figures for presentation purposes or to support regular reporting of safety information.”  These responsibilities lie with the VPP Coordinator or other safety personnel as assigned.  Therefore, the appellant’s PD of record does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and the agency must revise the PD to reflect our findings. 

Position information

As the Nation’s Combat Logistics Support Agency, DLA sources and provides nearly all consumable items America’s military forces need to operate, from food, fuel and energy to uniforms, medical supplies, and construction material.  DLA Distribution is a primary field level activity of the DLA and leading provider of global distribution support to America’s military including receiving, storing and issuing supplies as well as providing other tailored services to increase warfighter readiness.  DLA Distribution Norfolk has incorporated regional distribution operations to include warfighter support sites in Cheatham Annex; Little Creek; Crane, Indiana; and in New London, Connecticut.  Additionally, Norfolk Naval Shipyard industrial operations are now supported on site through the DLA Distribution Norfolk affiliate organization in Portsmouth, Virginia.  DLA Distribution Norfolk also partners with DLA Disposition Norfolk in the reutilization, recycling, and disposal of government property.

The appellant’s position is assigned to the DLA Distribution Norfolk Safety Office.  The mission of the office is to create and maintain a safe working environment that influences the attitudes of leadership and employees, thereby reducing injuries, accidents, environmental impact and ensuring compliance.  The office manages the local DLA Occupational Safety and Health (OSH) Program, its multiple subprograms, and local command safety training programs.  Program activities ensure site functions are performed in a manner that safeguards human health and safety and are in compliance with safety laws, regulations and policies.  The office is headed by the appellant’s supervisor (i.e., Safety Manger), and is composed of one Safety and Occupational Health Specialist, GS-0018-09, four Safety and Occupational Health Specialists,GS-0018-11, one Safety Technician, GS-0019-07 (the appellant’s position), one Supply Technician, GS-2005-07, and a Material Handling Equipment Trainer, GS-0301-09 (position currently vacant). 

The appellant performs technical work that directly supports the mission of the DLA Distribution Norfolk Safety Office.  He is responsible for conducting periodic safety inspections of DLA Distribution Norfolk facilities including but not limited to industrial areas, warehouse operations, office environments, construction and storage areas, and contractor workplaces (i.e., conex boxes).  The inspections focus on eliminating unsafe practices and/or conditions and prevent similar recurrences.  The nature of the hazards identified range from minor to serious in severity found in the areas of hazardous materials, electrical, ventilation, construction, equipment, maintenance and repair and material handling.  The appellant uses the Enterprise Safety Application Management System (ESAMS) to document the location and description of the hazard (referred to as “deficiency”), assigns a Risk Assessment Code (RAC) to each identified hazards.   RACs 1, 2, and 3 are assigned to severe hazards, RAC 4 to minor hazards and RAC 5 to negligible hazards.  The appellant issues deficiency notices to the official responsible for abatement, providing interim control recommendations some of which may involve innovative prevention methods that comply with safety standards and prevention techniques until permanent abatement actions are taken.  For hazards that are work process-related, the owner of the work process is responsible for managing hazard abatement.  For hazards that are facility-related, the facility’s supervisor is responsible for managing the abatement.  The appellant’s supervisor reviews the appellant’s findings and recommendations entered in ESAMS.  When controversial or sensitive situations are presented the appellant seeks guidance from his supervisor.  Once abatement actions have been taken, the appellant reviews the actions taken as provided in ESAMS and either closes or requests further action be taken if necessary. 

The appellant also performs mishap investigations of unsafe physical conditions involving injury or illness of persons and/ or damage to government property.  The investigations focus on determining how and why the event occurred.  The appellant gathers factual information about the nature of the mishap, contributing causes and recommends accident prevention measures the supervisor or other designated employee must complete to prevent the mishaps from reoccurring.  Further, the appellant participates in Department of Labor Occupational Safety and Health Administration (OSHA) and Environment Protection Agency (EPA) inspections, Industrial Hygienist Surveys, DLA headquarters and other similar inspections by accompanying safety personnel during inspections, documenting findings, taking photographs and reporting findings to his supervisor.  Furthermore, he initiates actions to procure Personal Protective Equipment (PPE) based on need and as determined after a hazard assessment is conducted.  He provides assistance to supervisors responsible for the development of Job Hazards Analysis (JHA) used to identify potential hazards associated with conducting a task or process.  He also assists supervisors in identifying procedures and techniques (i.e., lockout/ tagout) that protect personnel where death or injury can occur because of the unexpected release of hazardous energy associated with machines, equipment, or processes.  Additionally, he provides informal basic safety training to supervisors and/or employees in safe work methods and standard accident prevention techniques.  He also conducts safety briefs to contractors, vendors and visitors working or conducting business in DLA sites to ensure that responsibilities are understood, that personnel recognize hazards they may encounter, and that they follow safety reporting procedures. 

In reaching our classification decision, we have carefully reviewed all of the information provided by the appellant and his agency including his official PD, which although not completely accurate we have incorporated by reference into this decision.  Also, to help decide the appeal, we conducted separate telephone interviews with the appellant and his supervisor including follow-up requests for additional information from the appellant.

Series, title, and standard determination

The agency classified the appellant’s position in the Safety Technician Series, GS-0019, titling it Safety Technician, and evaluating it by application of the PCS for the Management and Program Clerical and Assistance Series, GS-0344.  The appellant disagrees with his agency’s title, series, and standard determination.  He believes his work warrants classification to the Safety and Occupational Health Management Series, GS-0018.

The Safety and Occupational Health Management Series, GS-0018, covers two-grade interval positions in the management, administration, or operation of a safety and occupational health program or performance of administrative work concerned with safety and occupational health activities and includes the development, implementation, and evaluation of related program functions.  The purpose of the work is to eliminate or minimize human injury and property and productivity losses, caused by harmful contact incidents, through the design of effective management policies, programs, or practices.  Safety and occupational health management work requires application of the knowledge of (a) the principles, standards, and techniques of safety and occupational health management and (b) pertinent elements of engineering, physical science, ergonomics, psychology, industrial hygiene, physiology, sociology, and other scientific and technological fields which contribute to the achievement of comprehensive safety and occupational health objectives. 

Safety and occupational health activities include developing a comprehensive plan for safety and occupational health; achieving compliance with the intent of safety and occupational health legislation and related standards, order, rules, and regulations; analyzing accident and illness data, applicable legislation, and job hazards to design appropriate education activities; and inspecting work areas to identify and eliminate unsafe and unhealthful environmental conditions.  Positions in the GS-0018 series require broad knowledge of safety and occupational health principles, methods, and techniques and skill in recognizing hazardous or potentially hazardous conditions, developing measures to eliminate or control these conditions, and effectively communicating the appropriate measures to resolve these problems.

The Safety Technician Series, GS-0019,  covers one-grade interval positions that involve support work in accident prevention, including inspecting safety conditions, investigating and compiling data on accidents, and providing information on safety standards and techniques.  Positions in this series require a practical knowledge of work processes and equipment, environmental conditions, and established safety standards, protective devices and accident prevention measures.  Safety technicians perform support work in the safety field that involves obtaining and giving factual information about safety.  Safety technicians perform routine inspection and investigative work in enforcing occupational safety and health laws.  Safety technicians look for and report on unsafe mechanical and physical conditions and work practices bordering on carelessness or negligence that may involve injury to persons or damage to property, or both.  Safety technicians report findings and recommendations to the supervisor.  Their findings result typically from observing violations of established requirements and safe practices.

Safety technicians investigate accidents and review accident reports for such items as specific causes and the nature of injuries or damage to property to assure proper coding.  They issue and maintain personal protective equipment.  They provide supervisors, employees and safety representatives with clearly applicable information concerning accident hazards in the work setting.  Safety technicians also conduct safety meetings with workers to give or reinforce training in safe work methods, and standard accident prevention techniques such as use of protective clothing, defensive driving, etc.  Safety technicians apply technical knowledge of the trades and craft or general safety practices type.  They also frequently perform duties which require a general understanding of the construction, operation, and capacity of industrial machinery, construction machinery, and Diesel, automotive, and marine equipment.  Knowledge of blueprints and designs may also be utilized in the performance of work in this series.  Such knowledge may have been gained through vocational training or practical work experience.

Classification guidance in the Introduction and The Classifier's Handbook describes distinctions between positions properly classified in two-grade interval administrative series and positions classified in one-grade interval support series.  Administrative positions (two-grade interval) are involved in work primarily requiring a high order of analytical ability.  This ability is combined with a comprehensive knowledge of (1) the functions, processes, theories, and principles of management and (2) the methods used to gather, analyze, and evaluate information.  Administrative positions are involved with analyzing, evaluating, modifying, and developing the basic programs, policies, and procedures that facilitate the work of Federal agencies and programs.  Administrative work also requires skill in applying problem solving techniques and skill in communicating effectively both orally and in writing.  Administrative positions do not require specialized education, but they do involve the type of skills (analysis, research, writing, judgment) typically gained through college level education or through progressively responsible experience.  Administrative work often involves planning for and developing systems, functions, and services; formulating, developing, recommending, and establishing policies, operating methods, or procedures; and adapting established policy to the unique requirements of a particular program.  In contrast, support positions (one-grade interval) perform work that follows established methods, procedures, and guidelines and may require a high degree of technical skill, care, and precision.  The work can be performed based on a practical knowledge of the purpose, operation, procedures, techniques, and guidelines of the specific program area or functional assignments.  Support personnel typically learn to do the work on-the-job and also may attend specific training courses related to their work.

We find the appellant’s position does not involve two-grade interval administrative work and thus does not meet the series definition and nature of work for positions classified in the Safety and Occupational Health Management Series, GS-0018.  The primary purpose of the appellant’s position is to perform technical work in accident prevention including inspecting safety conditions, investigating and compiling data on mishaps, and providing information on safety standards and techniques to supervisors, employees and other personnel.  The paramount knowledge required is practical knowledge of work process and equipment, environmental conditions, established safety standards and accident prevention measures.  The appellant’s position does not require applying the depth of analytical ability, and research and writing skills, indicative of administrative positions, nor the broad and/or specialized knowledge and skills described in the definition for positions in the GS-0018 series.  Positions in the GS-0018 series are involved in analyzing accident and illness data, applicable legislation, and job hazards to design appropriate education activities, and to develop a comprehensive plans for safety and occupational health.  In contrast, the appellant’s work is reactive by design and limited to resolving specific safety deficiencies.  His work is driven primarily by inspection findings and investigation requests with the end product taking shape immediately and concretely; i.e., when the unsafe practice or condition is mitigated or the work order is completed.  He is not responsible for developing occupational and safety plans, policies, and procedures and his work is covered extensively by well-documented guidelines.  Further, the work performed by the appellant is typically learned on-the-job and from formal training related to his work.  For instance, the appellant has completed courses in OSHA general industry safety, hazard awareness, mishap investigation, fall prevention, electrical safety and other courses.  Further, as indicated by the appellant’s supervisor, the appellant’s position would require some degree of knowledge in safety techniques that could be gained from on-the-job experience, and would include individuals who can work independently and know how to communicate effectively with supervisors when providing inspection findings.  Consequently, the GS-0019 series best represents the position’s purpose which is to perform technical work in accident prevention, including inspecting safety conditions, and investigating and providing information on safety standards and techniques.  The prescribed title for nonsupervisory positions in this series at grades GS-04 and above is Safety Technician. 

The Position Classification Flysheet for the Safety Technician Series, GS-0019, does not contain grade level criteria.  As explained in the Introduction, an appropriate general classification guide or criteria in a PCS or PCSs for related work should be used if there are no specific grade level criteria for the work.  PCSs used for cross-comparison should cover work as similar as possible to the work being performed with regard to the kind of work processes, functions, or subject matter; qualifications required to do the work; level of difficulty and responsibility; and the combination of classification factors with the greatest influence on grade level. 

The appellant’s agency evaluated the grade of the appellant’s position by application of the PCS for the Management and Program Clerical and Assistance Series, GS-0344. [1]  We disagree with their determination.  The PCS for the Program Clerical and Assistance Series, GS-0344 evaluates positions involved in supervising or performing clerical and technical work in support of management analysis and program analysis, the purposes of which are to evaluate and improve the efficiency, effectiveness, and productivity of organizations and programs.  The work requires a practical knowledge of the purposes, methods, and techniques of management analysis and/or program analysis and the structures, functions, processes, objectives, products, services, resource requirements, and similar features of Government programs and organizations.  Employees in this series perform many different kinds and combinations of work at different organizational levels.  Some employees perform the basic procedural tasks needed to complete management or program analysis projects and processes.  For example, they maintain, gather, and compile records of organizational and workflow charts, staffing levels, mission and function statements, program resource use and availability, and internal audit reports; review reorganization requests, performance and management indicator reports, suggestions for program improvements, and other similar management and program analysis documents for appropriate format, distribution, and inclusion of required information and explain reporting procedures and requirements to operating officials; compile and distribute reports on proposed program goals, budgets, staff levels, and performance criteria to operating officials for review and comment; make and verify routine calculations such as standard cost estimates, production rates, staff hours, and workload figures; or prepare charts, graphs, and narrative information for management or program analysis reports from material provided by higher level employees.  The appellant does not perform any such clerical or technical work in support of management and/or program analysis, nor does he perform different kinds and combinations of assistance work at different organizational levels.  Moreover, the Position Classification Flysheet for the Safety Technician Series, GS-0019 states that positions in the GS-0019 series are appropriately evaluated by standards from technician occupations.  Thus, the GS-0344 PCS is not appropriate for evaluating the grade level of the appellant’s position.

The PCS for the Fire Protection and Prevention Series, GS-0081 provides an appropriate comparison for establishing the grade level of the appellant’s position.  Analogous to the appellant’s position, the GS-0081 series covers fire protection inspector positions that involve physically inspecting a variety of facilities to detect and reduce or eliminate potential fire hazards.  It also covers positions that train personnel in fire protection and prevention, implement fire protection and prevention plans, procedures, and standards, and advise on improvements to structures for better fire prevention.  Similar to the appellant’s positon, fire protection inspectors are responsible for areas of an installation characterized by equipment, materials, and operations involving hazards that when identified require methods to reduce or eliminate them.  Thus, by cross-series comparison we have applied the grading criteria from the PCS for the Fire Protection and Prevention Series, GS-0081, to evaluate the grade of this position. 

Grade determination

The PCS for positions in the GS-0081 series is divided into two parts: Part I consists of three sections used to grade fire chief and supervisory and lead firefighter positions.  Part II contains grade level criteria for nonsupervisory firefighter and fire protection inspector positions, GS-03 through GS-09.  We have applied Part II to evaluate the appellant’s position, as his principal duties and responsibilities are comparable to fire protection inspector positions involved in conducting inspections of a variety of buildings and structures to identify equipment, materials, operations, activities and conditions having potential to result in fires.  The standard provides descriptions of the duties typically performed by fire protection inspectors at each grade level.

At the GS-07 level, fire protection inspectors are responsible for areas of an installation characterized by equipment, materials, and operations involving hazards that are difficult to recognize and, once identified, require advanced, sometimes innovative, methods to reduce or eliminate them.  For example, they deal with hazards in large shops engaged in industrial or maintenance, overhaul and repair activities; active piers servicing several ships; and industrial shops containing and storing hazardous and flammable materials.  They adapt accepted fire protection techniques for application to potential hazards in highly specialized and technical operations.  They must be especially alert to new or unusual types of combustibles or other hazardous materials and recognize conditions of high fire expectancy and severity.  When these are noted, GS-7 inspectors question operating personnel as to their identification.  They search technical manuals, fire codes, or trade reference books to ascertain the fire characteristics.  They determine measures to reduce or eliminate the potential for fire or explosion.  Many of the recommendations made by inspectors at this level are controversial in terms of their effect on the time and operating requirement of the programs and projects involved.  Inspectors are expected to maintain relationships with operating officials such that only difficult or controversial cases need to be referred to the supervisor. 

In addition to those discussed above the following are some duties and responsibilities of Fire Protection Inspectors, GS-07:  (1) Reviews plans for new construction and alternation and extension of existing structures.  Recommends changes and additions to ensure compliance with fire protection and prevention requirements; (2) Inspects and corrects deficiencies in a variety of fixed fire protection systems, many of which are complex and/or designed for the specific operations and hazards.  Examples include:  carbon dioxide cascade systems, halon total flood systems, heat rise detection systems, and interlock systems; (3) Maintains thorough familiarity with the layout and contents of buildings, location of fire protection systems, and other similar characteristics of the installation; (4) Knows the recognized standards covering (a) fire prevention techniques and procedures, (b) agency and installation manuals, rules, and regulations; and (c) local, State, and Federal fire prevention ordinances and building codes; (5)  Occasionally participates with fire prevention or safety engineers in studying fire prevention problems; (6) Adapts standard fire prevention practices and procedures to local requirement, and (7) Uses tact and firmness in dealing with all levels of management in gaining acceptance of good fire prevention practices. 

At the GS-08 level, in addition to the fire protection inspector duties and responsibilities identified at the GS-07 level, fire protection inspectors conduct an information program and secure client involvement in fire prevention, detection, and suppression.  They emphasize fire prevention topics, develop prevention messages from actual fire incidents, and interact with a wide variety of employees and others in all aspects of fire prevention.  They coordinate established fire watch programs with designated building, facility, or installation program representatives (e.g., fire marshals) and teach school children about home fire prevention and emergency procedures.  They develop materials, provide situational and classroom training in installation fire prevention activities, and address a variety of client groups in fire program methods and goals.

The appellant’s position meets the GS-07 level.  The installations inspected by the appellant consist of large shops engaged in industrial, maintenance and repair operations (e.g., repair of 18-wheelers and flatbed trucks), and carpenter shops susceptible to fire and/or other hazards.  Activities require the use, storage and/or movement of hazardous materials (e.g., corrosives, flammable liquids).  Installation functions are also engaged in shipbreaking operations for Navy inventory, crane services for removing materials from vessels or other structures, and longshoreman activities.  Thus, similar to fire protection inspector positions at this level, the appellant is responsible for inspecting DLA Distribution Norfolk sites (including Portsmouth site) facilities characterized by equipment, materials, and operations involving safety and health hazards, some difficult to recognize and conditions of various severities that once identified require applying a range of  hazard abatement methods which may include innovative prevention methods (based on the degree of risk posed by the hazard) to eliminate or reduce imminent danger situations.  For instance, recommending using alternative materials as secondary safeguarding measures to create a vertical structure used as a shelving restraint to prevent materials from falling and causing injury.  Furthermore, the appellant conducts investigation of mishaps.  Severity of mishaps range from a minor injury or illness resulting in lost time of less than one lost-work day, or medical treatment in excess of first aid, or a loss of consciousness to a serious mishap resulting in a fatality or permanent disability or extensive costs of damages to government property.  Comparable to the GS-07 level, the appellant adapts hazard reduction and prevention techniques to eliminate or reduce imminent-danger situations.  For instance, he may withdraw exposed personnel from hazards, or “lock and tag” unsafe equipment (e.g., carriage cutting handle not returning properly) until the hazard has been controlled to a level below that of imminent danger.  Also, like this level, he is alert to new or unusual types of hazardous materials and recognizes safety and health hazards and severity.  For instance, in the case of peeling paint on a wall structure in a controlled industrial area, the appellant recognized the potential for a hazardous material, and recommended that a fully qualified and properly equipped personnel test the paint for lead.  Also, similar to duties performed by GS-07 fire protection inspectors, the appellant reviews contractor construction, alteration, or renovation of buildings and advises contractors of safety hazard reduction and preventive requirements that must be met.  Comparable to this level the appellant maintains familiarity with the layouts and contents of buildings and warehouses (e.g., supplies, chemicals), and other similar characteristics of the Portsmouth and DLA Distribution Norfolk installations such as non-air conditioned buildings, high hazard areas, and surrounding loading bays. 

Like the GS-07 level, the appellant is knowledgeable of recognized safety standards including occupational safety and health prevention methods and controls (i.e., abatement and hazard reduction methods), Department of Defense and DLA OSH Program Instructions, DLA Distribution Norfolk Safety Manual, and OSHA general industry standards and regulations.  He also occasionally participates in inspections with other safety personnel in hazard prevention problems.  For instance, after participating in an Industrial Hygienist Noise Survey, he assisted the Safety Manager in researching appropriate noise support needed by employees exposed to high levels of noise.  He also participates in OSHA and/or EPA inspections or investigations documenting and taking photographs of hazards identified.  Further, he adapts hazard prevention methods and techniques to local requirements.  He does this by ensuring all interim controls for an alternate standard provide an equal or greater level of protection for employees thereby reducing the risk of injury.

The appellant’s position does not meet the GS-08 level.  While the appellant’s work involves elements of some activities performed at this level, such as: conducting training and briefing employees and others on safety hazards and preventive measures; interacting with a wide variety of employees and others in all aspects of  hazard prevention (i.e. supervisors, employees, contractors); and addressing hazard prevention activities and controls to a variety of groups (i.e., OSHA inspectors, industrial hygienist specialists, safety engineers), unlike the GS-08 level he does not have  primary responsibility for the development and implementation of the installation’s safety training program(s).  Our review disclosed that such responsibility is held by the appellant’s supervisor.  In contrast to the GS-08 level, the appellant does not determine which hazard prevention topics to emphasize and develop original training materials based on actual hazardous events occurred.  The training provided by the appellant is solely informal training given to reinforce safety practices (e.g., safety briefings), or presented to new installation supervisors and other installation personnel.  Thus, the appellant does not have the level of program responsibility or the depth of involvement in the educational/training development program representative of GS-08 fire inspectors. 

Summary

The appellant’s position is evaluated at the GS-07 level.

Decision

Based on our review, the appellant’s position is properly classified as Safety Technician, GS-0019-07.

 

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