FR 2020-29197

The document from the Federal Register outlines a new information collection initiative by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), a Department of Justice agency. The ATF plans to use a form called the Prohibited Persons Questionnaire to evaluate whether potential federal employees or contractors are disqualified from possessing firearms or explosives under specific U.S. laws. Public comments are being sought to assess the necessity, accuracy, and methodology of this newly proposed collection method. The form is expected to be completed by approximately 2,000 individuals per year, with each submission taking around 5 minutes, thus projecting a collective annual burden of 167 hours.

Significant Issues and Concerns

One key issue is the document's insufficient explanation of the Questionnaire's necessity for the ATF's operations. While it states its purpose, it does not provide the context to understand how it fits into the ATF's broader objectives or why it is crucial for employment considerations. This lack of clarity leaves questions on its practical utility.

Additionally, while the projected public burden appears mathematically sound, the reasoning behind the need for this data collection isn't wholly justified. More context about how these questions align with legal standards for firearm and explosive possession would provide better transparency.

The document also omits information on how respondents’ personal data will be securely managed. With potential sensitive data being collected, assurance of data protection measures would be vital to allay privacy concerns.

Another concern is the document's lack of alternative methods to reduce the burden on respondents. Mentioning any digital or automated options could highlight efforts to streamline the process and make it more accessible.

Moreover, the role and authority of Melody Braswell, the Department Clearance Officer, is referenced but not fully explained, leaving ambiguity about her role in the process.

Finally, the language used to request public comments is somewhat formal. A simpler approach might encourage wider participation from the public, enhancing the feedback's quality and breadth.

Potential Impact on the Public

This document potentially impacts both the broader public and specific stakeholders. For the general public, particularly those applying for ATF roles, this questionnaire adds a layer of compliance to the employment process. It introduces a relatively modest time burden per applicant, but collectively, it becomes significant.

For stakeholders such as current or prospective employees and contractors of the ATF, this questionnaire may introduce uncertainty or concern regarding privacy and the intended use of the collected information, especially without clear data protection assurances.

On a positive note, properly implemented, this process could enhance ATF's ability to comply with legal standards, potentially improving agency integrity and public safety by ensuring that employees meet federal safety regulations.

Positive and Negative Impacts on Stakeholders

For ATF stakeholders, primarily future employees and contractors, the Questionnaire could serve as a preventive measure, reinforcing the importance of compliance with federal firearm and explosive possession laws. This can positively impact public safety and the agency's standing.

Conversely, stakeholders might view the Questionnaire and the lack of detailed information regarding its necessity and data management practices negatively. Concerns over privacy, data security, and the administrative burden could overshadow the intended safety benefits.

In conclusion, while the introduction of the Prohibited Persons Questionnaire reflects an effort by the ATF to align with legal requirements, the document would benefit from more details regarding its rationale, necessity, and implementation to fully inform and reassure affected parties.