Digital BW, The Print

Thanks to all - I was trying to recreate a fatter version of Photokit's
"Soft Black Rule Fat".  I did a Select All/Border 35px then needed a solid
15px border without feather to "thicken" the black at the edge- all followed
by a little gaussian blur.  I now have a nice little action - thanks.  One
last question:  is there a way to record (in an action) a New Layer such
that it is always at the top of the stack (so-to-speak) regardless of which
layer might be selected when the action is run?