Civil Service Board recommends removing FACE requirement for sanitation inspectors; director agrees to review permanency

The City of Miami Civil Service Board investigated whether the Florida Association of Code Enforcement (FACE) Level 1 certification should be required for sanitation inspectors to attain permanent status. After hearing department testimony, union arguments and inspector testimony, the board recommended that FACE not be treated as a mandatory requirement for solid waste sanitation inspectors’ permanent appointment.

Wade Sanders, director of the Solid Waste Department, told the board the FACE requirement had been in some job postings and that the department initially offered to pay for the first exam; he also said he had worked with the union to remove some employees from a list when their job descriptions predated the requirement. Sanders said several supervisors who predated the requirement did not hold the certification. The department reported there are 12 inspectors in the unit and that three currently hold FACE Level 1 certification; the rest had not passed the certification despite multiple attempts and an offered study room.

Union counsel and AFSCME-represented inspectors, along with AFSCME Local 1907 representatives, said the FACE exam content overlapped with code-enforcement subject matter—construction and code topics—that are not central to sanitation-inspection duties and thus unfairly penalize otherwise-qualified inspectors. Counsel and union witnesses recounted a prior probationary case in which an otherwise satisfactory employee’s permanency was jeopardized only because of the FACE test outcome.

Board counsel cautioned that the board’s role was to investigate whether the FACE requirement was appropriate; management retains the right to set minimum qualifications, and collective bargaining questions could arise. After discussion, the board adopted a motion recommending that the FACE certification not be required as a condition of permanency for sanitation inspectors in the Solid Waste Department. The motion passed on a recorded/voice vote.

The director agreed on the record to act on the board’s recommendation and to address the single probationary inspector’s status; board members asked that the director consider making the inspector’s permanency effective retroactively to the employee’s one-year anniversary given the earlier confusion about job qualifications. Board counsel reminded members that formal promotion/permanency actions are management rights and that the board’s role is recommendation; the director signaled he would follow the board’s request.

The board’s recommendation applies to solid-waste sanitation inspectors and does not automatically change requirements in other departments. The board also asked the city and department to clarify job bulletins and whether alternative combinations of education and experience remain acceptable as stated on the posted job bulletin.