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

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

Job Grading Appeal Decision
Under sections 5103 and 5346 of title 5, United States Code


	Appellant:		[appellants name]

	Agency classification:	Medical Equipment Repairer
				WG-4805-11

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

	OPM decision:		Medical Equipment Repairer
				WG-4805-11

	OPM decision number:	C-4805-11-02


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

August 3, 2001
___________________________________
Date


As provided in section S7-8 of the Operating Manual: Federal
Wage System, this decision constitutes a certificate that is
mandatory and binding on all administrative, certifying, payroll,
disbursing, and accounting officials of the government. There is
no right of further appeal. This decision is subject to
discretionary review only under conditions and time limits
specified in section 532.705(f) of title 5, Code of Federal
Regulations (address provided in the Introduction to the Position
Classification Standards, appendix 4, section H).


 Decision sent to:

[appellant's name and address]

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

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



Introduction

On March 21, 2001, the Dallas Oversight Division of the U.S.
Office of Personnel Management (OPM) accepted an appeal from [the
appellant]. He works as a Medical Equipment Repairer, WG-4805-
11, in the [unit within a hospital], Department of Veterans
Affairs, [city, state]. Believing his job should be classified
as Electronics Technician, GS-856-10, the appellant filed an
appeal with the Department of Veterans Affairs. The Department's
decision of February 15, 2001, sustained the local servicing
personnel office's assignment of the appellant's work to the
Federal Wage System as WG-4805-11. In his appeal to OPM, the
appellant states that his job should be placed in the General
Schedule because he is performing work that was previously
assigned to an employee in a GS-856-10 Electronics Technician
position. We have accepted and decided the appeal under sections
5103 (pay category) and 5346 (Federal Wage System job grading
appeals) of title 5, United States Code (U.S.C.).

To help decide this appeal, an Oversight representative held
telephone conversations on June 28, 2001, with the appellant and
on July 11, 2001, with his immediate supervisor. In reaching our
decision, we have reviewed information gained from these
conversations and all material of record furnished by the
appellant and his agency, including the appellant's official job
description [number].

General issues

The appellant makes various statements about his agency and its
evaluation of his work. He identifies specific duties that he
believes warrant placement of his job in the General Schedule
because they were previously assigned to a GS-856-10 Electronics
Technician position. In adjudicating this appeal, our only
concern is to make our own independent decision on the proper
classification of the appellant's job. We cannot compare the
appellant's duties to those in other jobs or positions as a basis
for deciding his appeal. By law, we must make our decision
solely by comparing the appellant's current duties and
responsibilities to OPM standards and guidelines (5 U.S.C. 5346).
Therefore, we have considered the appellant's statements only
insofar as they are relevant to making that comparison.

Job information

The [appellant's specific Veterans Healthcare System] includes
[the hospital] where the appellant works and a campus in [a
nearby city]. The [appellant's unit] provides service to both
facilities. The appellant's supervisor is located at the [name]
campus and is routinely on site at the hospital in [the city
where the appellant works] one or two times a week.

The appellant's duties include maintaining, troubleshooting, and
repairing a wide variety of the medical equipment such as
electronically-controlled incubators, endoscope processors, steam
and ethylene oxide sterilizers, microprocessor-controlled
equipment, and surgical tables and lights. When not repairing
medical equipment, the appellant is responsible for first-call
maintenance of elevators, translogic and pneumatic tubes,
dietetic equipment, dumbwaiters, floor buffers, trash chutes, and
linen chutes. He is responsible for routine preventive
maintenance procedures, electrical inspection of new equipment,
and the modification of equipment at the manufacturer's request.
The work requires knowledge of electrical and electronic
circuitry; steam; chemical sterilization; and mechanical vacuum
pressure systems. Skill in using tools and test equipment and
the ability to use schematics, drawings, and technical
specifications to troubleshoot, isolate, and determine cause of
the malfunction are also required.

Pay category determination

Section 5102(c)(7) of title 5, United States Code, exempts from
coverage under the General Schedule those "employees in
recognized trades or crafts, or other skilled mechanical crafts,
or in unskilled, semiskilled, or skilled manual-labor
occupations, and other employees including foremen and
supervisors in positions having trade, craft, or laboring
experience and knowledge as the paramount requirement." The
Introduction to the Position Classification Standards defines
paramount requirement as the essential, prerequisite knowledge,
skills, and abilities needed to perform the primary duty or
responsibility for which the position has been established.
Whether particular types of positions are trades, crafts, or
manual labor occupations within the meaning of title 5 depends
primarily on the most important requirement for the performance
of a primary duty or responsibility for which the position
exists. If a position clearly requires trade, craft, or laboring
experience and knowledge as a requirement for the performance of
its primary duty, and this requirement is paramount, the position
is under the Federal Wage System regardless of its organizational
location or the nature of the activity in which it exists.

The Introduction also says that a position is exempt from the
General Schedule if its primary duty involves the performance of
physical work which requires knowledge or experience of a trade,
craft, or manual labor nature. The Introduction further states
that a position is subject to the General Schedule, even if it
requires physical work, if its primary duty requires knowledge or
experience of an administrative, clerical, scientific, artistic,
or technical nature not related to trade, craft, or manual-labor
work.

Maintenance and repair work is typically regarded as trade or
Federal Wage System work and usually performed in or from a shop,
while evaluation and design work is typically regarded as
technician or General Schedule work and usually performed in a
laboratory or under the direction of an individual with
professional training in the appropriate field of work. For
example, the job grading standard for Medical Equipment Repairer,
4805, states, "Medical equipment repairers install, modify,
troubleshoot, maintain, test, calibrate, adjust, overhaul, and
repair a wide variety of medical, laboratory, and dental
equipment (electronic, electrical, and mechanical)." The
standard excludes such work, however, when it is performed by
technicians incidental to the development and evaluation of
medical equipment. Development and evaluation are engineering
functions and, therefore, when nonprofessionals perform such
work, it is often to support a professional engineer who actually
directs the work.

The standard for Medical Equipment Repairer, 4805, is used to
grade nonsupervisory work involved in the installation,
maintenance, overhaul, repair, and testing of various medical and
dental equipment used in patient diagnosis and treatment and in
research laboratories. This work requires a knowledge and
application of mechanical, electrical, and electronic principles
and circuitry, the ability to determine malfunctions, and the
skill to repair and maintain a variety of medical, laboratory,
and dental equipment.

Characteristic of positions in the GS-856 Electronics Technician
Series is the requirement for theoretical knowledge about the
fields of electricity, electronics, physics, and, in some cases,
engineering mechanics, that is less than full professional
engineering knowledge but which nevertheless enables the
technician to understand how and why a specific device or system
embodying electronic principles operates. Electronics technician
positions require the ability to follow schematic diagrams and
block diagrams and in many cases to construct devices in
accordance with more or less detailed instructions (dependent
upon the requirements of the assignment). At the higher grade
levels, electronics technicians modify or elaborate upon basic
electronic designs in order to make them work in accordance with
the engineering objectives which have been set. While many
electronics technicians may combine their knowledge of electronic
theory and the ability to use their hands and tools to carry out
their assignments, the knowledge of electronic theory is the
paramount requirement of the assignment and the manual dexterity
and skill is secondary. The GS-856 series is not intended to
cover positions where employees are not required to understand
and apply a practical knowledge of electronic theories and
principles, even though they are dealing with electronic
equipment.

Even though installation, maintenance, repair, and testing are
mentioned in the GS-856 standard, it is the design, development,
and evaluation work that is considered paramount and controls the
pay category. Regular and significant technical evaluations,
development of specialized circuits or components, and complex
modifications to standard medical equipment are hallmarks of
electronics technician work. Such duties are noticeably absent
from the appellant's job.

The majority of the appellant's duties include maintaining,
repairing, and troubleshooting medical equipment. These duties
are reflected in the appellant's performance plan which lists
four elements for evaluation: repair, troubleshooting,
installation, fabrication, and preventive maintenance; safety;
ADP security; and customer service. Copies of work orders and
other information provided by the appellant and his supervisor
indicate that the appellant spends a large portion of his time
repairing specialty patient beds, electric patient beds,
incubators, and gas and steam sterilizers. He also maintains and
repairs automatic and roll-up door sensors and environmental
management equipment such as floor buffers and translogic and
pneumatic tubes. The appellant modifies equipment as requested
by the manufacturer. The appellant's regular and recurring work
assignments and the limited degree to which he performs
modification work clearly do not require the knowledge and
ability necessary for an electronics technician position.

We conclude that the paramount requirement for the appellant's
job is the performance of work which requires the application of
knowledge and experience typical of the Federal Wage System.
Therefore, the job is excluded from the General Schedule.

Occupation, title, and standard determination

The appellant's job best fits in the Medical Equipment Repairer,
4805, occupation which covers jobs that involve the installation,
maintenance, overhaul, repair, and testing of various medical and
dental equipment used in patient diagnosis and treatment and in
research laboratories. The job grading standard for Medical
Equipment Repairer prescribes the title Medical Equipment
Repairer for jobs at grade 10 and above. As explained in the
next section of this decision, the appellant's job is graded at
the 11 level. Therefore, the appropriate title for the appealed
job is Medical Equipment Repairer.

Grade determination

The job grading standard for Medical Equipment Repairer, 4805,
defines work at only the grade 11 level. It indicates that the
level of skill and knowledge and other work requirements
described may warrant grading above or below the 11 level. The
standard uses four factors for determining grade level: skill
and knowledge, responsibility, physical effort, and working
conditions. Our assessment of each factor follows.

Skill and knowledge

The appellant's work requires the skill and knowledge to
troubleshoot and repair to component level state-of-the-art gas
and steam sterilizers, incubators, endoscope processors, surgical
lights, electric patient beds, translogic and pneumatic tubes,
and various other mechanical equipment. The work requires
knowledge of the use of tools and test equipment, such as
multimeters, to troubleshoot to component level in both discrete
and integrated circuits. As an example of troubleshooting, the
appellant said a problem with the sterilization system for
endoscopes could be with the sterilizer itself or the
microprocessor that controls the chemical sterilization. If the
problem lies with the microprocessor, the appellant identifies
the error message and then presses the proper pre-programmed key
to restart the program. If it is an equipment problem, he must
identify the malfunction and replace the defective part(s). He
does not repair the microprocessor but calls in a contractor for
that type of repair. Good hand and eye coordination is necessary
for working with small components. The appellant must be skilled
in reading and interpreting electronic, electric, and mechanical
schematics, diagrams, and other technical literature.

The skill and knowledge required for the appellant's medical
equipment repair duties are comparable to the grade 11 level. As
described in the standard, medical equipment repairers at the
grade 11 level apply a practical knowledge of the principles of
electronic circuits and functions of electronic tubes and
transistors to diagnose malfunctions and repair, and test
electronic equipment. Repairers apply a practical knowledge of
the principles and theories governing the maintenance and repair
of electrical equipment in order to diagnose malfunctions and to
repair and test such electrical equipment as sterilizers.
Repairers at this grade level also have a knowledge of the
relationships between electrical and electronic circuitry as well
as the interrelationship of chemical, hydraulic, pneumatic,
vacuum, or gas components of a piece of equipment or system.
They have the ability to repair mechanical equipment such as
sterilizers and other mechanical assemblies, and they select
replacement parts. At this level, repairers must have good hand
and eye coordination to work with small components. They use
skill in the use of electronic test equipment multimeters and
have the ability to use electrical test equipment such as test
meters. Workers at this level have the ability to interpret and
apply blue prints, schematic drawings, technical manuals, and
other specifications.

This factor is credited at the grade 11 level.

Responsibility

The appellant works under the general supervision of the [unit's]
supervisor. Because the supervisor spends most of his time at
the campus in [a nearby city], the appellant completes nearly all
of his assignments without supervision. As at the grade 11
level, the appellant receives work orally or through work orders,
independently determines the nature of trouble and extent of
repairs required, and completes repairs by following established
trade practices and procedures using technical manuals and other
specifications. If the appellant is unable to make repairs, he
contacts the manufacturer for technical assistance, or he orders
and replaces equipment or parts. He checks repairs made by
contractors and signs off on their completed work. He assures
new equipment is within prescribed limits for electrical safety
and follows preventive maintenance procedures to assure equipment
is in proper working order, similar to workers at the grade 11
level who assure that equipment is working within prescribed
limits so that lives are not endangered. As at the grade 11
level, the appellant's supervisor spot checks work for compliance
with trade practices, directives, and operating procedures.

This factor is credited at the grade 11 level.

Physical effort

As at the grade 11 level, the appellant's work assignments
involve standing, stooping, bending, kneeling, and climbing. The
appellant must also maintain intense concentration and awkward
positions for long periods, often under adverse conditions. He
must have excellent hand and eye coordination and must be able to
lift more than 35 pounds.

This factor is credited at the grade 11 level.

Working conditions

Comparable to the grade 11 level, the appellant's environment
ranges from work in a well-lighted shop to on-site repair in user
locales within the hospital. The appellant works in proximity to
lethal voltage, current, and gases. During repair of some
equipment, he may be exposed to infectious diseases.

This factor is credited at the grade 11 level.

Decision

The job is properly exempt from the General Schedule and placed
under the Federal Wage System as Medical Equipment Repairer, WG-
4805-11.