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

 
Dallas Oversight Division
1100 Commerce Street, Room 4C22
Dallas, TX 75242-9968

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

	Appellant:		[appellants name]

	Agency classification:	Supervisory Cytotechnologist
				GS-601-10

	Organization:		[appellants facility]
				Department of Veterans Affairs
				[city, state]

	OPM decision:		GS-601-10
				title at agency discretion

	OPM decision number:	C-0601-10-01

/s/ Bonnie J. Brandon
_____________________________
Bonnie J. Brandon
Classification Appeals Officer

September 7, 2001
_____________________________
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).

 Decision sent to:

[appellant's name and address]

[servicing human resources office]

Shared Service Center, HR Links
Department of Veterans Affairs
3401 SW. 21st Street, Building 9
Topeka, KS 66604

Chief, Compensation and Classification
 Division (051)
Human Resources Management
Department of Veterans Affairs
810 Vermont Avenue, NW.
Washington, DC 20420

Deputy Assistant Secretary for
 Human Resources Management (05)
Department of Veterans Affairs
810 Vermont Avenue, NW., Room 206
Washington, DC 20420

Introduction

On March 5, 2001, the Dallas Oversight Division of the U. S.
Office of Personnel Management (OPM) accepted an appeal from [the
appellant]. His position is classified as Supervisory
Cytotechnologist, GS-601-10. He works in the [appellant's
activity], Department of Veterans Affairs (VA), in [city, state].
The appellant previously filed an appeal with the VA central
office. That office's decision of September 20, 2000, sustained
the classification as GS-601-10. The appellant believes the
classification should be Anatomic Pathology Manager, GS-12. We
have accepted and decided this appeal under section 5112 of title
5, United States Code (U.S.C.).

To help decide the appeal, an OPM representative conducted
telephone interviews with the appellant and his immediate
supervisor. We also spoke with the [appellant's veterans health
care system] human resources specialist who classified the
appealed position. In reaching our classification decision, we
reviewed the information obtained by telephone and all
information of record furnished by the appellant and his agency.

General issues

In the information the appellant sent to OPM, he raises several
issues that he believes should be considered in determining the
classification of his position: classification consistency,
impact of the person on the job, special technical demand, mixed-
grade duties, and grade levels for two-grade interval work. The
Introduction to the Position Classification Standards and The
Classifier's Handbook contain information that specifically
relates to the appellant's issues. The Introduction and the
Handbook provide background information, general concepts, and
technical guidance regarding the selection, interpretation, and
application of OPM classification standards for General Schedule
work.

Classification consistency

The appellant believes his work is similar to that performed by
cytology technologists, also referred to as cytotechnologists, in
higher grade positions at various locations within VA. By law,
we must classify positions solely by comparing their current
duties and responsibilities to OPM position classification
standards and guidelines (5 U.S.C. 5106, 5107, and 5112). Since
comparison to the standards is the exclusive method for
classifying positions, we cannot compare the appellant's current
duties to other positions as a basis for deciding his appeal.
OPM's classification appeal process is an independent, third-
party review that determines the duties and responsibilities
assigned to the appellant's position and performed by him and
properly applies the appropriate standards to those duties and
responsibilities. Therefore, the appellant's perceptions
regarding similarity of his position to others have no bearing on
the proper classification of his duties and responsibilities.

To support his claim that similar positions within VA are
classified differently, the appellant included information in his
appeal that lists the number of GS-9, GS-10, GS-11, and GS-12
cytology positions by grade level at various VA facilities. He
did not provide other evidence to support his claim. When
adjudicating appeals, OPM may require a consistency report from
an agency when there is reason to believe an agency's
classification of identical, similar, or related positions is
inconsistent with the appealed position. By itself, the listing
of cytotechnologist positions by grade level is not substantial
evidence that would lead OPM to require an intra-agency
classification consistency report from VA.

VA has primary responsibility for ensuring its positions are
classified consistently with OPM appeal decisions and for
consistency in applying the principle of equal pay for
substantially equal work. If the appellant considers his
position so similar to others that they all warrant the same
classification, he may address the consistency issue by writing
to VA's personnel headquarters. If the appellant pursues the
matter with VA, he should specify the precise organizational
location, classification, duties, and responsibilities of the
positions in question. If the positions are found to be
basically the same as his, VA must correct its classification of
the positions to be consistent with this appeal decision.
Otherwise, VA should explain to the appellant the differences
between his position and the others.

Impact of the person on the job

The concept of impact of the person on the job is addressed in
both the Introduction and the Handbook. This concept holds that,
by virtue of exceptional competence, an employee may have such an
impact on the duties, responsibilities, and qualification
requirements of a position that it is changed to the point where
its classification must also be changed. On the other hand, the
mere fact that an individual in a position possesses higher
qualifications or stands out from other individuals in comparable
positions is not sufficient reason by itself to classify the
position to a higher grade. When determining grade level based
on this concept, it is essential that management recognizes and
endorses the duties and that the work environment allows
continuing performance at a different level. Neither the
appellant nor officials of his agency provided evidence that
impact of the person on the job should be a factor in evaluation
of the appellant's position, that is, his performance actually
makes the appealed position materially different from what it
otherwise would be.

Special technical demand

The Handbook describes "special technical demand" as an element
that was considered when using the Supervisory Grade Evaluation
Guide (SGEG) to evaluate supervisory positions. The SGEG is no
longer used. It was superseded by the General Schedule
Supervisory Guide (GSSG) that was issued in April 1993; the GSSG
issued in April 1998 supersedes the one issued in April 1993.

The GSSG does not address special technical demand as a separate
element. Instead, the GSSG incorporates that element in other
factors, such as Factor 5 which measures the difficulty of
typical work directed and Factor 6 which addresses special
situations that may complicate a supervisor's work.

Even if the SGEG could be used, the appellant's position would
not meet the element for special technical demand. Credit for
that element could be given only when both of the following
conditions were present:

 a. There is at least one subordinate full-time position, at a
 level above the base level of work. The employee in that
 position performs, as a major part of the work, nonsupervisory
 substantive work for which the supervisory position being
 evaluated is technically responsible.

 b. The nonsupervisory substantive work concerned actually
 imposes on the supervisory position being evaluated a technical
 ability and knowledge requirement significantly higher than that
 needed to review work at the base level.

The position with a "special technical demand" to which the
appellant refers is his own position, not a subordinate position.
Clearly, the appellant's position would not have met the SGEG
criteria.

Mixed-grade duties

Some positions involve performing different kinds and levels of
work which, when evaluated separately in terms of duties,
responsibilities, and qualifications required, are at different
grade levels. The proper grade of such positions is determined
by evaluation of the regularly assigned work which is paramount
in the positions. In nearly all positions, the duties that
occupy the majority of the employee's time also represent the
highest level of work performed. However, duties may be grade
controlling if they are a regular and continuing part of the
position, are performed for at least 25 percent of the time, and
involve a higher level of knowledge and skill that would be a
factor in recruiting for the position. When an employee is
assigned higher level work for at least 25 percent of the time,
it is reasonable to conclude that the employee is applying the
level of knowledge and skills associated with that grade. As
explained later in this decision, the appellant's supervisory
duties, which occupy about 30 percent of his time, are the
highest level of work assigned to his position. The
cytotechnologist duties the appellant personally performs do not
exceed this grade. Therefore, the proper grade for his position
is the grade based on his supervisory duties.

Grade levels for two-grade interval work

The appellant questions the assignment of two-grade interval work
to an intermediate grade level (for example, GS-10). For
nonsupervisory positions, the grade levels of GS-6, GS-8, or GS-
10 are rarely appropriate for either two-grade interval
administrative or professional positions. However, it is
possible that use of a standard written in the Factor Evaluation
System (FES) format, which assigns a point value to the levels
within a factor, may produce an even-number grade for a position.
While that kind of situation is unusual for nonsupervisory
positions, it may happen because the Factor Evaluation System
uses one set of factor values for all covered occupations. If,
after checking the evaluation carefully, the position factors
convert to an even grade, then it is the correct grade for the
position. Similarly, the GSSG uses a point-value approach with
six evaluation factors designed specifically for supervisory
positions. The total points accumulated under the six factors
are then converted to a grade by using the point-to-grade
conversion table in the GSSG. The conversion may result in an
even-number grade.

If a position includes major nonsupervisory duties, those duties
must be evaluated by using appropriate standards and guides. If
the duties evaluate to a different grade than the position's
supervisory duties, the grade for the higher level duties will be
the final grade of the position. As previously stated, the
appellant's nonsupervisory duties do not evaluate at a higher
grade than the supervisory duties. Therefore, the grade of the
supervisory duties is the appropriate grade for the appealed
position.

Position information

The appellant is assigned to position description (PD) [PD
number]. The appellant and his supervisor have certified that PD
[number] is accurate.

The [appellant's activity] is part of [a laboratory], which
provides laboratory tests and procedures in support of three
hospitals and five community-based outpatient clinics. The
[appellant's activity] is the main testing and referral site and
performs a wide variety of basic and specialized laboratory
tests. While laboratories at the other [activities] and [an
outpatient clinic] perform various basic testing procedures, only
the [appellant's activity] performs surgical pathology, cytology,
and autopsy services. The appellant supervises the histology
work within the anatomic pathology laboratory at the [activity].
He directs a staff of approximately three histopathology
technicians who provide cytopathology, histopathology, autopsy,
and immunohistochemical services. The appellant works under the
administrative supervision of the [laboratory] Administrative
Director and under the technical supervision of the chief of
anatomic pathology.

The appellant spends about 30 percent of his time performing
supervisory duties. Those duties include planning and assigning
work, evaluating performance, counseling employees, hearing and
resolving complaints, and identifying training needs.

The appellant devotes about 40 percent of his time personally
performing cytotechnologist work. His nonsupervisory work
includes making cytodiagnoses of cell samples for presence or
absence of normal or abnormal cellular patterns; presence of
microorganisms; inflammatory reactions or benign cellular
conditions; cellular responses to therapeutic agents;
premalignant conditions; and neoplasms. He determines the
adequacy and quality of histologic and cytologic specimens and
either supervises or performs all technical functions related to
frozen sectioning and autopsy service. He also assists with
collection, preparation, and microscopic diagnosis of specimens
obtained by special procedures such as fine needle aspirations
and deep-organ biopsies.

The appellant develops, evaluates, modifies, adapts, and promotes
new methodologies to improve the accuracy, precision,
sensitivity, specificity, or proficiency of test analyses or to
enhance or improve diagnostic capabilities of the laboratory. He
designs forms for use in the laboratory, for example, an
intradepartmental gynecologic pathology diagnosis worksheet. He
also develops, implements, and enforces procedures and policies
for employee safety.

The appellant conveys information to professionals who are
directly responsible for patient care with respect to proper
anatomic pathology specimen collection methods, the handling and
transportation of specimens, proper submission of request forms,
and interpretation of anatomic pathology reports. He teaches
staff physicians, resident physicians, medical students, and
other students in the principles and practice of anatomic
pathology.

The remainder of the appellant's time relates to ensuring that
the lab is appropriately supplied and maintained and that it
meets accreditation and safety requirements.

Series determination

The appellant does not contest the agency's placement of his
position in the General Health Science Series, GS-601. We concur
that the GS-601 series is appropriate.

Title determination

The agency titled the position Supervisory Cytotechnologist. The
appellant believes the title of Anatomic Pathology Manager would
be a more descriptive title. Further, he notes that he does not
supervise cytology technologists. While the appellant supervises
histopathology technician work that his agency classified in the
GS-646 series, he personally performs cytotechnologist work. The
agency chose a title denoting that the paramount requirement of
the appellant's position is professional knowledge and competence
in the field of cytotechnology. The position is also delegated
supervisory responsibilities that meet the minimum criteria for
coverage of the GSSG. Since OPM has not prescribed titles for
positions in the GS-601 series, the agency may construct a title,
which recognizes the supervisory responsibilities, following the
guidelines in the Introduction to the Position Classification
Standards.

Standard and guide determination

The appellant's supervisory and nonsupervisory work must be
evaluated separately because the same classification criteria do
not apply to both. The overall grade of the position is the
higher level of either supervisory or nonsupervisory work. Work
demanding less than a substantial (at least 25 percent) amount of
time is not considered in classifying a position.

The GSSG is used to evaluate the appellant's supervisory duties
and responsibilities. Those duties require the accomplishment of
work through combined technical and administrative direction of
others, occupy at least 25 percent of the position's time, and
meet at least the minimum level of supervisory authority
specified in Factor 3.

OPM has not issued a standard that contains grading criteria
specifically for positions in the GS-601 series. Therefore, an
appropriate general classification guide or criteria in a
standard or standards for related kinds of work must be
referenced to make a grade-level determination. The criteria
selected as the basis for comparison should be for a kind of work
as similar as possible to the position to be evaluated with
respect to the:

 - kind of work processes, functions, or subject matter of work
 performed;

 - qualifications required to do the work;
 
 - level of difficulty and responsibility; and

 - combination of classification factors which have the
 greatest influence on the grade level.

Within the GS-600 Medical, Hospital, Dental, and Public Health
Group, the Pathology Technician Series, GS-646, involves
technical work subordinate to the work of pathologists or other
physicians (or other professional personnel) who make the final
diagnostic examinations of specimens of human tissues and/or cell
preparations. While the appellant's cytopreparatory techniques
can be evaluated by this standard, technical work does not
represent the highest level of nonsupervisory work performed.
The higher level work requires professional knowledge of cytology
principles, theories, practices, procedures, and methodologies
and related biological sciences; teaching and instructional
techniques; knowledge of the recognized standards of care and the
Federal, State, and accrediting agencies' regulations; and skill
in using a compound microscope and other laboratory testing
equipment.

The Medical Technologist Series, GS-644, includes positions that
require professional knowledge and competence in the field of
medical technology. The series provides related criteria in
respect to the evaluation of administrative and technical
laboratory processes, similar professional knowledge base
requirements in biological sciences, technical and analytical
methods and techniques, and certification requirements needed to
perform laboratory testing, evaluation, and diagnostic work.
While a medical technologist performs tests on blood and other
body fluids or tissues, a cytotechnologist focuses on evaluating
or diagnosing changes in cellular structure. With the
differences in subject matter noted, the GS-644 series is the
most closely related OPM standard that can be used to evaluate
the appellant's higher level nonsupervisory duties and
responsibilities.

Grade determination

Evaluation using the GSSG

The GSSG uses a point-factor evaluation approach with six
evaluation factors specifically designed to assess supervisory
positions. The points for all levels are fixed, and no
interpolation or extrapolation of them is permitted. If one
level of a factor is exceeded, but the next higher level is not
met, the factor is credited at the lower level. Points
accumulated under all factors are converted to a grade using the
GSSG's point-to-grade conversion table.

The appellant does not contest the agency's determination for
Factors 2 and 4. We have reviewed those factors and agree with
the agency evaluation. Therefore, this decision will only
address those factors with which the appellant disagrees.

Factor 1, Program scope and effect

This factor has two components, scope and effect. To receive
credit for a given level, the separate criteria specified for
both scope and effect must be met at that factor level.

 Scope

Scope addresses complexity and breadth of the program or work
directed, including the geographic and organizational coverage.
It has two elements: (a) the program (or program segment)
directed and (b) the work directed, the products produced, or the
services delivered.

Level 1-2 covers the direction of administrative, technical,
complex clerical, or comparable work that has limited geographic
coverage and supports most of the activities of a typical agency
field office, an area office, a small to medium size military
installation, or comparable activities within agency program
segments.

Level 1-3 covers the direction of a program segment performing
administrative, technical, or professional work where the program
segment and work directed encompass a major metropolitan area, a
State, or a small region of several States. When most of an
area's taxpayers or businesses are concerned, coverage may be
comparable to a small city. Providing complex administrative or
professional services directly affecting a large or complex
multimission military installation, or an organization of similar
magnitude, is also characteristic of this level.

The appellant believes that his position meets Level 1-3 because
the professional work he personally performs results in
professional work for the program segment he directs. He also
indicates that the services he directs support a complex
multimission organization (that is, the [appellant's activity]
which includes three hospitals and five community-based
outpatient clinics) that serves the veteran population in 35
rural counties.

The unit the appellant supervises is small and does not have a
subordinate structure. Although his unit provides critical
services (cytopathology, histopathology, autopsy, and
immunohistochemical work), they constitute a small portion of the
range of health services that the [veterans health care system]
makes available to veterans in its 35-county area. The
appellant's supervisor has [the health care system]-wide
responsibilities. The appellant's position meets Level 1-2.

We evaluate this element at Level 1-2 (350 points).

 Effect

Effect addresses impact of programs, products, or correctly
performed work both within and outside the agency.

At Level 1-2, services significantly affect installation level or
field office operations and objectives. This level also includes
services that are provided to a moderate local or limited
population of clients comparable to a major portion of a small
city.

At Level 1-3, activities, functions, or services directly and
significantly affect a wide range of agency activities, other
agencies, outside interests, or the general public. At the field
activity level (involving large or complex multimission
organizations and/or very large serviced populations), the work
directly entails the provision of essential support services or
products to numerous, varied, and complex technical,
professional, or administrative functions.

The appellant's position meets Level 1-2. While the work of the
appellant's unit directly affects [the appellant's activity]
operations and objectives, it does not directly and significantly
affect a wide range of agency activities (that is, VA activities)
or outside interests as envisioned at Level 1-3. The appellant's
supervisor stated that about 30,000 of the estimated 100,000
veterans in the 35-county area make use of the [veterans health
care system's] services during a year. About 5,000 veterans
require laboratory services from the appellant's unit.

Because the position meets Level 1-2 for both scope and effect,
we evaluate this factor at Level-1-2 (350 points).

Factor 3, Supervisory and managerial authority

This factor covers the delegated supervisory and managerial
authorities that are exercised on a recurring basis. To be
credited with a level under this factor, a position must meet the
authorities and responsibilities described for the specific
level.

At Level 3-2, positions must meet one of three descriptions.
Level 3-2a contains criteria for evaluating positions that
supervise production-oriented work, and Level 3-2b covers
supervision in organizations where work is contracted out.
Neither of those levels is appropriate for the appellant's
position. Level 3-2c specifies 10 authorities and
responsibilities characteristic of supervisors functioning at
this level. For that level to be credited, positions must meet
at least three of the first four authorities and responsibilities
and a total of six or more of the 10. The appellant's position
meets Level 3-2c. For example, he plans and assigns work for his
subordinate employees; evaluates their performance; gives advice,
counsel, or instruction to employees on both work and
administrative matters; hears and resolves complaints from
employees; and effects minor disciplinary measures.

To be credited at Level 3-3, positions must meet either paragraph
a or b of the factor description. Level 3-3a is applicable to
positions that are closely involved with high level program
officials, or comparable agency level staff personnel, in
developing overall goals and objectives for assigned programs.
Level 3-3a is not characteristic of the appellant's position.
The responsibilities described at Level 3-3a belong to higher
level positions within the agency. Level 3-3b is appropriate for
positions that exercise at least 8 of 15 authorities specified in
the factor description in addition to exercising all or nearly
all of the authorities at Level 3-2c.

The appellant believes his position meets 8 of the 15 supervisory
responsibilities at Level 3-3b: 2, 7, 9, 10, 11, 13, 14, and 15.
Responsibilities 1, 3, 5, 6, and 8 cannot be credited to the
appellant's position. These responsibilities are intended to
credit only supervisors who direct at least two or three
subordinate supervisors, team leaders, or comparable personnel.
Responsibility 4 cannot be credited because the appellant does
not direct a program segment with significant resources, for
example, multimillion dollar level of annual resources.
Responsibility 12 cannot be credited because the appellant does
not determine whether contractor-performed work meets standards
of adequacy needed to authorize payment.

Responsibility 2 requires the supervisor to exercise significant
responsibilities in dealing with officials of other units or
organizations or in advising management officials of higher rank.
The appellant's position does not meet the intent of this
responsibility in that it is his supervisors who deal with
officials in other units and higher level management officials.
This responsibility is not creditable.

Responsibility 7 requires making or approving selections for
subordinate nonsupervisory positions. This responsibility cannot
be credited because the appellant only recommends selections.
His supervisor has the authority to make or approve selections.

Responsibility 9 concerns hearing and resolving group grievances
or serious employee complaints. This responsibility refers to
resolving serious complaints (for example, sexual harassment) or
group grievances and is predicated on the regular exercise of
authority that exceeds the responsibility under Level 3-2c to
hear and resolve complaints from employees. The intent of this
responsibility is not met in the appellant's position since
disputes are resolved through collaboration with the appellant's
supervisor.

Responsibility 10 concerns reviewing and approving serious
disciplinary actions, such as suspensions, involving
nonsupervisory subordinates. As with responsibility 9, the
appellant's supervisor has the approval authority for serious
disciplinary actions. The appellant's position cannot receive
credit for this responsibility.

Responsibility 11 requires making decisions on nonroutine,
costly, or controversial training needs and training requests.
The appellant approves routine training for his staff. Unusual,
costly, or controversial training requires approval by the
appellant's supervisor. This responsibility is not credited.

Responsibility 13 concerns approval for expenses comparable to
within-grade increases, extensive overtime, and employee travel.
The appellant's supervisor approves such actions, which precludes
crediting the appellant with this authority.

Responsibility 14 concerns recommending awards or bonuses for
nonsupervisory personnel and recommending changes in
classification. The crediting of this responsibility is
predicated on an organization being varied and complex enough to
require regular attention to changes in position classification
and a reasonable chance that those changes would be adopted. The
appellant may make minor changes in position descriptions, such
as pen-and-ink changes to reflect new duty assignments or delete
duties that are no longer performed. The authority to make
substantive changes in classification is retained at higher
levels. This responsibility cannot be credited for the
appellant's position.

Responsibility 15 concerns finding and implementing ways to
eliminate or reduce bottlenecks and barriers to production,
promote team building, or improve business practices. The
appellant's responsibility in this area does not exceed routine
methods to improve productivity and increase the quality of work.
There is no evidence that the appellant is regularly faced with
bottlenecks and barriers as envisioned for this level.

The appellant's position does not meet any of the
responsibilities listed under Level 3-3b. Therefore, we evaluate
this factor at Level 3-2c (450 points).

Factor 5, Difficulty of typical work directed

This factor covers the difficulty and complexity of the basic
work most typical of the organization directed, as well as other
line, staff, or contracted work for which the supervisor has
technical or oversight responsibility (either directly or through
subordinate supervisors, team leaders, or others). The highest
level of work credited for this factor must constitute at least
25 percent of the workload of the organization supervised.
Excluded from consideration are:

 C work of lower level positions that primarily support the
 basic work of the unit,
 
 C work that is graded based upon the criteria in supervisory
 or leader guides,
 
 C work that is graded higher than normal because of
 extraordinary independence from supervision, and
 
 C work not fully under the supervisor's authority and
 responsibility as defined under Factor 3.

The agency's workload analysis indicates that of the three
employees supervised by the appellant, two spend most of their
time performing GS-7 level technician work. The third employee
is training for a GS-7 level technician position. None of these
three employees performs work higher than the GS-7 level.
According to the conversion chart in the GSSG, Level 5-4 is
appropriate since GS-7 is the highest level of work that
constitutes at least 25 percent of the workload of the
appellant's unit.

We evaluate this factor at Level 5-4 (505 points).

Factor 6, Other conditions

This factor measures the extent to which various conditions add
to the difficulty of supervision. For credit, the condition must
be present and dealt with on a regular basis. One level is added
to positions at Level 6-3 or below if they also meet at least
three of the eight special situations described under this
factor.

The appellant's position meets Level 6-2a where the work
supervised or overseen involves technician and/or support work
comparable in difficulty to GS-7 or GS-8. As at Level 6-2a, the
appellant's coordination activities ensure consistency of
services provided.

The position does not meet Level 6-3a where supervision requires
coordination, integration, or consolidation of administrative,
technical, or complex technician or other support work comparable
to GS-9 or GS-10, or work at the GS-7 or GS-8 level where the
supervisor has full and final technical authority over the work.
Full and final technical authority means that the supervisor is
responsible for all technical determinations arising from the
work, without technical advice or assistance on even the more
difficult and unusual problems and without further review except
from an administrative or program evaluation standpoint. While
the appellant supervises a base level of GS-7 work, he does not
have full and final technical authority over their work.
Although his work usually is evaluated for scientific and
technical soundness, appropriateness, and conformity, the
appellant's supervisor (a Board certified medical technician)
provides technical advice and the chief of anatomical pathology
is available for technical advice or assistance on the more
difficult and unusual problems.

The appellant's position does not meet Level 6-3b where positions
direct subordinate supervisors over positions in grades GS-7 or
GS-8, or the equivalent, which requires consolidation or
coordination within or among subordinate units or with outside
units. There are no subordinate supervisors or subordinate units
under the appellant's supervision.

The appellant believes his position should be credited with six
of the eight special situations: variety of work, fluctuating
workforce or constantly changing deadlines, physical dispersion,
special staffing situations, changing technology, and special
hazard and safety conditions. The agency credited only the
special hazard and safety conditions for the position. The
appellant states that the other two conditions, shift operations
and impact of specialized programs, do not apply to his position.

Variety of work. This situation is credited when more than one
kind of work, each kind representing a requirement for a
distinctly different additional body of knowledge on the part of
the supervisor, is present in the work of the unit. A "kind of
work" usually will be the equivalent of a classification series.
The appellant's subordinate staff performs work classifiable in
the GS-646 Pathology Technician Series. Supervising this work
does not require the appellant to possess a distinctly different
body of knowledge because his cytotechnologist duties require
knowledge of related disciplines such as histology and pathology.
Further, one of the GS-7 technicians also performs cytology
duties in the absence of the appellant. No credit is given for
this situation.

Fluctuating workforce or constantly changing deadlines. This
situation may be credited when the workforce supervised has large
fluctuations in size and these fluctuations impose on the
supervisor a substantially greater responsibility for training,
adjusting assignments, or maintaining a flow of work while
absorbing and releasing employees. Credit for constantly
changing deadlines may be credited when there are frequent,
abrupt, and unexpected changes in work assignments, goals, and
deadlines that require the supervisor to constantly adjust
operations under the pressure of continuously changing and
unpredictable conditions. The workforce in the appellant's unit
is stable. Although the work of his unit is subject to patient-
driven workload and may be affected by sudden deaths of patients,
these events do not instigate immediate and abrupt changes in the
appellant's work operations. Rather, response to these factors
is generally programmed well in advance. This situation is not
credited.

Physical dispersion. This situation is credited when a
substantial portion of the workload for which the supervisor is
responsible is regularly carried out at one or more locations
that are physically removed from the main unit, under conditions
that make day-to-day supervision difficult to administer.
Although one of the technicians in the appellant's unit works on
a separate floor from the appellant, that employee's work does
not constitute a substantial portion of the unit's workload.
Further, the physical separation does not unduly complicate the
appellant's day-to-day supervisory responsibilities. No credit
is given for this situation.

Special staffing situations. This situation is credited when (1)
a substantial portion of the workforce is regularly involved in
special employment programs or in similar situations which
require involvement with employee representatives to resolve
difficult or complex human resources management issues and
problems; (2) requirements for counseling and motivational
activities are regular and recurring; and (3) job assignments,
work tasks, working conditions, and/or training must be tailored
to fit the special circumstances. All three conditions must be
present for this situation to be credited. The appellant
believes this situation is met because he supervises a trainee
who has some performance problems. Since the appellant's
position does not meet all three criteria, no credit is given for
this special situation.

Changing technology. This situation is credited when work
processes and procedures vary constantly because of the impact of
changing technology, creating a requirement for extensive
training and guidance of subordinate staff. The appellant's
organization is experiencing some changes in technology as the
agency updates its automated and information management
processes, requiring some training of staff to accommodate new
procedures. While medical technology is updated and improved
frequently, there is no indication that such changes result in
constant variances in work processes and procedures used by the
appellant and his subordinate technicians. Although there has
been change in some of the apparatus used by the technicians,
there is no evidence that these changes have required extensive
training and guidance as envisioned in the GSSG. No credit is
given for this situation.

Special hazard and safety conditions. This situation is credited
when the supervisory position is regularly made more difficult by
the need to make provision for significant unsafe or hazardous
conditions occurring during performance of the work of the
organization. The appellant supervises a hospital laboratory
unit where the employees are subject to the hazardous conditions
typical of such operations in performing their work. The
employees must comply with all applicable safety, biohazard, and
hazardous material directives and are required to share in the
responsibility for sound laboratory safety and biohazard and
hazardous material programs. This situation is credited for the
appellant's position.

Since the appellant's position meets only one of the eight
special conditions, no additional level is credited. Therefore,
this factor is evaluated at Level 6-2a (575 points).

Summary

In sum, we have evaluated the appellant's supervisory duties and
responsibilities as follows:

Factor 				Level 	Points
1. Program scope and effect 	1-2 	350
2. Organizational setting 	2-1 	100
3. Supervisory and managerial 
authority exercised 		3-2 	450
4. Personal contacts
 4A. Nature of contacts 	4A-2 	50
 4B. Purpose of contacts 	4B-2 	75
5. Difficulty of typical work 
directed			5-4 	505
6. Other conditions 		6-2 	575

 Total 					2,105

In accordance with the grade conversion table in the GSSG, a
total of 2,105 points converts to grade GS-10.

Evaluation using the GS-644 standard

The GS-644 standard is written in FES format. Under the FES,
positions are placed in grades on the basis of their duties,
responsibilities, and the qualifications required as evaluated in
terms of nine factors common to nonsupervisory General Schedule
positions. A point value is assigned to each factor based on a
comparison of the position's duties with the factor-level
descriptions in the standard. The factor point values mark the
lower end of the ranges for the indicated factor levels. For a
position to warrant a given point value, it must be fully
equivalent to the overall intent of the selected factor-level
description. If the position fails in any significant aspect to
meet a particular factor-level description in the standard, the
point value for the next lower factor level must be assigned,
unless the deficiency is balanced by an equally important aspect
which meets a higher level. The total points assigned are
converted to a grade by use of the grade conversion table in the
standard.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information or
facts that a worker must understand to do acceptable work (such
as the steps, procedures, practices, rules, policies, theories,
principles, and concepts) and the nature and extent of the skills
needed to apply this knowledge.

At Level 1-6, the work requires professional knowledge of the
established principles, concepts, and methods of medical
technology (for example, cytotechnology) and skill in applying
this knowledge in performing and monitoring the full range of
specialized tests and nonroutine procedures for which there are
standard methods and techniques (that is, methods and techniques
are well-established, that apply to most situations encountered,
and that can be carried out with minor modification or
adaptation) in one or more areas of a clinical laboratory.
Knowledge of laboratory mathematics and statistics sufficient to
establish quality controls, troubleshoot procedures and
equipment, calculate and correlate test results, and set up and
implement new procedures is at this level. This level also
requires knowledge of related disciplines (for example,
histology, cytology, pharmacology, pharmacokinetics, anatomy,
physiology, epidemiology, genetics). In addition, this level
requires knowledge of the significance of certain clinical and
physiologic conditions (for example, conditions affecting hormone
secretion) sufficient to use such knowledge in assessing and
correlating data and verifying results (for example, evaluating
certain stains prepared in histology, recognizing interfering
drugs or infectious diseases that can cause abnormal results,
assuring proper collection and preservation of specimens,
performing therapeutic drug monitoring).

Level 1-6 describes knowledge and understanding of recognized
reference standards, medicolegal requirements, regulatory and
accrediting agency requirements, and pertinent statutes
sufficient to use such knowledge in performing/monitoring
diagnostic tests (for example, maintaining chain of custody when
a specimen is submitted for medicolegal reasons so as not to
affect the legality of the results, using and storing controlled
substances in an appropriate manner, assuring that blood and
blood products meet prescribed specifications, reporting
notifiable diseases to proper authorities). Some positions
require knowledge of instructing techniques and practices
sufficient to use such knowledge in instructing students and
others in the basic principles and specialized methods of one or
more areas of medical technology (classroom or bench teaching).

At Level 1-7, the work requires professional knowledge of medical
technology applicable to a wide range of duties in one or more
specialty areas or functions. The work also requires a high
level of skill in applying this knowledge in solving very complex
problems involving diverse aspects of clinical laboratory
practice (for example, conducting a variety of specialized tests
of greater than average difficulty, as in the more esoteric
laboratory areas of virology, histocompatibility, tissue typing,
or cytogenetics) or in a discipline that is undergoing
significant development, where procedures require frequent
modification and change in order to incorporate revised theories
and techniques; modifying or adapting established methods to
improve or extend test systems; and evaluating, modifying, or
adapting new methods to meet the requirements of particular
testing situations.

Positions at Level 1-7 require knowledge of regulatory,
licensing, and accrediting agency requirements, medicolegal
responsibilities, and statutes governing clinical laboratory
operations sufficient to use in planning, implementing, or
monitoring laboratory programs and services (for example,
determining needs, assuring compliance with standards). Further,
this level requires management, administrative, or coordinative
knowledge and skill sufficient to provide advisory, reviewing,
inspecting, education and training, or problem-solving services
(as a troubleshooter, specialist, or coordinator) on specific
problems, projects, programs, or functions (for example,
developing, reviewing, and evaluating the implementation of work
plans, including estimates of personnel, equipment and supplies,
and the detailed instructions necessary to carry out the plans
for complex long-term projects such as designing a clinical
laboratory information management system that provides reports of
results, interpretative information, and special reports).

Similar to Level 1-6, the appellant's work requires knowledge of
established cytology principles, methods, and concepts to perform
the full range of standardized tests and complex analyses of
nonroutine tests; skill and ability to instruct students and
staff in new or revised operating procedures; and the ability to
revise and implement changes in local operating procedures. He
must have skill in the operation and maintenance of laboratory
equipment and familiarity and knowledge of professional
laboratory and accreditation standards and requirements to
perform quality control and quality assurance responsibilities.
The appellant evaluates, modifies, or adapts new methods or
revises standard techniques to improve the accuracy, precision,
sensitivity, specificity, or proficiency of test analyses and to
improve diagnostic capabilities of the laboratory. He does not
have authority to develop new procedures because of the legal
liability associated with the work.

Although the techniques and methods used by the appellant may be
complex, they are universal and standard (that is, methods and
techniques are well established, apply to most situations
encountered, and require application of standard skills and
training to perform complex analysis) and are typical of Level 1-
6. Further, the appellant uses techniques that are dependent
upon the type of test requested by the clinician. He does not
modify or develop alternative testing methods to perform
diagnostic evaluations. Only a pathologist, scientist, or
medical researcher can modify or develop an alternative testing
method. The American Medical Association must approve any
changes to standard cytology testing.

The appellant's work in the specialized area of cytotechnology
relies primarily on standard operating procedures which are
updated based on changes to administrative, regulatory, and
medical standards as opposed to frequent changes in technical
requirements based on new or revised scientific or medical
research theories and technological advances. There is no
evidence that the appellant's case work involves a substantial
portion of diverse tests of greater than average difficulty than
is recognized by his profession or that his specialization is
frequently undergoing the type of significant theoretical and
technical development typical of Level 1-7. Therefore, Level 1-7
cannot be credited.

We evaluate this factor at Level 1-6 (950 points).

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect
controls exercised by the supervisor, the employee's
responsibility for carrying out assignments, and how completed
work is reviewed.

At Level 2-3, the supervisor makes assignments by defining
objectives, priorities, and deadlines and assists the medical
technologist with unusual situations that do not have clear
precedents. The medical technologist plans and carries out the
successive steps and handles problems and deviations in the work
assignment in accordance with established protocols, previous
training, or accepted laboratory practices. Judgment and
initiatives employed by the technologist include selecting and
implementing testing methods appropriate to the source and
characteristics of the specimen; monitoring, controlling, and
assessing the events of reactivity (for example, test conditions,
chemical and physical events, instrument performance);
recognizing conditions which cause erroneous results (for
example, blood typing from heparinized blood, superficial
contamination of specimens collected from body sites containing
indigenous or colonizing bacteria); troubleshooting complex
instruments; and correlating test results with patient data
(history, physical findings, medications, and other laboratory
data) to verify results. When there is a need to deviate from or
modify procedures to correct a problem, the technologist makes a
literature search or consults with medical staff or technical
authorities and implements corrective action provided it is
consistent with accepted professional methodology. Completed
work is evaluated for technical soundness, appropriateness, and
conformity to policy and requirements. The methods used in
arriving at the results are not usually reviewed in detail. If
the technologist is alone (for example, on night shift, on call),
the supervisor may review reports after the fact.

At Level 2-4, the supervisor sets the overall objectives and
resources available. The medical technologist and supervisor, in
consultation, develop the deadlines, projects, and work to be
done. The medical technologist, having developed expertise in a
particular specialty or application area (for example, laboratory
information management, quality assurance), is usually assigned
continuing responsibility for independently planning and carrying
out a major laboratory program; resolving most of the conflicts
which arise; coordinating the work with others as necessary; and
interpreting policy in terms of established objectives. In some
assignments, the medical technologist also determines the
approach to be taken and the methodology to be used. The medical
technologist keeps the supervisor informed of progress,
potentially controversial matters, or far-reaching implications.
Completed work is reviewed only from an overall standpoint in
terms of feasibility, compatibility with other work, and
effectiveness in meeting requirements or expected results.

Although the appellant independently plans and carries out the
procedures necessary for performing his cytology work, he does
not plan and carry out a major laboratory program. A major
laboratory program, as described in OPM classification standards,
is a laboratory program that furnishes a variety of laboratory
services including a laboratory that offers a variety of
specialized testing services and procedures because of the
medical and specialized services offered by the hospital,
resident training programs, or a hospital equipped to handle the
most complex and unusual patient conditions; a reference
laboratory providing specialized laboratory services to other
laboratories; or a remote laboratory providing a diverse number
of laboratory services without pathologist or higher graded
medical technologist supervision. The appellant's laboratory
program is more limited than the type of laboratory program
described at Level 2-4.

We evaluate this factor at Level 2-3 (275 points).

Factor 3, Guidelines

This factor covers the nature of guidelines and the judgment
needed to apply them. Guides used in the field of medical
technology may include laboratory manuals and operating
procedures, manufacturers' protocols, medical orders, standard
textbooks, professional journals and literature, accepted
professional standards, agency policies and directives,
accreditation standards, and Federal and State laws and
regulations.

At Level 3-3, guidelines are available, including established
and/or experimental protocols, technical manuals and journals,
and agency/hospital regulations, but they are not completely
applicable to the work or they have gaps in specificity. The
medical technologist uses judgment in interpreting and adapting
guidelines and precedents for application to specific cases or
problems in accordance with established policies and accepted
theory; in setting up and adapting new tests for local use; and
in recommending changes to procedures to improve the reliability
of data, enhance services, and correct deficiencies.

At Level 3-4, administrative policies and precedents, laws,
regional or area directives, agency regulations, accreditation
requirements, and scientific references are usually applicable,
but they are stated in general terms. Guidelines for performing
the work are often scarce or of limited use, for example, when
there is insufficient information about the accuracy, precision,
reliability, and utility of new or controversial instruments or
techniques; when professional journals and other literature have
conflicting views on accuracy and reliability; or when
proven/valid methods of testing are lacking or incomplete. The
medical technologist uses initiative and resourcefulness in
deviating from or extending traditional methods and practices, or
in developing and recommending new or substantially modified
methods, criteria, or policies.

Comparable to Level 3-3, the appellant's guidelines include
technical manuals and journals, reference material,
manufacturers' guidelines and instructions (for example,
instrument handbooks, procedural manuals for testing kits,
control and calibration procedures), Federal regulations, and
agency and local hospital regulations, directives, and policies.
As at Level 3-3, these materials do not always specifically cover
every situation. The appellant must use sound professional
judgment in interpreting and adapting instructions and developing
protocols for new tests being introduced in the laboratory.

For positions at Level 3-4, available technical references seldom
apply, and the technologist is expected to develop new procedures
and methods or substantially modify guidelines to resolve
technical problems related to the diversity of laboratories in
the employee's program area. In contrast, the appellant is
responsible for applying judgment in interpreting and adapting
guidelines to develop local procedures in accordance with
established polices and accepted practices. There is a limit to
how much the appellant can deviate from accepted practices and
guidelines and still maintain the integrity of the tests and
quality control standards they must meet. Unlike Level 3-4, the
guidelines and instructions in the test kits, instrument
instructions, and quality assurance procedures, typically apply
to most of the appellant's routine work. The modifications or
adaptations to guidelines and procedures made by the appellant
are not of the extent intended to credit Level 3-4.

We evaluate this factor at Level 3-3 (275 points).

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 work includes a variety of duties involving
different processes and methods. Examples include collecting and
preparing specimens, preparing and controlling reagents,
calibrating or standardizing and maintaining instruments, and
performing complex analyses; conducting quality control
procedures on equipment, reagents, and products; setting up,
standardizing, and implementing new procedures. Decisions
regarding what needs to be done depend upon the analysis and
evaluation of collection techniques and conditions, specimen
characteristics, adequacy of reagents, instrument performance,
acceptability of control samples, results of quality control
procedures, and other variables such as physical or drug related
factors involved in each assignment. The chosen course of action
may have to be selected from many alternatives, for example, when
standards or control samples do not give acceptable values. The
work requires analyzing and interpreting a variety of conditions
and elements to verify or clarify results. Judgment is required
to apply a range of established approaches and solutions to
malfunctions.

At Level 4-4, the work typically involves full responsibility for
the technical aspects of a discipline or functional area of the
laboratory and includes a wide variety of duties involving
diverse and complex technical or administrative problems and
considerations (for example, evaluating, refining, and
implementing new methods and procedures for laboratory
systems/programs). Assignments involve such complicating factors
as practical economic or operating problems; inadequate or
discrepant information about the use and capabilities of new
instruments or methodologies; or requests for modified procedures
or test alternatives. The work typically requires determining
ways to extend standard test systems; modifying conventional
methods to produce acceptable results; developing new or revised
procedures and protocols using standard techniques; creating or
revising logic schema (within state-of-the-art) to determine
corrective action for problems; or refining existing criteria for
administering or evaluating programs.

The appellant's position fully meets the Level 4-3 criteria. The
appellant is responsible for all aspects of the cytology work
within the anatomic pathology laboratory. The work involves
preparing specimens and reagents; performing quality control
procedures and maintenance on equipment and instruments; and
conducting, evaluating, and interpreting test results. He
analyzes the adequacy and quality of the specimen; the
requirements of the test; the function of the equipment; the
validity of the data; and the correlation of the test results
with other patient data. When selecting alternative procedures
or adapting tests, the appellant applies accepted techniques and
practices.

The appellant's position does not meet the intent of Level 4-4
where the performance of unusually difficult or uncommon tests
and the frequent introduction of new methodologies and equipment
are typical. Although the appellant performs the more difficult
or infrequently requested tests, the procedures have been
previously developed or instructions are available with the test
kits. The appellant does not frequently develop new methods
(although he may alter procedures or make adaptations) or
frequently use or test new equipment. The equipment in the
laboratory is expensive and not frequently replaced. When new,
state-of-the-art equipment is purchased for the laboratory, the
manufacturer usually sends a representative to train
technologists in the use of that equipment.

We evaluate this factor at Level 4-3 (150 points).

Factor 5, Scope and effect

This factor covers the relationship between the nature of the
work (that is, 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 work involves performing and monitoring the
full range of specialized and nonroutine tests according to
established methods, reviewing and analyzing conventional testing
problems and recommending or implementing solutions to overcome
them, and setting up and developing protocols for new procedures.
The work affects the adequacy of clinical laboratory services or
research conclusions (and hence the correct diagnosis and
treatment of patients), the efficient operation of laboratory
systems and programs, and the effective management of laboratory
resources.

At Level 5-4, the work involves devising new or improved
techniques or solutions to complex technical problems in one or
more disciplines or functional areas; assessing the effectiveness
of various laboratory programs; providing advisory, planning, or
surveillance services to clinicians, laboratory directors, and
supervisors on specific functions, programs, or problems that are
particularly difficult, widespread, or persistent; or developing
procedural manuals or guidelines for major agency activities (for
example, developing and administering a proficiency testing
program for all laboratories testing for lead intoxication under
the national occupational exposure to lead standard; designing
and conducting training courses on the availability of newer and
more reliable diagnostic and quality control techniques in the
field of bacteriology for a national program to improve the
bacteriology laboratory services of State health departments; and
developing endocrinologic reference methods which can be used for
standardization of analytical methods by clinical laboratories).
Assignments typically involve problems that occur at a number of
laboratories within a broad geographic area or at a reference
laboratory that provides unique supplemental services to other
laboratories in a geographic area, or problems that are systemic
in nature involving major testing or quality assurance systems
and processes. The work directly influences the effectiveness
and acceptability of total laboratory systems/programs, the
operations of many laboratories in different localities or in
other Federal or State agencies, or the activities of
nongovernment laboratories.

Comparable to Level 5-3, the appellant provides diagnostic and
research support for the histopathologic and cytopathologic
services offered to veterans. The appellant's laboratory also
supports medical students and residency programs by providing
training in a specialized environment for histo-cytopathologic
studies. The appellant's work affects the outcome of the tests
performed in the laboratory, the diagnosis and treatment of
patients, and the quality of medical care provided to veterans.
Level 5-4 is not met in that the appellant's work does not
involve problems that are systemic in nature involving major
testing or quality assurance systems and processes, and it does
not affect total laboratory systems/programs (for example, a wide
range of agency activities, or the operation of laboratories in
other Federal or State agencies). Further, the appellant does
not develop procedural manuals or guidelines for major agency
activities (for example, designing and conducting training
courses on the availability of newer and more reliable diagnostic
and quality control techniques for a national program of State
health departments). He does not develop reference methods which
can be used for standardization of analytical methods by clinical
laboratories, as would be typical of positions at Level 5-4.

We evaluate this factor at Level 5-3 (150 points).

Factor 6, Personal contacts

This factor measures face-to-face contacts and telephone dialogue
with persons not in the supervisory chain.

At Level 6-2, contacts are with employees in the same agency, but
outside the laboratory (employees who generally are engaged in
different functions, missions, and kinds of work, for example,
representatives from various levels within the agency, such as
headquarters, regional, district, or field offices or from other
departments/services of the hospital or center), or with
individuals or groups from outside the employing agency in a
moderately structured setting. At this level, contacts are
generally established on a routine basis, the purpose of contacts
may have to be made clear, and the role and authority of one or
more of the parties may have to be identified.

Similar to Level 6-2, the appellant's contacts are primarily with
fellow employees in the anatomic pathology laboratory,
technologists, technicians, physicians, nurses, and other
hospital staff. Contacts also include patients and their
relatives, college students, inspection-accrediting agency
officials, and corporate representatives.

The appellant's contacts do not meet Level 6-3 where contacts are
typically individuals or groups from outside the employing agency
in a moderately unstructured setting (for example, where the
contacts are not established on a routine basis, the purpose and
extent of each contact is different, and the role and authority
of each party is identified and developed during the course of
contact). Examples of contacts at Level 6-3 include contractors;
inspectors; researchers; educators; community leaders; or
representatives of other Federal agencies, State, or local health
departments; or organized or ad hoc public action groups.

We evaluate this factor at Level 6-2 (25 points).

Factor 7, Purpose of contacts

The purpose of personal contacts ranges from factual exchange of
information to situations involving significant or controversial
issues and differing viewpoints, goals, or objectives. The
personal contacts that serve for the level selected for this
factor must be the same as the contacts that are the basis for
the level selected for Factor 6.

At Level 7-2, the purpose of contacts is to plan or coordinate
work efforts or to resolve operating problems by influencing or
motivating individuals or groups who are working toward mutual
goals and who have basically cooperative attitudes (for example,
coordinating work efforts or resolving operating problems
concerning test methods, unexpected results, schedules, etc.,
with other laboratory workers and physicians). Contacts may also
be for the purpose of clarifying problems of equipment use, test
accuracy, etc., with reference laboratories, product suppliers,
or equipment manufacturers or advising laboratory managers or
State representatives on the need for or the results of
inspections.

The purpose of the appellant's contacts meets Level 7-2 where
contacts with fellow workers are to resolve problems and exchange
information, and contacts with patients are to explain procedures
to be performed. Likewise, the appellant's contacts with co-
workers are to exchange information, coordinate the work of other
technologists, and resolve problems with equipment.

The appellant's position does not meet Level 7-3 where the
purpose of the contacts is to influence, motivate, or persuade
persons or groups. Persons contacted are typically skeptical or
uncooperative. The technologist at this level must be skillful
in approaching the individual or group to obtain the desired
outcomes, such as gaining compliance with accrediting and
regulatory agency requirements by persuasion or negotiation and
negotiating and resolving difficult problems with suppliers or
contractors involving discrepancies, price adjustments, quality
control, and similar matters.

We evaluate this factor at Level 7-2 (50 points).

Factor 8, Physical demands

The physical demands placed upon the appellant are best evaluated
at Level 8-2 where the work requires long periods of standing and
walking, some bending and carrying of moderately heavy articles,
and assisting patients to achieve proper positioning. The
appellant's work requires regular and recurring physical exertion
such as prolonged standing, sitting at a computer, walking, and
lifting moderately heavy items.

We evaluate this factor at Level 8-2 (20 points).

Factor 9, Work environment

This factor considers the risks and discomforts in the employee's
physical surroundings, and the safety precautions required.

At Level 9-2, the work involves regular and recurring exposure to
moderate risks or discomforts which require special safety
precautions (for example, working in a hospital laboratory where
there is risk of exposure to contagious diseases, carcinogenic
materials, caustic reagents, noxious fumes, flammable liquids,
and low-level radiation). Protective clothing or gear is
required.

The appellant's working environment meets Level 9-2. The
appellant is exposed to high-risk biohazards such as Hepatitis B
Virus, Human Immunodeficiency Virus, carcinogens, and chemical
hazards as described by OSHA regulations. The appellant must
take and assure compliance with special safety precautions.

We evaluate this factor at Level 9-2 (20 points).

Summary

Factor 					Level 	Points
1. Knowledge required by the position 	1-6 	950
2. Supervisory controls 		2-3 	275
3. Guidelines 				3-3 	275
4. Complexity 				4-3 	150
5. Scope and effect 			5-3 	150
6. Personal contacts 			6-2 	25
7. Purpose of contacts 			7-2 	50
8. Physical demands 			8-2 	20
9. Work environment 			9-2 	20

 Total 1,915

A total of 1,915 points falls within the grade point range (1,855-
2,100) for GS-9 according to the grade conversion table in the GS-
644 standard.

Decision

The appellant's position is properly classified as GS-601-10 with
the title at the discretion of the agency.