Washington, DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
DLA Distribution Cherry Point
Defense Logistics Agency
Cherry Point, North Carolina
GS-2102-07 (Parenthetical Title at Agency Discretion)
Robert D. Hendler
Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
06/22/2016
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate which 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).
Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702. The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, must be followed in implementing the decision. If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented. The servicing human resources office must submit a compliance report containing the corrected position description and a Standard Form 50 showing the personnel action taken. The report must be submitted within 30 days from the effective date of the personnel action to the OPM Agency Compliance and Evaluation (ACE) Atlanta Office.
Introduction
On January 20, 2015, the U.S. Office of Personnel Management’s (OPM) Agency Compliance and Evaluation (ACE) Atlanta office accepted a classification appeal from Mr. Melvin A. Stigler. On March 2, 2015, we received the complete agency administrative report (AAR). The appellant’s position is currently classified as Traffic Management Specialist, GS-2130-11, and is located in the Continuing Government Activity (CGA), DLA Distribution Cherry Point (DDCN), Defense Logistics Agency (DLA), in Cherry Point, North Carolina. The appellant believes his position should be classified at the GS-12 grade level. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
Background
At the conclusion of A-76 competition in 2001, the agency determined that DDCN wholesale operations would be outsourced and performed by a contractor. Thus, the DDCN is considered a “hybrid DLA distribution site,” since the wholesale side part of the site is government-owned but contractor-operated, and the retail side is government-owned and government-operated. At the time this appeal was received, the wholesale side of the organization was under the management of General Commodities Warehouse and Distribution Company (GENCO), a third party logistics (3PL) company. The current Contractor is Accent Controls, Inc. (ACI), referred to by the agency as their Service Provider (SP). The appellant believes his contractor oversight duties, which he describes as those of a Contracting Officer’s Technical Representative (COTR), have not been considered in the classification of his position. The appellant’s position description (PD) was under intermittent discussion between the appellant, his supervisor, and the servicing classifier from September 2012 through July 2013. A review of the appellant’s position was completed by DLA Human Resources Services, New Cumberland (DHRS-N), in July 2013, resulting in updates to the duties described in the PD with no change in the classification of the position. Disagreeing with the results, the appellant subsequently filed this appeal with OPM.
General Issues
The appellant makes various statements about his agency’s review and evaluation of his position and compares his position to a Supervisory Traffic Management Specialist, GS-2130-12, announced for recruitment by his organization at a DLA Distribution (HQ) location. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position. By law, we must classify positions solely by comparing their current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107 and 5112). Since comparison to PCSs is the exclusive method for classifying positions, we cannot compare the appellant’s position to others, which may or may not be properly classified, as a basis for deciding this appeal. Because our decision sets aside any previous agency decisions, the appellant’s concerns regarding his agency’s classification review process are not germane to this decision.
The appellant also believes the amount of his responsibilities (i.e., designations as Transportation Officer, Ordering and Certifying Officer) increase the amount of work he performs, and thus should be considered for purposes of evaluating the grade of his position. However, volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook, chapter 5).
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 position description (PD). This decision is based on the work currently assigned and performed by the appellant.
The appellant and his former first-level supervisor certified to the accuracy of the appellant’s PD of record (number H191290). However, during the interview with his former first-level supervisor (now his second-level supervisor), the supervisor pointed out discrepancies and explained that due to contractor involvement at the site, the appellant does not perform the full range of traffic management duties as described in the PD of record. Similarly, the appellant’s current supervisor asserted the PD is written for a position in a fully government-run activity and does not clearly reflect the duties for a contracted site.
Our review disclosed the appellant’s PD of record is not accurate in that it describes duties the appellant either does not perform or overstates the level of knowledge required and actually used by him. Specifically, and as explained later in this decision, the appellant is not involved in the development of general and detailed functional requirements and policies for transportation/traffic management programs and operations. He does not interpret and implement new directives resulting from additions to, or changes in, national or agency policies and programs, or identify deficiencies in established supply programs. Also, contrary to what is indicated in the appellant’s PD, he no longer serves as Certifying Officer (CO) for transportation transactions. As of May 2015, this designation was transferred to the appellant’s supervisor to comply with Defense Transportation Regulations (DTR) as to who may hold such designation. He also does not receive or review computer program changes related to the automated billing system or resolve problems resulting from the application of changes. Furthermore, the PD describes several duties performed by personnel at the Defense Distribution Center (DDC) contracting, policy and operations divisions. For instance, the appellant does not prepare Traffic Management solicitations for submission to the Military Traffic Management Command (MTMC) to meet depot requirements. He also does not participate in panels of experts to determine best value as it applies to carrier bids to the solicitations, or arrange pre-award meetings with carriers to lay out specific needs under pending Guaranteed Traffic/Tailored Transportation Contract (GT/ TTC) awards. He does not develop methods for measuring performance, efficiency, and effectiveness of depot operations, and does not establish requirement baselines for the outputs performed by the SP. Further, the appellant’s supervisor indicated he is not aware if the appellant continues to conduct carrier meetings on a regular basis to monitor and discuss performance issues and services.
Our fact finding also revealed that certain duties described in the appellant’s PD of record are assigned to the Contracting Officer Representative (COR) onsite. For instance, the COR is responsible for identifying specific requirements the SP’s output must meet as contained in the Request for Proposal (RFP), and analyzes SP output to determine compliance based on the surveillance reports provided by the appellant. Moreover, the appellant does not identify workload requirements, validate monthly workload accomplishments, validate SP data requirements for technical requirements with the contract of Most Efficient Organization Letter of Obligation (MEO LoO), or write proposed modifications for incorporation into the contract or MEO LoO as necessary to accommodate mission changes.
Position information
DDCN provides wholesale and retail support to the 2nd Marine Air Wing, numerous Marine Aviation Logistics Squadrons, Marine Corps Air Station (MCAS) Cherry Point (the largest Marine Air Station in the world), and the Naval Air Systems Command’s Fleet Readiness Center (FRC, East Cherry Point). The Center provides support for all Marine Corps deployments, exercises and mobilizations, as well as rigging, loading, blocking and bracing, and transportation services for essential air and ground support equipment, weapons and vehicles. It also supplies all of the preservation and packing, hazardous material packaging, central receiving, rigging operations, ordnance transportation certification and transportation management office requirements for all units in the local area.
The appellant’s position is located in the wholesale side under the CGA, which consists of approximately 19 Federal employees. The primary mission of the CGA is to ensure that contractor provided services as defined by the Performance Work Statements (PWS) meet specified quality standards in accordance with the Quality Assurance Surveillance Plan (QASP). The QASP documents a program undertaken by the Government to provide a measure of quality and timeliness of products and services performed by the contractor. The QASP contains measurable inspection and acceptance criteria corresponding to the performance standards contained in the contract. The CGA also serves as the point of contact between DLA Distribution and the SP.
The appellant’s position is designated by the DDCN Director as Transportation Officer (TO). In accordance with the DTR, as TO the appellant appoints one or more contractor personnel as Transportation Agents (TA) to act as agents to the U.S. Government and execute all aspects of the shipments initiated from the DLA DDCN. However, because the site is contractor-operated, the appellant does not exercise any supervision or control over the contractor’s employees performing these services. The contractor, not the Government, is responsible for management and quality control actions to meet the terms of the contract. The contractor employees are accountable solely to the contractor who, in turn, is responsible to the Government. The contractor’s primary interaction with the Government is through the onsite COR. The role of the Government is quality assurance to ensure contract standards are achieved, thus the appellant serves as a Quality Assurance Evaluator (QAE) and is responsible for conducting performance and quality inspections (i.e., surveillance reviews) pertaining to the quality and quantity of transportation services provided under contract. The results and observations of his reviews regarding compliance and/or noncompliance are used by the onsite COR to ensure contract standards are being achieved, and by the Contracting Officer located at DLA Distribution HQ to evaluate and make decisions regarding contractor operations.
The appellant is also the designated Ordering Officer (OO) for various DLA Surface Small Package Contracts and the Defense Transportation Coordination Initiative (DTCI) contract. The DTCI is a DOD program that is based on a commercial partnership with a 3PL provider, in this case ACI, which is contracted by the Government to manage a portion of DOD’s CONUS freight. As the OO, the appellant performs prepayment audits of all carrier invoices/electronic bills (e-Bills) before authorizing payment under the Third Party Payment System (TPPS), Syncada (i.e. PowerTrack). We note that at the time this appeal was submitted the appellant was also Certifying Officer (CO). The CO is responsible for certifying amounts shown on the monthly summary invoices as accurate and correct. However, as previously mentioned, this designation per the DTR must be assigned to a Federal supervisor; thus, the Deputy Director currently holds the designation.
In addition, the appellant refers to the following duties listed in the DTR 4500.9-R, Individual Missions, Roles and Responsibilities, Section X, Transportation Officer, as duties inherent in his TO designation as follows:
1. Provide efficient, responsive, and quality transportation services within the assigned AOR and ensure compliance with governing laws, directives, systems or programs, and regulations for cargo, passenger, personal property, and unit moves.
2. Provide technical direction, management, and evaluation of the traffic management and unit movement aspects of the DOD transportation movement program on a worldwide basis, subject to the overall guidance, policies, and programs established by USTRANSCOM, the CFR, and DOD Components.
a. Prepare and edit shipment documentation to ensure quality electronic data and timely submission to support total movement business processes IAW DTR Part II Chapter 2, Table 202-2, Timeliness Evaluation Criteria, for higher-level visibility, force systems, and downline stations.
b. Support contingency, mobility, natural disaster, and humanitarian relief requirements.
c. Provide contact information for the servicing TO, as well as training on transportation procedures, documentation, clearance, and the CBP requirements to Unit Mobility Officers (UMOs)/Noncommissioned Officers and Government Purchase Card holders with overseas shipping requirements in support of contingencies.
3. Assist the DTMO COR with monitoring and reporting contractor performance under DOD CTO contracts.
4. Act as a COR, alternate COR, or ordering officer when CTOs and other related traffic management functions are served under contracts.
5. Appoint one or more military members, civilian employees, or contractor personnel as a Transportation Agent (TA) to assist the TO in his or her responsibilities. This may be accomplished by letter, which is to be retained in the transportation office. Service-unique procedures may require the TOs to request that TAs be appointed by their CDRs. Contractor personnel will not be appointed to perform any function involving the obligation or expenditure of Government funds. This also applies to tenant units.
6. Seek Antiterrorism/Force Protection (AT/FP) advice from the installation Force Protection Working Group
7. Include AT/FP considerations in local transportation publications and procedures.
8. Plan, prepare, and document shipments IAW this regulation.
9. For shipments requiring delivery after hours, weekends, and on holidays, obtain the origin and destination POC and a commercial telephone number
10. Use “Best Value” in determining carrier selection, as he/she is required to do. TOs are not authorized to use equalization methods to determine a carrier for shipments originating from their installation.
11. Prior to shipment release, coordinate with the receiving site (e.g., water port, DLA Depot, aerial port), TO, or POC, when there is a surge of freight (defined as five or more truckloads) or when special materials handling equipment (not otherwise identified in the Transportation Facility Guide) is required.
Our fact finding revealed and was confirmed by his supervisor that while these responsibilities fall on the appellant as designated TO, except for duty # 5, they are actually performed by contractor transportation personnel (i.e., TAs). However, through the appellant’s quality assurance work he is responsible for ensuring that the TAs are performing these duties in accordance with DTR and other Federal regulations. For instance, the TAs will sign the Bill of Lading (BOL) on the appellant’s behalf. Regarding duty #4, in the appellant’s response to the AAR he asserts that according to information provided in the Defense Acquisition University website, there are different phrases to describe a Contracting Officer’s Representative, including QAE and COTR, because the terms are interchangeable. However, management states that the appellant is not a designated COTR, nor is one necessary for their site. The TAs seek technical direction primarily from their immediate supervisors, and their primary point of contact for any problems encountered is the onsite COR. If requested or if a special situation is presented to the appellant, as TO he would provide technical guidance and direction. For instance, the TO may be advised when a shipment is undeliverable because of natural disaster, labor dispute, or other such condition, and he will coordinate with the shipping or receiving authority for disposition. In addition, management also explained the TO designation could be vested on any Federal employee. Since the appellant is the only Federal employee with transportation knowledge, management designated him as the site TO. The record shows the appellant performs duty #2 via his work as a QAE and ensures that SP is performing the aforementioned duties in accordance with regulations.
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. In addition, to help decide the appeal we conducted separate telephone interviews with the appellant, his former supervisor, the Distribution Facilities Manager, GS-2030-14 (i.e., Director), his immediate supervisor, the Distribution Facilities Manager, GS-2030-14 (i.e. Deputy Director), and follow up requests for additional information from the appellant and his supervisors.
To clarify information in the record, we also conducted interviews with the Surveillance Lead (General Supply Specialist, GS-2001-12) located at DDCN, the Traffic Manager (GS-2130-13) formerly located at the Policy branch of DLA Distribution HQ (currently in a different position within DLA), and with the Chief, Transportation Officer (Supervisory Traffic Management Specialist, GS-2130-14) from the Transportation Operations branch also at DLA Distribution HQ.
Series, title, and standard determination
The agency has placed the appellant’s position in the Traffic Management Series, GS-2130, titling it Traffic Management Specialist and evaluating it by application of the Traffic Management Series, GS-2130 PCS. Although the appellant does not dispute these determinations, he asserts the GS-2130 PCS does not address his oversight responsibilities over the contractor.
In the appellant’s request to OPM, he asserts his position is an “interdisciplinary or mixed duty position” because he serves as a Traffic Management Specialist and a COTR and conducts technical inspections of the contractor at least 25 percent of his time. As discussed in the Introduction, for a position to be considered interdisciplinary it must be a professional position, for example, in the mathematical, scientific or engineering disciplines, involving duties and responsibilities closely related to more than one professional occupation, with the final classification determined by the qualifications of the person to fill it. The appellant’s position is not in a professional series and thus cannot be considered or treated as an interdisciplinary position.
The appellant also asserts that the Traffic Management Series, GS-2130, does not address what he describes as “contractual oversight responsibilities.” In his response to the AAR, he states that compliance responsibilities should not be considered using the GS-2130 series but rather the “GS-1100 series,” and refers to the Administrative Analysis Grade Evaluation Guide (AAGEG). We note there is no GS-1100 series but rather a Business and Industry Group, GS-1100, which encompasses different occupational series for work covered by that group. The General Business and Industry Series, GS-1101, is the general occupational series for positions properly assigned to the Business and Industry Group, GS-1100, when no established occupational series is appropriate. The appellant does not perform work descriptive of the GS-1101 series in that he does not perform: (1) any combination of work characteristic of two or more series in the group, where no one type of work is series controlling and where the combination is not specifically included in another series; or (2) other work properly classified in this group for which no other series has been provided. The AAGEG provides grade level criteria for non-supervisory staff administrative analytical, planning, and evaluative work, at grade GS-9 and above. However, this guide is used to evaluate work that is administrative in nature and does not require specialized subject-matter knowledge and skills. Therefore, the appellant’s position cannot be placed in the GS-1101 series or evaluated using the AAGEG.
It appears the appellant may be referring to the Contracting Series, GS-1102, which includes positions that manage, supervise, perform, or develop policies and procedures for professional work involving the procurement of supplies, services, construction, or research and development using formal advertising or negotiation procedures; the evaluation of contract price proposals; and the administration or termination and close out of contracts. However, the appellant does not perform work descriptive of this series in that he does not perform technical contract administration work involving the exercise of the full range of knowledge required by that series. Rather, he conducts surveillance reviews to ensure the contractor is meeting the performance standards contained in the contract based on his subject-matter knowledge of transportation regulations, practices, and procedures. As discussed in the series determination section below, the appellant’s contractor quality assurance/oversight responsibilities are appropriately addressed within the context of the Transportation Clerk and Assistant Series, GS-2102.
The Traffic Management Series, GS-2130, covers positions that involve (1) performing, administering, or supervising technical and analytical work concerned with planning, development, and execution of traffic policies and programs; or (2) directing and managing programs to obtain the economical and efficient transportation of freight, personal property, and/or passengers. Classification guidance in the Introduction and The Classifier’s Handbook describe the distinctions between positions properly classified in one-grade interval support series and two grade interval administrative series.
Support work usually involves proficiency in one or more functional areas or in certain limited phases of a specified program. Normally a support position can be identified with the mission of a particular organization or program. The work usually does not require knowledge of the interrelationships among functional areas or organizations. Employees who perform support work follow established methods and procedures. They may occasionally develop work plans or recommend new procedures, but these typically are related to the employee's individual assignment or immediate work unit. Support work can be performed based on a practical knowledge of the purpose, operation, procedures, techniques, and guidelines of the specific program area or functional assignment. Support personnel typically learn to do the work on the job and may also attend specific training courses related to their work.
Administrative work, on the other hand, primarily requires a high order of analytical ability 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 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.
The appellant’s position does not meet the GS-2130 series as defined above. Positions in this series primarily require knowledge of Federal traffic management principles and policies; transportation industry operations, practices, and capabilities; special handling or movement requirements associated with freight, passengers, or other transportation operations; and the relationship of traffic management to other agency or organizational programs and functions. The record shows this is not descriptive of the appellant’s work. Unlike the appellant’s position, traffic management specialists are also not generally concerned with the transportation of single shipments. Rather, they act in a staff capacity to, for instance, advise on traffic management policies, perform studies covering specific functional areas, and assess the impact of the overall traffic management program on the agency’s mission. Such responsibilities are assigned to personnel at higher levels in the Transportation Policy branch at DLA Distribution HQ. Furthermore, at the local level, the Director of the distribution center is responsible for the overall management of the distribution mission and its programs. Although the appellant may recommend small parcel carrier selection based on “best value” determinations to meet the mission needs of the specific site, such task does not meet the scope of the broader general traffic management studies performed by specialists. His duties in that regard are limited to providing factual data obtained from different systems such as on-time pickup and delivery percentage, lost or damaged cargo percentage, provider availability and other service factors to suggest removing a small parcel carrier from use at a site, from all use, or from any selected lanes or modes. In contrast, positions classified in the GS-2130 series use this information negotiate with carriers on a much broader level and with greater authority to establish agreements for transportation services for the installation.
The appellant’s duties do not require that he perform the significantly broader assignments of GS-2130 positions, where the employee is concerned with advising traffic managers on overall transportation program requirements, and where analysis and evaluation techniques are used to assess the general efficiency and economy of the installation’s operating transportation program as a whole. We found no indication the appellant is involved with the transportation program to the extent that he develops transportation plans to support the overall transportation programs at the installation. The record shows these tasks are performed by staff specialists of the transportation policy and operation branches.
To decide the proper series we must also consider the characteristics and requirements of the work as well as management's intent for establishing the position. Each position performs part of the mission of the organization in which they are located. Because the wholesale side is not government-run, DLA Distribution maintains and staffs the CGA onsite. As previously stated, the primary responsibility of the CGA is to oversee the contractor-provided performance data to the CO at DLA Distribution HQ. In support of this mission, the purpose of the appellant’s position and management intent for establishing the position is to provide quality assurance in the area of transportation services and processes. We find the paramount knowledge required by the position is practical knowledge of the regulations and methods governing traffic management or transportation programs to conduct performance reviews and quality inspections of services provided under contract. Much of this knowledge is obtained from functional area knowledge (i.e., freight) or through review of agency-developed materials (e.g., DTR). Thus, the work assigned to and performed by the appellant does not require knowledge of Federal traffic management principles and policies and the relationship of traffic management to other agency or organizational programs and functions.
As indicated by the appellant’s supervisor, an employee in the appellant’s position would require some degree of transportation knowledge that could be gained from job experience, and the employee could confer with appropriate subject-matter experts located in the transportation policy and operations branches DLA Distribution HQ for specific operational guidance and interpretation of policies. Recruitment sources as described by the appellant’s supervisor would include individuals who possess oral, teamwork and analytical skills. For instance, the analyses performed by the appellant primarily involve reviewing contractor workflow to ensure it is performed in accordance with operational cargo movement guidance as stated in the DTR. Although the appellant’s work affects the adequacy of the evaluation of the contractor, the CO analyzes quality assurance findings and results, and takes action to suspend or remove if a contractor or carrier fails to perform satisfactorily. The appellant’s analysis of specific freight situations is based on information that is readily apparent and for which established methods and procedures can be applied. These types of assignments do not require a high order of analytical ability or problem solving techniques typical of administrative positions appropriately classified in two-grade interval series, such as the GS-2130 series.
We find that the appellant’s position is best classified in the Transportation Clerk and Assistant Series, GS-2102, which includes one-grade interval positions involving supervising or performing work to arrange transportation for or perform other actions in connection with the movement of freight, passengers, or personal property by Government or commercial means. This series also includes other transportation support work not covered specifically by another one-grade interval series in the Transportation Group (e.g. fleet management, safety or regulatory program support, quality control and inspection, carrier performance evaluation, or transportation report analysis and preparation). The work requires a practical knowledge of the regulations and methods governing traffic management or transportation programs. As discussed in the Occupational Information section of the GS-2102 PCS, freight shipment work involves duties such as securing carriers to arrange for pickup, delivery, and storage of shipments; identifying the mode or combination of modes, types of special equipment, and services required for shipments; and advising customers of inadequacies or inaccuracies in shipping requests and related documentation.
Among other responsibilities, the following tasks are common to many transportation clerk and assistant functions: (1) preparing and issuing paperwork to initiate, document, or complete transportation actions; responding to customer complaints or problems involving delays, loss, or damage; (2) reconciling and certifying bills related to transportation actions; (3) analyzing,services, implement the QASP, and perform process analysis work focused on risk mitigation to provide contractor performance data to the CO at DLA Distribution HQ. In support of this mission, the purpose of the appellant’s position and management intent for establishing the position is to provide quality assurance in the area of transportation services and processes. We find the paramount knowledge required by the position is practical knowledge of the regulations and methods governing traffic management or transportation programs to conduct performance reviews and quality inspections of services provided under contract. Much of this knowledge is obtained from functional area knowledge (i.e., freight) or through review of agency-developed materials (e.g., DTR). Thus, the work assigned to and performed by the appellant does not require knowledge of Federal traffic management principles and policies and the relationship of traffic management to other agency or organizational programs and functions.
As indicated by the appellant’s supervisor, an employee in the appellant’s position would require some degree of transportation knowledge that could be gained from job experience, and the employee could confer with appropriate subject-matter experts located in the transportation policy and operations branches DLA Distribution HQ for specific operational guidance and interpretation of policies. Recruitment sources as described by the appellant’s supervisor would include individuals who possess oral, teamwork and analytical skills. For instance, the analyses performed by the appellant primarily involve reviewing contractor workflow to ensure it is performed in accordance with operational cargo movement guidance as stated in the DTR. Although the appellant’s work affects the adequacy of the evaluation of the contractor, the CO analyzes quality assurance findings and results, and takes action to suspend or remove if a contractor or carrier fails to perform satisfactorily. The appellant’s analysis of specific freight situations is based on information that is readily apparent and for which established methods and procedures can be applied. These types of assignments do not require a high order of analytical ability or problem solving techniques typical of administrative positions appropriately classified in two-grade interval series, such as the GS-2130 series.
We find that the appellant’s position is best classified in the Transportation Clerk and Assistant Series, GS-2102, which includes one-grade interval positions involving supervising or performing work to arrange transportation for or perform other actions in connection with the movement of freight, passengers, or personal property by Government or commercial means. This series also includes other transportation support work not covered specifically by another one-grade interval series in the Transportation Group (e.g. fleet management, safety or regulatory program support, quality control and inspection, carrier performance evaluation, or transportation report analysis and preparation). The work requires a practical knowledge of the regulations and methods governing traffic management or transportation programs. As discussed in the Occupational Information section of the GS-2102 PCS, freight shipment work involves duties such as securing carriers to arrange for pickup, delivery, and storage of shipments; identifying the mode or combination of modes, types of special equipment, and services required for shipments; and advising customers of inadequacies or inaccuracies in shipping requests and related documentation.
Among other responsibilities, the following tasks are common to many transportation clerk and assistant functions: (1) preparing and issuing paperwork to initiate, document, or complete transportation actions; responding to customer complaints or problems involving delays, loss, or damage; (2) reconciling and certifying bills related to transportation actions; (3) analyzing, reviewing, and preparing reports or correcting computerized error listings; and (4) conducting performance reviews and quality inspections of services provided under contract. Because these duties and responsibilities closely match those of the appealed position, it is properly classified to the Transportation Clerk and Assistant Series, GS‑2102. The authorized title for positions in grades GS-5 and above is Transportation Assistant. Transportation support duties are varied and, in some cases, highly specialized. For ease of recruitment, promotion, reduction-in-force, or other purposes, agencies may add parenthetical titles, for example, (Freight), (Passenger), (Personal Property), or (Fleet Management), when further distinctions in the work are necessary. These parenthetical titles are suggestions only, and their use is at agency discretion.
Grade determination
The GS-2102 PCS is written in the Factor Evaluation System (FES) format, which employs nine factors. Each factor is evaluated separately and is assigned a point value consistent with factor-level definitions described in the PCS. The total points are converted to a grade by use of a grade conversion table. Under the FES, each factor-level description describes the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor- level description in any significant aspect, it must be credited at a lower level unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some aspects and still not be credited at a higher level. Our evaluation with respect to the nine FES factors follows.
Factor 1, Knowledge required by the position
This factor measures the nature and extent of information or facts which the employee must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, theories, principles, and ideas) and the nature and extent of skills needed to apply that knowledge.
At Level 1-4, the highest level described for this factor in the PCS, the work requires knowledge and application of an extensive body of transportation regulations, methods, and practices to perform a wide variety of interrelated or nonstandard transportation support assignments and resolve a wide range of problems. Illustrative of knowledge at this level is performing work that requires knowledge of transportation regulations that relate to the movement of a wide range of specialized shipments. For example, this includes assignments regularly involving the movement of oversized, heavy haul, hazardous, and security risk items. Moves of this nature require extensive practical knowledge of the carrier industry, specialized shipment needs, and terminal or storage capabilities to identify the appropriate shipping method, carrier equipment, services, and special handling required. Other work at this level requires knowledge of the requirements of various transportation regulations or operations to monitor or report on carrier compliance with contract terms, safety provisions, or other transportation programs. This work typically involves knowledge of report preparation and skill in analyzing factual information to document deficiencies or areas of noncompliance and make recommendations.
Illustrative of freight work at Level 1-4, employees review customer requests for various shipments of hazardous, temperature sensitive, fragile, oversized, heavy haul, urgent, or other freight not covered by standing route orders. They identify the need for special packing, loading, or handling, and coordinate arrangements for these needs with other activity personnel as well as with carriers. For example, employees review the nature, size, and weight of items to determine if open-top conveyance for loading by crane, temperature controlled equipment, special packaging or containerization, or security escort service is needed. They arrange for complete routings to handle shipments with urgent delivery dates, or shipments to isolated origin or destination points that cannot be transported through normal channels. They prepare complete in-route instructions for material being shipped. For example, they provide information on shipment size, shape, weight, packing requirements, and compatibility for consolidation. They also indicate whether the material is knocked down or set up, skidded, palletized, nested, loose, packaged in barrels, boxes, or crates, and whether it is new or used.
The appellant’s position meets but does not exceed Level 1-4. Like this level, the work requires that the appellant use knowledge and application of an extensive body of transportation regulations, methods, and practices when providing oversight by conducting quality assurance evaluations of a variety of freight transportation functions performed by the SP, e.g., shipment, document processing, carrier dispatch, and special packing requirement, in order to evaluate whether the SP is effectively and efficiently complying with DTR and other transportation requirements. For instance, the appellant performs quality assurance evaluations relating to release of shipments containing classified materials to ensure that TAs monitored all receipts until the classified material was received in accordance with Defense Distribution Center Standard Operating Procedures for Processing and Handling Classified Material. He ensures that TAs coordinate with the consignee to ensure the destination can receive the type, quantity, and classification of material, and confirms the shipment can be delivered prior to destination closure and that a Report of Shipment (REPSHIP) has been received prior to releasing the shipment. The REPSHIP documents and confirms this coordination has taken place. If the SP does not get advance acknowledgement prior to shipping the material, the SP would be found nonconforming to this requirement. The appellant verifies that this process was completed by using a random sampling method, runs queries from the Query Management Facility (QMF) report to review reports of all monthly classified material shipped, and confirms that RESHIPS were received.
Also, like Level 1-4, the appellant uses extensive practical knowledge of the carrier industry, specialized shipment needs, and terminal or storage capabilities to identify the appropriate shipping method, carrier equipment, services, and special handling required. When conducting quality assurance evaluations, the appellant must ensure that various activities were performed by the SP to conform to the requirements of the DTR and DOD Arms, Ammunitions and Explosive (AA&E) Safety Standards in regards to shipments of hazardous and AA&E materials. For instance, he verifies that vehicle inspections were conducted; hazardous packing was properly marked, packaged, and labeled for shipping in accordance with Military Standards for marking shipments; all required signatures are on a Bill of Lading (BOL) and/or manifest; and bracing and cable/bolt belts were applied to conveyance and that the carrier contained proper placards before it was released.
Comparable to Level 1-4, he ensures all paperwork associated with transportation invoices for shipments is accurate, reconciling problems as needed when performing prepayment audits of all carrier invoices and e-Bills before authorizing payment. He is responsible for approving payments only for the amount that is determined to be the Government’s responsibility to pay.
He does this by ensuring all invoices contain a Transportation Accounting Code (TAC) for the transaction before approving payment in Syncada. He will not accept a shipment if the shipping document does not contain a TAC. If a TAC is not identified in the shipment document he will use a query TAC function to retrieve the Transportation Global Edit Table (TGET) to determine which TAC to apply. Query results allow him to view the description and usage for the TAC code. The Defense Finance and Accounting Service (DFAS) personnel will then process the bill/invoice and collect against the valid TAC provided. Further, he resolves shipment related problems by analyzing factual information in order to document carrier deficiencies and identify shipment problems, and traces data entries to reconcile payment processing errors.
This factor is evaluated at Level 1-4 and 550 points are assigned.
Factor 2, Supervisory controls
This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the individual employee’s responsibilities, and review of completed assignments.
At Level 2-3, the highest level described for this factor in the PCS, the supervisor outlines objectives, priorities, and deadlines and provides guidance on dealing with unusually involved or one-of-a-kind situations. Employees independently plan and carry out the successive steps to complete transportation support duties and use accepted practices to resolve problems and deviations which may result because of the specialized nature of the problems, the existence of various conflicting documentation, the lack of documentation or information available, or other conditions. The supervisor reviews completed work for technical soundness, appropriateness, and conformity to policy and requirements, which in some situations may only be after the fact in response to complaints from customers. The methods the employee uses to complete the assignments usually are not reviewed in detail.
The position meets but does not exceed Level 2-3. Like this level, the appellant independently plans and carries out all transportation related duties, applying accepted practices, current regulations, and his extensive freight management experience to resolve most problems and deviations. For instance, he reconciles bills or verifies costs when documentation is unclear or inaccurate to determine the propriety of the rates charged. Like this level, the supervisor may assist with controversial problems if necessary. Furthermore, when needed DLA Distribution staff will provide guidance for unusual problems and/or difficult interpretations of policy. Similar to Level 2-3, although the appellant's supervisor does not review in detail the methods used by the appellant to complete his responsibilities, he is responsible for determining whether the appellant’s performance meets defined goals. This includes verifying that the appellant submits his quality assurance evaluation findings as annotated on the SP Surveillance Report into the Quality Management Scheduling and Inspection Tool (QMSIT) to report on performance of the SP in a timely manner. Like this level, the appellant’s work is reviewed for completeness, appropriateness and conformity to transportation policy requirements.
This factor is evaluated at Level 2-3 and 275 points are assigned.
Factor 3, Guidelines
This factor covers the nature of guidelines and the judgment needed to apply them.
At Level 3-3, the highest level described for this factor in the PCS, guidelines are similar to Level 3-2 in that there are numerous guidelines requiring judgment to identify and select the appropriate reference and procedure. However, at Level 3-3 guidelines are not completely applicable to many aspects of the work because of the problem solving or complicated nature of the assignments. Employees use judgment to interpret guidelines, adapt procedures, decide approaches, and resolve specific problems.
The position meets but does not exceed Level 3-3. The appellant uses a variety of transportation regulations such as the DTR, DLA policies, procedures and instructions, automated distribution systems manuals, applicable Government contracts such as the DTCI, tenders and agreements. He must also be familiar with aspects of Federal Acquisition Regulations to the extent they relate to transportation processes, charges, etc. In addition, in performing quality assurance duties he ensures the SP complies with applicable Federal (e.g., OSHA, EPA), State and other local laws and regulations, and meet requirements relating to the material and distribution services performed as stated in the Contractor’s PWS. However, these regulations and guides are not always completely applicable. For instance, the appellant uses judgment to decide on approaches to use to resolve difficult problems presented to him as designated TO. In that regard, he determines financial liability when Government property is lost, damaged or destroyed, requiring him to analyze the situation and interpret applicable guidelines to determine who should be found accountable. The appellant may also be advised a shipment is undeliverable due to a natural disaster, labor dispute, or other such conditions. In such cases, he uses judgment in adapting procedures to coordinate with the shipping or receiving authority for disposition of freight.
This factor is evaluated at Level 3-3 and 275 points are assigned.
Factor 4, Complexity
This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed; the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.
At Level 4-3, the highest level described for this factor in the PCS, the work involves performing one or more transportation support functions that require the use of different and unrelated procedures and methods. The use of different procedures may result because assignments received are relatively broad and varied; work methods are not completely standardized; or transactions are interrelated with other systems and often require extensive coordination with various, different personnel. Employees identify the nature of the request, problem, or issue, and determine the need for and obtain additional information through oral or written contacts and review of regulations and manuals. Employees may have to consider previous actions and understand how these actions differ from or are similar to the issue at hand before deciding on an approach. Employees make recommendations or take actions based on a case-by-case review of pertinent transportation regulations and documents.
The position meets but does not exceed Level 4-3. Like this level, the appellant’s work involves performing transportation support functions that are broad and varied and require the use of different and unrelated procedures and methods. He performs quality assurance over the contractor who provides traffic management support for other Federal activities, to include deployment support on request, in a manner that provides for the efficient, economical, on time delivery of requisitioned material to customers. He performs quality assurance over TAs who are responsible for selecting methods and modes of transportation, coordinating transportation arrangements, monitoring shipments and services, and diverting and arranging movement by alternate means when necessary. Comparable to Level 4-3, the appellant resolves individual problems of a procedural or factual nature by tracing, locating, and reviewing invoices and documentation (i.e., e-Bills, CBL) when reconciling bills and approving payments. Duties require the appellant to interpret and/or clarify transportation regulations and review publications and messages for changes in policy or procedures.
This factor is evaluated at Level 4-3 and 150 points are assigned.
Factor 5, Scope and effect
This factor covers the relationship between the nature of the work, i.e., the purpose, breadth, and depth of the assignment, and the effect of work products or services both within and outside the organization.
At Level 5-3, the highest level described for this factor in the PCS, the purpose of the work is to apply conventional practices to treat a variety of problems in transportation transactions. The employee treats problems encountered by applying established procedures. In some situations, the work results in recommendations, actions, or reports that affect the ability of serviced programs to conduct business adequately. In other work situations, the quality of the transportation advice and decisions may affect the operation of certain programs. In still other situations, the work may affect the physical well-being of persons, or it may affect substantial costs incurred by the agency or activity.
The position meets but does not exceed Level 5-3. Like this level, the appellant applies conventional practices and techniques to address a variety of problems associated with transportation transactions. These include conducting quality assurance evaluations and inspections for services provided under contract using established methods of surveillance (e.g., random sampling, one-hundred percent inspection), and approving bills related to transportation transactions by using standard practices of reconciliation to determine the propriety of rates charged or services performed. Similar to Level 5-3, his work affects the costs incurred by the installation in that when conducting pre-audits of carrier payments, he is monitoring carriers for compliance with service requirements. For instance, TOs are to ensure compliance in using “Best Value” to make recommendations of carrier selection or removal. The “Best Value” approach is based on determining factors such as quality of service, past performance, cost/price, claims experience, and ability to perform service within stated requirements in order to make recommendations on changes in carriers. This may affect the efficiency of operations and the adequacy of investigations into non-compliance with agreements and contracts or investigations.
Comparable to Level 5-3, the appellant’s work may also result in recommendations that affect the ability of serviced programs to conduct business adequately. For instance, the appellant made recommendations to improve the process for handling of Return of Repairable (RoR) Shipments coming from Canada so as to capture the amount of hours and costs associated with the handling of these types of shipments. Action was taken based on one of his recommendations, thus improving the process to effectively handle this service.
This factor is evaluated at Level 5-3 and150 points are assigned.
Factors 6 and 7, Personal contacts and Purpose of contacts
These factors include face-to-face contacts and telephone dialogue with persons not in the supervisory chain and pertain to the reasons the contacts are made. The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.
Personal contacts
At Level 2, the highest level described for this factor in the PCS, contacts are with: (1) employees in the immediate organizational unit or in closely related support units, and/or employees outside the organization or with members of the general public in very highly structured situations, and/or (2) with employees in the same agency, but outside the immediate organization and/or contacts with members of the general public in a moderately-structured setting. Contacts at this level may also be with employees in other agencies who are providing, requesting, or coordinating actions and information and with the general public in a structured setting, e.g., representatives of carrier companies, freight hauling companies, or commercial storage warehouses confirming information related to the transport and storage of items.
The position meets but does not exceed Level 2. The appellant’s primary contacts are with employees of his agency both within and outside his organization, such as CGA employees, ACI contracting personnel, staff specialists from DLA Distribution HQ, and individuals in other agencies who are providing, requesting, or coordinating actions and information and with the general public in a structured setting, e.g., representatives of commercial carrier companies and agents.
Purpose of contacts
At Level b, the highest level described for this factor in the PCS, the purpose of contacts is to plan and coordinate actions to prevent or correct errors, delays, or other complications from occurring.
The appellant’s position meets but does not exceed Level b. Like this level, he plans and coordinates actions with contractors and headquarters-level staff to preclude errors, delays, or other complications from occurring with transportation related activities. These include ensuring that SP Surveillance Reports findings are submitted through QMSIT to the CO at headquarters.
This factor is evaluated at Level 2b and 75 points are assigned
Factor 8, Physical demands
This factor covers the requirements and physical demands placed on the employee by the work assignment.
At Level 8-1, the work may require some physical effort, such as standing, walking, bending, or sitting. There are no special physical demands.
At Level 8-2, the work requires above average physical agility, such as regular and recurring periods of prolonged standing, bending, stretching, and lifting.
The appellant’s position meets Level 8-1. Comparable to this level, the appellant’s work is generally sedentary in nature and performed in an office setting. Although his quality assurance evaluation work may require him to go onsite to the depot, unlike Level 8-2 the work does not require above average physical agility, such as regular and recurring periods of prolonged standing, bending, stretching, and lifting typical of work performed at loading docks. The inspections performed by the appellant do not involve the physical demands described at Level 8-2. Instead, like Level 8-1, he stands or walks, with no special physical demands, when making onsite visits to evaluate the contractor’s performance at the time a process is performed. For instance, he could go onsite to observe that transportation personnel access the DTTS (BOL) screen, through the Intelligent Road/Rail Information Server (IRRIS), 20 minutes after releasing the shipment to verify that shipment information is resident in DTTS.
This factor is evaluated at Level 8-1 and 5 points are assigned.
Factor 9, Work environment
This factor considers the risk and discomfort in the employee’s physical surroundings or the nature of the work assigned and the safely regulations required.
At Level 9-1, the employee works primarily in an office setting involving everyday risks or discomforts. Normal safety precautions are adequate.
At Level 9-2, the employee works in areas with moderate risks or discomforts that require the use of special safety precautions. Employees may work in warehouses or loading docks and may have to exercise special care when working around moving parts, materials handling equipment, conveyors, or crates. In some situations, employees may be required to wear protective clothing or gear.
The appellant’s position meets Level 9-1. Like Level 9-1, the employee primarily works in an office setting and may go onsite, but only to perform quality assurance that requires observation of work processes performed by transportation personnel. Unlike Level 9-2, the appellant does not typically work in areas with moderate risks or discomforts that would require him to use special safety precautions or wear protective clothing.
This factor is evaluated at Level 9-1 and 5 points are assigned.
Summary
| Factor | Level | Points |
| 1. Knowledge Required by the Position | 1-4 | 550 |
| 2. Supervisory Controls | 2-3 | 275 |
| 3. Guidelines | 3-3 | 275 |
| 4. Complextiy | 4-3 | 150 |
| 5. Scope and Effect | 5-3 | 150 |
| 6. & 7. Personal Contacts and Purpose of Contacts | 2b | 75 |
| 8. Physical Demands | 8-1 | 5 |
| 9. Work Environment | 9-1 | 5 |
| Total | 1485 |
The total of 1485 points falls within the GS-7 range (1355-1600) on the grade conversion table provided in the standard.
Decision
The appellant’s position is properly classified as Transportation Assistant, GS-2102-7. Selection of a parenthetical title is at the discretion of the agency.