"Role of Responsibility"?

I have been looking at the proposed changes to the FLSA and, although they aren't in effect yet, have been looking at our workforce to determine if any of them may be affected by these changes and have come up with two potential. The first one is the "senior estimating engineer" and the other is the "production scheduling supervisor" (although there isn't anyone she supervises). I know it's not the job titles but the duties that make the determination but in reading the regs. the administrative test addresses the fact that the employee has a "role of responsibility" within the organization. My thoughts are that you can claim that all positions have a "role of responsibility" but not all these jobs are exempt. I'm hoping some of you will be able to provide me with some advice and/or guidance for what you perceive this definition to be.

Thanks.
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