1140-0056 justification

Department of Justice

Bureau of Alcohol, Tobacco, Firearms and Explosives

Information Collection Request, 1140-0056

Supporting Statement

ATF F 2300.10 Special Agent Medical Preplacement

A. Justification

1. 5 CFR 339.301 provides the authority to require a routine pre‑appointment examination for a position with specific medical standards. Medical standards are part of the qualification standards for positions in the Federal government. In general, there must be a direct relationship between the medical standard or physical requirement and the actual duties of the position being filled. Failure to meet an established medical standard of physical requirement means that the individual is not qualified for the position. Medical requirements for positions that involve arduous/hazardous duties or require a high standard of human reliability are based on the arduous or hazardous nature of the duties typically performed in most of the positions covered.

Criminal Investigator ‑ Enforcement Agent, GS‑1811, has been identified as a position that has specific medical requirements. The qualification standard for Criminal Investigator ‑ Enforcement Agent is published in the Qualification Standards Operating Manual beginning at page IV‑B‑229, with the medical requirements for the Enforcement Agent on pages IV‑B‑231 and IV‑B‑232. These medical requirements are part of the basic qualification requirements for the position.

Pre‑appointment medical information is currently being required. It is collected now on two forms. One is the United States Civil Service Commission Certification of Medical Examination, Standard Form No. 78, October 1969 (Revision) and the other is Report of Medical History, Standard Form 93, Rev. June 1996. Both are Office of Personnel Management forms. They are generic forms that are used for any position, not just for Criminal Investigators. Therefore, they are not specific to the duties of the position. Additionally, they do not capture information that is essential in the evolution of law enforcement. For example, they do not address the issues of blood lead or the use of respirators. When these forms were developed, many of the environmental factors Criminal Investigator – Enforcement Agents are routinely exposed to today, were not considered or perhaps didn't exist.

ATF F 2300.10, Special Agent Medical Preplacement replaces two existing generic forms and address the specificity of the duties of the Criminal Investigator ‑ Enforcement Agent. The form collects specific identifiable data, these elements are name, address, telephone, social security number and certain medical data.

2. The information on the form must be collected in order to determine whether or not an applicant is actually qualified for the position. The information will be initially used to make a recommendation on either hiring or not hiring an applicant for the Criminal Investigator ‑ Enforcement Agent. It will be further used by management officials in making the management decision on whether to hire or not to hire.

3. ATF F 2300.10 is not available on the ATF website because the form is specifically used by special agents who are applying for a specific criminal investigator position with ATF. This position has specific medical standards and physical requirements. The information on the form is used to determine medical suitability for the position. The special agent completes the first half of the form and the doctor/health care provider completes the second half. When the form is completed, it is FedEx to Law Enforcement Medical Programs in Atlanta, GA by the health care provider.

4. ATF uses a subject classification code on all ATF forms. This code ensures that there is no duplication within ATF. Guidelines for the development and management of all ATF forms are contained in ATF O 1322.1B, Forms Management Program.

5. The collection of this information will not impact small businesses or other small entities.

6. If pre‑appointment medical information is not collected, we will be unable to determine whether or not an applicant is qualified for the position of Criminal Investigator - Enforcement Agent.

7. The pre‑appointment medical examination is a one‑time examination. There are no special circumstances associated with this information collection.

8. Collection of pre‑appointment medical information for positions in the Federal government has been a requirement for qualification determination since at least 1947. The ATF Personnel Division and the ATF Recruitment Branch were consulted in the creation of this form. A 60-day and 30-day Federal Register notice was published in order to solicit comments from the public. No comments were received.

9. No payment or gift will be made to any respondent for this information collection.

10. Medical records are part of a Government‑wide Privacy Act system of records. 5 CFR

293.504, Composition of, and access to, the Employee Medical File System sets the

assurance of confidentiality. ATF F 2300.10 is maintained in a secured room and

employees that process the form have a special clearance.

11. There are specific medical questions that are asked in order to determine medical suitability to qualify for a position that has specific medical standards and physical requirements.

12. We estimate that 300 agents will be selected for employment. Each agent will respond

1 time. We estimate that it will take the agent 30 minutes to complete his portion of

the form and medical personnel will take approximately 15 minutes to complete the form for

a total of 45 minutes. Therefore, the total burden will be 225 hours. The form will be

maintained in the Personnel Division for as long as the agent is employed with the

Bureau of Alcohol, Tobacco and Firearms.

13. The health care provider sends the form by FedEx to Atlanta, GA at a cost of $5.76 per form. The total cost associated with this information collection is $1,728.00.

14. Estimated cost to the Federal government would be approximately $300.00 for in‑house

printing of the form.

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

16. Results of this information collection will not be published.

17. The Bureau of Alcohol, Tobacco and Firearms requests that the expiration date not be

printed on the form. There is no expectation of changes in the form unless there are

significant changes in the position. The collection of medical information for

pre‑appointment is an on‑going process. We believe printing costs would be kept at a

minimum if we did not have to reprint every three years to accommodate an expiration

date.

18. There are no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

None

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