U.S. Office of Personnel Management
Office of Merit Systems Oversight and Effectiveness
Classification Appeals and FLSA Programs

Atlanta Oversight Division
75 Spring Street, SW., Suite 1018
Atlanta, GA 30303-3109


Classification Appeal Decision
Under section 5112 of title 5, United States Code


	Appellant:		[Appellant]

	Agency classification:	Industrial Engineer
				GS-896-12

	Organization:		U.S. Mint
				U.S. Department of the Treasury
	 	
	OPM decision:		Industrial Engineer
				GS-896-11
			
	OPM decision number:	C-0896-11-01

/s/
_____________________________
Virginia L. Magnuson
Classification Appeals Officer

3/29/02
_____________________________
Date



As provided in section 511.612 of title 5, Code of Federal
Regulations, 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, 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 servicing personnel office must submit a compliance
report containing the corrected position description containing
the duties and responsibilities that form the basis of this
decision 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.

The personnel office must also determine if the appellant is
entitled to grade or pay retention, or both, under 5 U.S.C. 5362
and 5363 and 5 CFR 536. If the appellant is entitled to grade
retention, the two-year retention period begins on the date this
decision is implemented.

Decision sent to:

[Appellant]

[Representative]

[Human Resources Officer]

Mr. Ronald A. Glaser
Director, Office of Personnel Policy
Department of the Treasury
1500 Pennsylvania Avenue, NW.
 ATTN: Metropolitan Square
 Room 6075
Washington, DC 20220



Introduction

On August 15, 2001, the Dallas Oversight Division of the U.S.
Office of Personnel Management (OPM) accepted a classification
appeal from [appellant], for the position of Industrial Engineer,
GS-896-12, [organization], U.S. Mint, U.S. Department of
Treasury, [geographic location]. The appellant requests that his
position be reclassified to GS-13. OPM received a complete
administrative report on September 24, 2001. The appeal was
subsequently transferred from the Dallas and Washington, DC
Oversight Divisions to the Atlanta Oversight Division on February
22, 2002.

The appeal has been accepted and processed under section 5112(b)
of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements about the agency's
evaluation of his position. In adjudicating this appeal, our
only concern is to make our own independent decision on the
proper classification of his position. By law, we must make that
decision solely by comparing his current duties and
responsibilities to OPM standards and guidelines (5 U.S.C. 5106,
5107, and 5112). Therefore, we have considered the appellant's
statements only insofar as they are relevant to making that
comparison.

The appellant believes that the GS-896 standard is outdated and
does not provide consistent classification with engineering
technician positions. However, the adequacy of grade-level
criteria in OPM standards is not appealable (section 511.607 of
title 5, Code of Federal Regulations).

In reaching our classification decision, we have carefully
reviewed all information furnished by the appellant, his
supervisor and his agency, including the official position
description.

Position information

The appellant is assigned to position description number [#].
The appellant and supervisor certified the accuracy of the
position description. An OPM representative conducted an on-site
audit with the appellant on February 13, 2002. We also conducted
telephone interviews with the appellant's immediate supervisor
and the Human Resources Office representative.

Our fact finding revealed that while the position description
contains the major duties and responsibilities of the position,
it overstates the complexity of the products, as identified in
this decision, nature and scope of commitments, and advisory,
planning and reviewing functions. The position description
indicates the incumbent represents the [organization] in
conferences and meetings, often making decisions that bind the
[organization] to a course of action. The appellant indicated
that his involvement at conferences is limited. Additionally,
there is no evidence in the record of significant commitment
authority. Decisions on courses of action are made by other
positions in the organization and at higher headquarters level.
The advisory, planning and reviewing functions, when performed,
are peer consultation tasks. The position description should be
corrected.

The appellant serves as the [organization] technical authority in
industrial engineering. The appellant estimates that he spends
about 80 percent of his time on circulation production, because
of the sheer volume of coins produced, and 20 percent on
numismatics. The [organization] manufactures circulating coins
and numismatic coins and medals from coinage strips and blanks.
Division manufacture includes the following processes: blanking,
blank annealing and cleaning, upsetting, inspecting/reviewing,
stamping, counting and bagging/packaging, and materials handling.
The [organization] has a three-shift operation.

The appellant's predominant duties and responsibilities involve
applying industrial engineering principles and practices to
production design improvements. He performs analyses to maximize
the productivity of the [organization] workforce. He
investigates and evaluates factors affecting performance of
personnel, materials, equipment, and inherent integrated systems
and performs or reviews the results of work measurement and work
simplification studies. The appellant plans methods, techniques,
and practices for new production equipment and maintains optimum
plant layout for production areas. He recommends new procedures
for management processes such as workflow and management of
information. He establishes and maintains controls used by
[organization] supervisors to ensure that production is
accomplished according to schedule and works with production
personnel to resolve production problems. The appellant provides
advice to the division chief on production systems, machinery,
equipment and personnel. He develops or selects appropriate
techniques for measuring the efficiency of production activities
and insuring maximum utilization of machinery, equipment,
personnel and related resources. As appropriate, he works with
other functional engineers and specialists on issues of mutual
concern.

The appellant also selects methods to be used in setting work
standards, develops appropriate reporting systems, trains
employees in the use of work standards, and follows up to assure
proper application of standards. He writes standard operating
procedures for equipment operation. He works with or provides
recommendations to other mints on problems, projects and
functions of conventional nature.

The appellant's immediate supervisor, a mechanical engineer,
currently serves in a dual capacity over both the [organization]
and the overall [organization]. His completed work is reviewed
for adequacy of results, for general consistency with other
projects and for conformance with administrative policies and
regulations. There is little or no technical guidance provided
by the supervisor except on critical or controversial matters.

The appellant's position description and other material of record
furnish much more information about his duties and
responsibilities and how they are performed.

Series and title determination

The appellant does not contest the agency's title or series
determination for his position. The agency determined the
appellant's position is properly placed in the Industrial
Engineering Series, GS-896, and titled as Industrial Engineer. We
concur with the agency's series and title decision.

Standard determination

The agency used the Industrial Engineering, GS-896, position
classification standard for grade level determination purposes.
The Grade Level Guide for Engineer Positions Concerned With
Production (Guide) supplements published classification standards
for specific engineering series, including the GS-896 series.
This Guide supersedes the grade-level criteria in the GS-896
standard for positions concerned with production. We must use it
in evaluating positions that are entirely or primarily oriented
to production. The appellant's paramount duties require
continuous production design improvements and analysis to
maximize productivity of personnel, machinery and equipment and
related resources, all of which relate to overall coin
production. Therefore, the grade level criteria contained in the
Guide must be used for grade level determination in evaluating
his position.

Grade determination

The Guide uses two broad factors for grade level determination in
evaluating positions covered by the Guide. These factors are
Nature of Assignments and Level of Responsibility. Our
evaluation of the duties and responsibilities of the appellant's
position follows.

Nature of Assignments

This factor deals with the scope, difficulty, complexity, and
purpose of the work; originality required; and knowledge and
judgment required.

At the GS-9 level, engineers independently plan and carry out a
variety of assignments that pertain to the overhaul and/or
manufacture of an assigned group of commodities or products.
Assignments involve either new or established commodities or
products. They use well-established approaches, closely related
precedent, criteria and practices that apply to the product and
functions. The engineers are required to understand the
established design concepts and materials of construction
associated with their specialized area. In addition to their
professional engineering knowledge of the subject matter, GS-9
engineers apply sound knowledge of the production facilities,
production equipment, materials, processes and test methods.
They use available drawings and technical information to prepare
specifications, drawings and standards as well as quality control
documentation. They determine where items should be inspected
during the production process, the need for new mechanical and
electrical gages, and the characteristics and properties of any
parts or raw materials needed in the production processes. They
prepare plant layout plans for relocation of production or
assembly lines, evaluate feasibility and desirability of
replacing individual items of machinery in the line with updated
models, provide modification requirements to others, and prepare
various cost estimates. GS-9 assignments require knowledge of
professional engineering practices, design analysis, quality
control principles, production methods, and industrial processes
necessary to control quality during an overhaul or manufacturing
process.

At the GS-11 level, engineers apply extensive theoretical and
practical knowledge of the means for overhauling or manufacturing
the diverse products within their area of expertise. This
knowledge covers the manufacturing or overhaul procedures and
processes, necessary machinery and facilities, materials,
assembly, and production testing of the item. Typically GS-11
engineers work with products that: (1) are complicated because
they include several complex subassemblies; (2) require
performance of many difficult and critical machining, assembling,
or difficult-to-control processes in their production; and (3)
require use of complicated testing and inspection methods and
specially designed test equipment. The engineers must apply good
judgment and originality. They use it to modify established
production and quality verification concepts or criteria to fit
the particular situation, to introduce a new type of machine
tool, to automate some formerly manual process, or to conceive a
new inspection technique.

The level of the appellant's assignments meets the GS-9 level.
The appellant's primary commodity is coins. He performs
continuous analyses to maximize the productivity of the
workforce, equipment, and operations. For example, the appellant
recommends the production floor layout of equipment such as
annealing lines, milling machines, washers, labeling machines and
sorters. He uses three-dimensional software to test layout
feasibility. He also recommends equipment changes such as
installation of safety controls on the furnaces so workers can
visibly gauge proper equipment operation. He develops the
purchasing specifications when equipment needs to be replaced.
He writes contractor specifications for chemical purchases and
operations such as equipment movement and tank sandblasting. He
uses equipment instructions and translates them into simple
language, accompanied with pictures or drawings on how to operate
the equipment.

The overall coin production duties and exercise of judgment and
originality are comparable to the GS-11 level. The appellant is
expected to recognize possible new directions of approach and
devise new or improved techniques and methods of obtaining
effective results. This is exemplified by appellant's studies to
simulate the stresses on dies and planchets (blanks) during
striking, determine the makeup of the quench, burnish and rinse
chemicals used, and the air/gas mixture combustion on the
annealing furnaces. He also worked on projects, sometimes with
functional specialists such as the mint's metallurgist, to
improve the metal flow on planchet surfaces and to clean the
blanks with a minimal amount of oil. He developed a database to
serve as an inventory tracking program for all equipment and
materials and a means to monitor the capabilities of the
equipment. The appellant advises on problems, projects, and
functions of conventional nature with the various mints at other
sites. All of these activities require good judgment and
originality in applying established industrial engineering
concepts and principles similar to that described in the Guide at
the GS-11 level.

The appellant's need to research and adapt procedures, such as
for the annealing furnaces, and develop associated standards for
operation is closely related to one of the GS-11 assignment
illustrations. In this example, the GS-11 engineer utilizes
recognized approaches of an engineering discipline to adapt
manufacturer's repair and overhaul procedures to a local
activity's particular facilities, equipment, and operations. The
engineer analyzes the manufacturer's technical manuals and
overhaul procedures and writes a locally applicable repair
standard which details the work processes involved in tasks such
as disassembly, overhaul, repair, and reassembly. The Guide also
provides illustrations that describe GS-11 level work in planning
the production of pilot products; in preparing complete sets of
process drawings; and, in detailing methods, processes, and
sequences of operations to be followed in producing the product.
Equipment modifications and new processes implemented by mint
headquarters, such as those identified in its Selected Major
Capital Projects - FY 2001 plan, require that the appellant study
equipment changes and debugging methods and develop processes and
procedures for the division's operations.

The Guide describes six characteristics that typically are found
in engineering assignments at the GS-12 level. We find that
these characteristics are not present in the appellant's
position.

The first characteristic involves many different or special
applications of the same product by various customers requiring
consideration of such aspects as packaging or testing. The
appellant's principal product is coins, both clad and pennies.
These are packaged in either bulk bags for circulating coins or,
for numismatics, in sets usually containing 10 coins in a mylar
package. The product applications for coins are more limited
than the many different or special applications of the same
product intended by this grade level characteristic.

The second characteristic concerns products that are advanced and
especially complex because of numerous subassemblies or component
parts. Information from the agency specifically states that "the
coins themselves do not possess subassemblies or component parts,
but each new intricate quarter design requires that the machinery
and equipment" be monitored, modified and operated appropriately
to effectively produce a coin that meets tolerances and quality
levels. The intent of the Guide for this characteristic is not
to focus on the machinery involved, but rather to recognize the
advanced nature and complexity of the product. As confirmed by
our factfinding, the production of coins does not involve
numerous subassemblies or component parts.

The third and fourth characteristics deal with technical
documentation or background information that is unproven or
inadequate and with assignments that are without precedent.
These assignments often involve production activities that are
complex and of high risk. The appellant's position is not
characterized by unproven or inadequate technical documentation
or complex and high-risk assignments without precedent. The
record shows that technical information is available in most
circumstances to differing degrees and the mint has a large
library filled with technical materials. There is more
information on the newer pieces of equipment and parts.
Precedent, such as concepts developed and used in other places,
is usually available, but must be researched and adapted for use
at the mint. The appellant has engineering manuals, technical
directives, drawings, manufacturers' catalogs, and precedent
situations available. The appellant must select, modify and
adapt applicable guidelines to the solution of specific problems
or initiatives in the production process.

The assignments are of a conventional nature rather than
unprecedented and involving complex and high-risk activities.
The appellant stated that new technologies he implements mostly
involve replacing old controls on the equipment with new ones or
replacing the equipment. For example, he had safety controls
installed on the furnaces and installed new coin washers. He
makes determinations as to the makeup of the quench, burnish and
rinse chemicals used in production through performance trials to
increase quality and reduce effluent. He consulted with the
environmental office to ensure the chemical makeup would not have
an adverse impact elsewhere. He performed research on older
American Gas Furnace annealing furnaces and developed a procedure
to change the atmosphere in the annealing furnaces that
eliminated the oxidation on the blanks. For this procedure, he
worked with the environmental engineer in determining what needed
to be done and making necessary adjustments.

The fifth characteristic is present when concurrent contracts
with more than one producer complicate obtaining identical
equipment from different production lines and assuring
interchangeability of components and performance. The appellant
may recommend equipment specifications and does provide advice on
equipment, but he is not responsible for working with equipment
contractors or making significant purchases.

The sixth and final characteristic refers to production
activities that involve diverse machining, mixing, and other
operations that must be done to very precise tolerances; and
numerous significant design changes occurring during production.
While coining operations must meet established and precise
tolerances, the record does not show that operations require
numerous design changes.

Although the incumbent plans for production of new quarter
designs and works with his counterparts on creating technical
documentation or background information for each of these new
designs, this product does not meet the intent of the Guide.
Rather, examples of GS-12 level assignments include production
work with newly developed chemical products, unusually
complicated pyrotechnic devices, new state-of-the-art products,
large and complete new overhaul and repair facilities, and
prototype or advanced products. In addition, the broad scope and
complexity of assignments at the GS-12 level require engineers to
apply substantial knowledge of additional engineering
disciplines. The appellant does utilize some knowledge of
chemical and environmental science and mechanical engineering as
they relate to the production processes. The knowledge used,
however, is not the substantial knowledge envisioned by the Guide
to accomplish GS-12 level assignments and is not a required
qualification for the position.

GS-12 engineers frequently must apply experienced judgment and
knowledge of advanced engineering concepts to major production
modification plans and requirements; and their decisions will
determine whether it is most feasible to modify in-house
production operations or to stop production and contract out
product production. The appellant does not frequently apply
advanced engineering concepts to major modification plans and
requirements. He may make recommendations, but not decisions,
relating to outsourcing production operations. The appeal record
indicates that most modifications involve how many coins to
produce rather than how to produce the coins.

GS-12 engineers are considered to possess such breath and depth
of knowledge in their area of expertise that they often are
required to provide technical guidance to other engineers who
encounter difficulty in adapting and modifying established
methods and precedents and in resolving the most perplexing or
unusual problems. Within the plant, the appellant provides
technical guidance to other engineers. He provides
recommendations relating to production processes and systems and
works with other engineers and scientists in resolving problems
of mutual concern. The appellant does perform advisory, planning
and reviewing duties with the various mints at other sites.
However, these are consultative duties and the problems, projects
and functions involved are of a conventional nature, rather than
perplexing or unusual problems typical of the GS-12 level. These
also are presented as recommendations.

The Nature of Assignment meets the GS-11 level as described in
the Guide.

Level of Responsibility

This factor deals with supervision received; availability and
pertinency of guidelines; nature, scope and significance of
recommendations, determinations, advice rendered and commitment
authority; and nature and purpose of contacts.

At the GS-9 level, supervisors screen assignments in advance and
furnish general instructions as to the scope of engineering
activities. They review completed assignments thoroughly for
appropriateness of approach, technical accuracy, soundness of
conclusions, and conformance to policy. The supervisor gives
detailed instructions when new criteria or new techniques are
involved.

At the GS-11 level, supervisors typically provide assignment
goals and general background information, when it is available,
and a general technical review at assignment completion.
Engineers consult agency engineering manuals, manuals on program
requirements for quality assurance, production engineering
handbooks, procurement regulations, etc., in determining
methodology and completing analyses. GS-11 engineers normally
carry out their assignments by modifying available guidelines or
precedent approaches. They have many contacts with engineers
inside and outside the organization. On those occasions, they
make judgments and recommendations, and, commonly, they make on-
the-spot determinations regarding the acceptability of finished
products, production models, test procedures, etc. GS-11
engineers suggest changes in production processes and equipment
to contractors and other engineers; and they recommend changes in
materials, designs, and resources for the purpose of reducing
costs, including manpower requirements, promoting
standardization, and facilitating and reducing the cost of test
and inspection activities. GS-11 engineers also represent their
activity on assigned aspects, and coordinate their assignments
with other engineers who are concerned with other engineering
specializations. These activities are performed with
considerable freedom from supervision, independence of action,
and freedom from technical guidance.

The GS-11 level is met. The appellant functions independently
and provides a weekly update to his supervisor. The supervisor
informed us that he maintains awareness of the appellant's
activities, sometimes approves courses of action for the
appellant, and only steps in when there is need for his
intervention. Completed work is reviewed for adequacy of
results, general consistency with other projects and for
conformance with administrative policies and regulations. The
appellant generally makes recommendations on production
processes, materials, equipment, design and resources. The
supervisor, the [organization], or other levels of authority
review recommendations for decision or further action. Like GS-
11 engineers, the appellant primarily selects, modifies and
adapts applicable guidelines to resolve specific problems or
initiatives. He has had to do research on old equipment in order
to develop current procedures. The mint does have a technical
library with technical information available in varying degrees
in most circumstances.

The appellant's contacts also meet the GS-11 level in that he has
frequent contacts with key professional and engineering personnel
in the plant, bureau headquarters and other mints, and
contractors and coordinates assignments with the environmental
engineer, metallurgist, other industrial engineers, and others
concerned with specialized aspects of the assignment. He attends
seminars occasionally and his involvement in conferences is
limited.

At the GS-12 level, engineers define the scope, isolate problem
areas, plan and execute problem solving of their assignments
independently. They seek assistance from the supervisor on
policy questions and radical departures with far-reaching
implications. Supervisors review completed assignments to
determine technical adequacy, achievement of goals, and policy
compliance.
GS-12 engineers characteristically plan and advise on pilot
production and volume manufacture of products that do not lend
themselves to use of established product evaluation and
production methods. Guidelines and approaches used in previous
manufactures are only partly applicable and require use of
untried methods and machines. This is because items may be state-
of-the-art and radically changed versions of existing ones.

GS-12 engineers, because of assigned commodities, typically
coordinate with one or several other commands and agencies. They
have continuing contacts with project engineers, contractors'
engineers, production plant workers, key inspectors, methods
personnel, etc. They make technical decisions and recommendations
on a variety of matters, without prior consultation with their
supervisors. Decisions pertain to the acceptability of terms,
production waivers, production methods, and acceptability of new
designs of replacement production machinery from contractors.

The GS-12 level is not met. The overall level of supervision
does not meet the GS-12 level where engineers routinely work
independently, but on issues involving radical departures from
policy with far-reaching implications; products that do not lend
themselves to use of established product evaluation and
production methods, and use of untried methods and machines. The
record shows that on several occasions the appellant performed
studies that resulted in use of methods new to the mint. He
researched equipment (e.g., the intricacies of the gas systems
for older American Gas Furnace annealing equipment) or methods
used elsewhere. He used this information to develop procedures
previously untried at the mint, such as the different
concentrations of chemicals for the golden dollar production.
These studies support credit for GS-11 level use of judgment and
originality in adapting guidelines and precedent approaches.
They do not meet the intent of untried methods characteristic of
the
GS-12 level. The appellant also does not have the decision-
making authority and the broader personal contacts with other
agencies and commands characteristic of GS-12 engineers.

The appellant's Level of Responsibility meets the GS-11 level.

The appellant's position meets the GS-11 level under both the
classification factors above.

Decision

The position is properly classified as Industrial Engineer, GS-896-11.