ENVIRONMENTAL DIFFERENTIAL AND HAZARD PAY (EDP) PLAN

CHAPTER 532 ENVIRONMENTAL DIFFERENTIAL AND HAZARD PAY (EDP) PLAN

........................................................................................................................................532-1
General Information..................................................................................................532-1
Purpose:.....................................................................................................................532-1
Objective....................................................................................................................532-1
Definitions..................................................................................................................532-1
Responsibilities.........................................................................................................532-3
Environmental Differential Pay (EDP).....................................................................532-5
Hazard Differential Pay (HDP)..................................................................................532-7
Establishing EDP/HDP Situations...........................................................................532-8
Resubmission of Requests for Review................................................................532-10

ATTACHMENT 1 REQUEST FOR APPROVAL OF EDP/HDP (IDNG Form 53R)...532-12

1. General Information. This chapter contains the Idaho National Guard’s plan and
guidelines for consideration of situations that may qualify for EDP/HDP. It establishes
procedures for submitting requests for situation review and establishes a committee to
conduct assessments and make recommendations for payment of the differential. The
Human Resource Officer has the Adjutant General’s delegated authority to make decisions
concerning differential pay.

2. Purpose. The purpose of this regulation is to establish policies and procedures for the
implementation and administration of Environmental Differential Pay/Hazard Differential
Pay (EDP/HDP).

3. Objective. The Idaho National Guard’s objective is to eliminate or reduce to the lowest
level possible, all hazards, physical hardships and working conditions of an unusually
severe nature. When these efforts do not correct the unusually severe nature of the
hazard, physical hardship, or working condition, EDP/HDP is warranted. Even though an
environmental differential is authorized, supervisors must continue to diligently pursue
measures that may eliminate danger and risk which contribute to or cause the hazard,
physical hardship, or working condition of an unusually severe nature.

4. Definitions.

a. Environmental Pay Differential: A method of payment to a Federal Wage System

(FWS) employee who is exposed to a hazard, physical hardship, or working condition of an
unusually severe nature, as listed under the categories in 5 CFR 532, Parts I or II.

b. Payment for actual exposure: A payment authorized to a technician for the actual
hours of exposure to the condition. Payment for actual exposure is an environmental pay
differential subject to 5 CFR 532, Part I.
 c. Payment for Hours in Pay Status: A payment authorized to a technician for all hours
he/she is in a pay status during the day on which the exposure occurs, including hours in a
paid leave status. Payment for hours in pay status is an environmental pay differential
subject to 5 CFR 532, Part II.

d. Hazardous Pay Differential: Additional pay for a General Schedule (GS) employee
for the performance of irregular or intermittent hazardous duty or duty involving physical
hardship listed under the categories in Appendix A of CFR 550.

e. Hazardous Duty: A duty performed under circumstances in which an accident could

result in serious injury or death.

f. Physical Hardship: A duty which may not in itself be hazardous but which causes
extreme physical discomfort or distress, and which is not adequately alleviated by
protective clothing or mechanical devices.

g. Practically Eliminated: The term “practically eliminated” does not require a complete
or absolute elimination of potential injury. This term does not mean “virtually” as that would
require a higher standard to be applied than is normally accepted in safety and
occupational health standards or other applicable Air Force, Army or DoD instructions.
The term is more correctly defined as “almost” and is more consistent with the intent of the
language of the Code of Federal Regulations (CFR). The CFR requires that potential
injury be “practically eliminated” and as such, total elimination of the hazard is not required
nor expected.

h. Qualification for Payment: For a technician to qualify for EDP or HDP, a work
situation will be approved by work center as circumstances are expected to vary between
bases, installations, states, etc. In certain instances, the Human Resource Office (HRO)
may authorize an approved situation to be used at more than one location.

i. Unusually Severe: Working conditions that are unusually severe include those
conditions which are “not taken into consideration in the job-grading process” FWS Pay
Administration §S8-7. In other words, Position Descriptions (PD) may already describe
work of a hazardous nature or with inherent risk involved. Therefore, the work situation is
considered “usual” and pay has already been considered in the grading process.
However, where the situation includes elements of unavoidable hazard or risk that are not
covered in the PD, and the type of duty is covered in Hazardous Duty Differentials,
(Appendix A, 5 CFR 550), or in Environmental Differentials, (Part I and Part II, 5 CFR 532),
it is considered unusually severe and EDP/HDP may be payable.
5. Responsibilities.

a. Employees: Employees at all levels must insure every effort is made to protect
themselves and others from potential hazards or physical hardships. If a hazard or
physical discomfort cannot be eliminated, then compensation must be provided to a
technician through Differential Pay.

b. The Adjutant General:

(1) The Adjutant General will appoint a State EDP committee to review requests and
make recommendations to the Human Resource Officer (HRO).

(2) The Adjutant General is the approving authority for local EDP/HDP and has
delegated that authority to the Human Resource Officer.

c. The Human Resource Officer (HRO):

(1) Render staff assistance concerning this plan to managers, supervisors, labor
organizations, employees and the State EDP/HDP Committee.

(2) The HRO is authorized to approve/disapprove all EDP/HDP situations.

(3) The HRO or a designated representative will serve as the Chairperson and a non-
voting member of the State EDP/HDP committee.

(4) The HRO will ensure that all approved EDP/HDP situations are reviewed and re-
certified at least annually by the State EDP/HDP Committee. When the level of risk in the
work place has been reduced to generally accepted standards such as the DoD, DA, DAF,
or OSHA standard, EDP/HDP shall be discontinued.

(5) Ensures the appropriate technician payroll office is promptly informed of approved
work situations and their corresponding EDP/HDP rates.

(6) Assists in reviewing and processing of unique hazards that are not covered in the
applicable CFR for consideration by OPM for inclusion.

d. The State EDP/HDP Committee:

(1) At a minimum, the EDP/HDP Committee will consist of two representatives (one air,
one army) from the following areas. The Adjutant General may appoint additional
members.

 Human Resource Officer (non-voting member)

 State Safety Offices
 Environmental Office
 Occupation and Public Health Office
  Classification Specialist
 Labor Organization Representative (appointed in writing by the Local Union)
 Executive Secretary (non-voting member)

(2) The supervisor responsible for submitting each of the current situations being
reviewed will be invited to meetings.

(3) Each member will ensure an alternate member is appointed to serve in his or her
absence.

(4) If all committee members are not in attendance, a quorum will consist of the HRO or
his/her representative and at least 3 committee members.

(5) Will meet by direction of the Adjutant General or the committee chairperson to
review requests for EDP situations.

(6) Will recommend differential payment approval/disapproval to the HRO.

(7) Will conduct an assessment of EDP/HDP requests and prepare a thorough report
explaining the research conducted, the standards by which each of the requests were
evaluated and therefore, findings and recommendations. These reports will be prepared
and ready for committee review generally within 30 days of the date sent from HRO.
Exceptions to the 30 days must be requested of and approved by the HRO.

e. Supervisors:

(1) Must ensure that safety practices and acceptable work procedures are followed. In
those instances where a hazardous situation cannot be avoided, a request to establish
HDP/EDP (IDNG Form 532/550) must be prepared and forwarded through supervisory
channels to the Human Resource Office.

(2) Upon receipt of a request to establish an HDP/EDP situation, the supervisor must
assess the situation. He/She will review safety/health regulations, and consider any other
means available to the supervisor to reduce the hazardous environment – specifically by
reviewing the situation with appropriate specialists in the Safety Office or the Public/
Occupational Health offices. If the supervisor cannot improve the situation, he/she will
provide his/her recommendations and forward the situation through proper supervisory
channels.

(3) Supervisors and managers do not have the authority to approve or disapprove a
request to establish an HDP/EDP situation. Each supervisory/managerial level must
forward the request to the next higher level within 10 working days of receipt.

(4) Where EDP/HDP has been approved for payment, supervisors must diligently
continue to work toward reducing the element of hazard. When the level of risk in the work
place has been reduced to generally accepted standards, such as those accepted by DoD,
DA, DAF, or OSHA, supervisors must submit an IDNG Form 532/550 A, EDP/HDP
Change. This report details the change that may discontinue the EDP/HDP.

f Technician Responsibilities:

(1) Notify your immediate supervisor when hazards or unusually severe working
conditions exist.

(2) If there are any severe physical hardships or exposures which cause significant
physical discomfort or distress, the technician is responsible for submitting a detailed CA-1
to his/her supervisor.

6. Environmental Differential Pay (EDP).

a. Introduction: EDP is authorized by 5 CFR 532. EDP is in addition to any other pay
and allowances to which a technician is authorized. It is not part of basic pay and may not
be used to compute any additional pay which is payable under another law.

b. Coverage: Environmental Differential Pay applies only to Wage Scale Technicians

as authorized by OPM, NGB and this regulation. Personnel assigned to General Schedule
(GS) positions cannot be tasked with a situation governed by 5 CFR 532. EDP will be paid
in accordance with applicable regulations and only for those situations approved by the
Adjutant General or his designated representative.

c. Basis for EDP:

(1) Environmental differentials are paid for those work situations in which a potentially
severe hazard exists and the level of risk to the technician exceeds generally accepted
standards. Examples of unusually severe hazards for which EDP could be authorized are:

(a) A high structure when the hazard is not eliminated by protective facilities such as
scaffolding, enclosed ladders, etc.

(b) A high open structure when adverse conditions such as darkness, lightning, steady
rain, snow, sleet, ice, or high winds exist.

(c) Exposure to an unusually severe physical hardship under circumstances which

cause significant physical discomfort or distress, which cannot be eliminated by protective
devices.

(d) Exposure to unusually severe working conditions involving exposure to fumes, dust,
or noise which cause significant distress or discomfort in the form of nausea, skin, eye, ear
or nose irritation; or conditions which cause abnormal soiling of body or clothing.

(2) Environmental situations do not qualify for differential compensation solely because
an element of hazard or discomfort has been identified in a work situation. The hazard
must involve a real threat with no effective measures available to protect the technician
from discomforts or threat of injury. A technician must experience significant actual
discomfort arising from the work situation with no effective means available to relieve the
discomfort. The hazard or discomfort in a job situation must be such that the technician is
exposed to unrelieved discomfort or to potential injury or harm significantly beyond that
experienced by other technicians or the general population from the same source.

(3) EDP will not be paid for positions that include hazardous conditions that are
recognized and compensated for in the technician’s position description or classification
standard.

(4) If no effective measures are available to protect the technician from the serious risk
or unusually severe effects of the work environment, appropriate compensation through
environmental differential pay will be provided.

d. Payment for EDP Situations:

(1) An environmental differential is paid to Wage Grade (WG) technicians who are
exposed to a hazard, physical hardship, or working condition of an unusually severe nature
for which an approved situation exists.

(2) These payments are made only in those instances where the exposure, physical
hardship or working conditions of an unusually severe nature are not taken into
consideration in the job-grading process, and additional pay for exposure to these
conditions is provided only through the authorized environmental differentials in this
regulation.

(3) A technician subjected at the same time to more than one hazard, physical hardship,
or working condition of an unusually severe nature shall be paid for the exposure which
results in the highest differential but shall not be paid more than one differential for the
same hours worked.

(4) Establishing the Environmental Differentials. Environmental differentials are stated

as percentage amounts and are authorized for categories of exposures in 5 CFR 532,
Parts I and II. Calculating the differential is explained in 5 CFR 532.

(5) Recommendations for changes to the approved situations, or requests to establish

new situations will be processed through the State EDP Committee to Office of Personnel
Management (OPM) for approval.

(6) EDP is paid on an actual exposure basis (Part I) or basis of hours in pay status (Part
II) as set forth in 5 CFR 532.
7. Hazard Differential Pay (HDP).

a. Introduction: This chapter provides the details necessary to implement HDP in the
Idaho National Guard Technician Program, as authorized by 5 CFR 550. HDP is in
addition to any other pay and allowances to which a technician is authorized. It is not part
of basic pay and may not be used to compute any additional pay which is payable under
another law.

b. Restrictions: HDP is only paid to General Schedule (GS) technicians. In order to be

eligible for HDP, a GS technician must be performing hazardous duties or duties involving
physical hardship. It should be noted that it is highly improbable that HDP situations will
occur in the Idaho National Guard. However, should such a situation arise, affected GS
technicians will receive differential pay in accordance with (IAW) the prescribed
regulations. These situations require review and pay approval by the Adjutant General of
Idaho or his designated representative.

c. Situations:

(1) Duty involving physical hardship means a duty, which may not in itself be
hazardous, but which causes extreme physical discomfort or distress which is not
adequately alleviated by protective or mechanical devices, and, the duty is covered in
Appendix A, 5 CFR 550.

(2) Situations that could qualify for HDP are:

(a) Duty requiring exposure to extreme temperatures for a long period of time.

(b) Duty involving hard physical exertion, such as a duty that must be performed in
cramped conditions.

(c) A duty involving exposure to fumes, dust or noise, which may cause nausea, or a
skin, eye, ear or nose irritation.

d. Limitations on use of HDP:

(1) HDP will be terminated when adequate safety precautions have reduced the hazard
to a level “consistent with generally accepted standards that may be applicable, such as
those published by OSHA; or when protective or mechanical devices have adequately
alleviated physical discomfort or distress.” (5 CFR 550).

(2) HDP will not be paid for positions that include hazardous conditions that are
recognized and compensated for in the technician’s position description (usually identified
in Factor 8 and 9 in the Position Evaluation Statement).

e. Payment of HDP: Hazardous Pay Differential calculations are explained in 5 CFR

550.
8. Establishing EDP/HDP Situations.

a. General: Individuals or supervisors may initiate requests to establish EDP/HDP

situations when they believe an unusually severe hazardous or environmental risk to
employees exists.

b. IDNG Form 532/550, Request for Approval of EDP/HDP: All requests for review will
be submitted on an IDNG Form 532/550, Approval of EDP/HDP, (See Attachment 1) The
form will be completed as follows:

(1) Section 1. Administrative data. Consult 5 CFR 532, parts I or II, or Appendix A of 5
CFR 550 and select the appropriate category and differential rate.

(2) Section 2. Descriptive Information.

(a) Unusually Severe Duty Description. Provide a detailed description of the duty and
what specifically is unusual about the severe conditions being reported. For example, if
“dirty work” is the category applicable to the work condition being reported, then the
description must justify the unusually severe nature of dirty work over and above what
would normally be expected in this occupational series. In addition, include the length of
time this situation is likely to exist (months, years, indefinite).

(b) Comparable Situations. Provide any personal knowledge or researched information

gathered on similar situations in the State of Idaho that can be investigated and compared
to the situation being reported.

(c) Historical Data on this Situation. Describe situations and give statistics on incidents
or injuries that have occurred because of exposure to the hazard or physical hardship. For
example, 3 of 5 employees have submitted CA1s documenting respiratory problems since
the introduction of and exposure to new processes.

(d) Past Efforts to Practically Eliminate the Situation. Supervisors should document all
their efforts to eliminate the situation being reported. For example, if multiple solvents
have been researched and tried already, in an effort to eliminate the physical discomfort
and irritation experienced by the employees, write down what they were and why they did
not either satisfactorily accomplish the work or practically eliminate the condition. This will
assist the committee members in their effort to research and assess the situation.

(e) Justify the Work Requirements. The essential requirement for the work assignment
must be explained; describe the available protection that is used to reduce the effect of the
adverse environmental conditions as much as possible; and confirm the absolute minimum
number of technicians who must be exposed to the potential hazard or severe discomfort
and still ensure the mission is accomplished.
 (3) Section 3. Attachments. Submit the following attachments with IDNG Form
532/550, Request for Approval of EDP/HDP.

(a) A current position description.

(b) Classification and grade levels of technicians performing the work.

(c) Technical operating instructions of the hazardous situation.

(d) All applicable safety, industrial hygiene, and/or environmental directives covering the
situation.

c. Submit the request to the supervisor for coordination. The completed and
coordinated request will be forwarded to the Human Resource Office, Attn: EDP/HDP
Executive Secretary, for action.

d. The EDP/HDP Executive Secretary will log in the request and forward it to the
Committee members for review, assessment, coordination and suspense. Before the
State EDP/HDP committee meets to review and make determinations on the proposed
situation, the committee members will conduct their assessments and write reports of their
findings and submit them to the Committee’s Executive Secretary. This will be done within
30 days.

e. State EDP/HDP committee will meet and follow these procedures:

(1) Establish concurrence or non-concurrence of committee members based on the

submitted reports. The Executive Secretary will have a summary sheet prepared on each
situation indicating each committee member’s position.

(2) Minority reports will be reviewed and the submitting committee member will be given
an opportunity to present the reasons for his/her recommendation.

(3) Questions

(4) Vote

f. The Human Resource Officer is the final approval authority for EDP/HDP situations.

g. Upon approval, the HRO will determine the effective date of a situation.

h. All IDNG Form 532s submitted will be kept in historical files by the Executive
Secretary.

i. Prior to a vote, the State EDP/HDP committee may, if deemed necessary, return a
request to the originator for more information.
9. Resubmission of Requests for Review. When a previously reviewed situation is
deemed changed and the supervisor believes it warrants another review he/she may
resubmit the original request with a new IDNG-EDP/HDP Form 1 requesting review. The
request will go through the coordination process to HRO. It will describe the specific
change in circumstances that warrants another review.
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HQ IDNG REG (ARNG) 690-201/HQ IDNGI (ANG) 36-502, 31 JAN 06 532-12

ATTACHMENT 1

REQUEST FOR APPROVAL OF EDP/HDP

REQUEST FOR APPROVAL OF EDP/HDP

The following local work situation is submitted in accordance with 5CFR 532/550 (as appropriate),
and HQ IDNG Reg (ARNG) 690-201/HQ IDNGI (ANG) 36-502 Personnel Manual (Technicians),
Chapter 532/550.
This request is submitted for determination of For HRO Use:
entitlement to differential pay under provisions of: Log Number:_________________________
Date Received:_______________________
30 Day Report Suspense: ______________
Committee Review Date: ______________
 Hazard Pay  Environmental Pay Annually Review in (month):_____________
Section 1. Administrative Data
To: From: Date of Request:
Title of Applicable Category Requested: Differential Rate:
Section 2. Descriptive Information
A. Unusually Severe Duty Description. Provide a detailed description of the severe hazard,
physical hardship, or working condition that is the subject of this request. Include the length of time
this situation is likely to exist (months, years, indefinitely). Use a continuation sheet if necessary.

B. Comparable Situations. Describe local situations of which you are aware that could be
investigated and compared to the situation being reported.

C. Historical Data. Describe the measurable impact of the current work situation.

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D. Past Efforts. Describe Past Efforts to Practically Eliminate the Situation.

E. Justify the Work Requirements. Address the essentiality of the work; describe existing
protective measures; give the minimum number of employees who must be exposed in order to
accomplish the mission.

Section 3. Attachments. Ensure the following documents are attached to this request before submission
through supervisor and Commander/Director to HRO.
 Current Position  List, by name, the  Applicable technical  All other applicable
Description (s) technicians affected, operating instructions safety, industrial
their PD Control hygiene, and/or
number, Pay plan, environmental
Classification series, directives covering the
and Grade Level. situation.
Section 4. Supervisory Coordination
Submitted by: (Typed or printed name, rank, and position)

Supervisors of Submitter through Commander/Director in turn:

Your signature indicates your review of this request. Please concur or nonconcur with remarks.
Typed/Printed name, rank and Signature Date  Concur
position:
 Nonconcur
Remarks :

Typed/Printed name, rank and Signature Date  Concur

position:
 Nonconcur
Remarks :

Typed/Printed name, rank and Signature Date  Concur

position:
 Nonconcur
Remarks :

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Section 5. Committee Coordination

Report
Attached Report written Recommendation Remarks
Y/N/ by:
NA
 Concur
Classification Specialist
 Nonconcur
 Concur
Safety Specialist
 Nonconcur
 Concur
Environmental Specialist
 Nonconcur
 Concur
Occupation and Public
Health Specialist  Nonconcur
 Concur
Labor Union
Representative  Nonconcur
Notes on Committee Discussion:

Section 6. HRO Determination

 Decision is made to approve differential at a rate of:

Typed/Printed name and Signature Date

signature of the HRO

 Decision is made to disapprove differential based upon the following findings:

Typed/Printed name and Signature Date

signature of the HRO

IDNG FORM 53R (DEC 03) (3 of 3) PREVIOUS VERSIONS OF THIS FORM ARE OBSOLETE