1140-0099_Adjunct_Instructor_Justification 2.14.2017 - 508

Department of Justice

Bureau of Alcohol, Tobacco, Firearms and Explosives

Information Collection Requirement

Supporting Statement

OMB # 1140-0099

ATF Adjunct Instructor Data Form, ATF Form 6140.3

A. Justification

1. ATF provides law enforcement and arson investigation related training to Bureau employees and Federal, State, and local law enforcement personnel. Training covers numerous topics using both internal and external technical experts from various disciplines. Internal instructors consist of those individuals who are ATF employees; however, external instructors may be contractors or volunteers from other law enforcement agencies, fire and rescue departments, professional organizations, or academia. Due to the nature of law enforcement and related training, detailed records must be kept regarding the conduct of training and the expertise of the individuals providing the instructing. Individual records include contact information as well as areas of expertise, educational and professional backgrounds, and professional vitas. Such records are critical in maintaining a legally defensible training program and are required for Federal law enforcement training accreditation. In such legal situations, it may be necessary to not only show that a specific individual received training, but that training was provided in a consistent manner by qualified instructors. The ATF Adjunct Instructor Data Form will be used to collect the necessary information from non-ATF employees to uniquely identify individual instructors and to document their qualifications. The collection of this data is authorized through 5 CFR 410.602 which provides for the maintenance of training records as per an agency’s identified needs.

2. The information will be collected by the Human Resource and Professional Development Directorate of the Bureau of Alcohol, Tobacco, Firearms and Explosives. The information collected on this form will provide ATF with data sufficient to identify and contact the individual instructors, validate instructor topical expertise prior to training, and defend an instructor’s qualifications in court regarding topical expertise. In addition, the data form contains a “Hold Harmless” agreement notifying that adjunct instructor that they will not be able to claim compensation benefits from ATF in the event of an accident during or in route to training. The adjunct instructor or his/her parent organization will be responsible for addressing liability in regards to injury unless gross negligence can be shown.

3. Currently, ATF does not have a method of collecting the information electronically as the use of electronic signatures has yet to be adopted by the Bureau. However, the respondent will be able to complete the form and send it as an email attachment. Where possible, checkboxes have been incorporated into the form in order to minimize the burden on the user.

4. The Human Resource and Professional Development Directorate consists of a number of divisions and branches responsible for developing and managing training for differing areas of expertise and audiences. However, due to the nature of the topical matter, the same instructor may be used for multiple programs. In order to prevent duplication of effort, the management of instructors is centralized with the Professional/Technical Training and Development Branch. This branch is responsible for the collection and maintenance of instructor records for the training directorate. The information collected is specific to ATF training activities and is not collected anywhere else either within the Bureau or externally.

5. The collection of this information does not have any significant impact on small business or other entities.

6. The collection of this information is necessary in order for ATF training programs to verify and defend the qualifications of instructor personnel. In addition, the information supports training records necessary for the accreditation of training with the Federal Law Enforcement Training Accreditation (FLETA) board. The FLETA Board was established jointly by the Office of Management and Budget and congressional appropriations as a body of Federal law enforcement agencies that sets standards for the administration of law enforcement training in the Federal government.

7. There are no special circumstances regarding this information collection and it is in conformance within the guidelines of 5 CFR 1320.6 with one possible exception. In situations where a previously scheduled instructor is unexpectedly unavailable, then the form may need to be completed in less than 30 days after receipt in order to select and schedule a new instructor in a timely manner prior to the training.

8. No comments were received for either the 60-day or 30-day FR Notices published in the Federal Register.

9. No payment or gift is associated with this collection.

10. Respondents are advised that the information being collected will remain confidential and that the confidentiality of the information collected via this survey is protected by 5 U.S.C. 552 except where noted. Access to responses is secured.

11. No questions of a sensitive nature are asked.

12. Estimates of the annual burden hours are as follows:

    Number of Respondents	Ave 20 per year
    Frequency of Response	One time application
    Number of Responses	20
    Completion Time	30 minutes
    Total Burden	10 hours

13. There is no annual cost burden to the respondent as a result of this collection of information.

14. Estimates of the annual cost to the Federal Government are as follows:

    Printing	None
    Distribution (Electronic)	None
    Staff Salary (monthly review, analysis, and data entry, GS13 @ 2 hrs per month)	$ 1,008
    Total	$ 1,008

15. There are no program changes or adjustments associated with this collection.

16. The results of this collection will not be published.

17. ATF does not request approval to not display the expiration date of OMB approval for this collection.

18. There are no exceptions to the certification statement.

2. Statistical Methods

No.

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