Adjunct Instructor Justification

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Department of Justice
Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF)
Information Collection Request (ICR)
OMB 1140-0099
ATF Adjunct Instructor Data
(ATF Form 6140.3)

SUPPORTING STATEMENT


A.	JUSTIFICATION
1. Explain the circumstances that make the information collection necessary.

The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) provides law enforcement and investigation training to ATF employees and other federal, state, local, and international law enforcement personnel. Training covers numerous topics using both internal (ATF employees) and external technical experts from various disciplines. External instructors are non-ATF experts and may be from other law enforcement agencies, fire and rescue departments, professional organizations, or academia. Due to the nature of law enforcement and related training, ATF must maintain detailed records on the instructors’ qualifications and expertise.

An instructor’s record includes their contact information, areas of expertise, educational and professional background, and professional vita or curriculum vitae. ATF must retain these records to maintain its Federal Law Enforcement Training Accreditation (FLETA) and to maintain a legally defensible training program. In some legal cases, it may be necessary to not only show that a specific individual received training, but also demonstrate that qualified instructors provided the training in a consistent manner. ATF uses the Adjunct Instructor Data Form, ATF Form 6140.3, to collect the necessary personally identifiable information (PII) from non-ATF employees to document and evaluate their qualifications to serve as an ATF instructor. 5 CFR 410, which permits agencies to collect and maintain training records per the agency’s identified needs, authorizes ATF to collect this data.

2. Indicate how, by whom, and for what purpose the information will be used.

Individuals who are interested in being adjunct instructors for ATF voluntarily submit the information on ATF Form 6140.3, and submit it to ATF’s Human Resource and Professional Development (HRPD) directorate. ATF uses the collected data to identify and contact individual instructors, validate their topical expertise prior to training delivery, and defend their topical expertise during a court proceeding. Additionally, the form contains a “hold-harmless” agreement (HHA), which clarifies that an adjunct instructor is unable to claim compensation benefits for injuries or accident that might occur during travel to provide ATF training courses. The adjunct instructor’s organization is responsible for addressing any liability related to such accident or injury, unless gross negligence can be proven.

3. Describe whether, and to what extent, the information collection involves using automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronically submitting responses, and the basis for the decision to adopt this means of collecting.

ATF Form 6140.3 is an electronically fillable, 508c-compliant form, which can be downloaded from the ATF website. The form is fillable and can be electronically completed, digitally signed, and electronically submitted to ATF for processing.

4. Describe efforts to identify duplication.

ATF’s HRPD directorate is comprised of several divisions and branches, whose personnel are responsible for developing and managing training for different areas of expertise and audiences. Depending on the nature of the subject matter, the same instructor may be used for multiple programs. To prevent collecting duplicative information on instructors, HRPD’s Leadership and Professional Development division within the Training Accreditation branch collects, maintains, and manages all instructor records for ATF. Instructors therefore do not need to submit their information more than once. The information collected is specific to ATF training activities and is not collected anywhere else either within ATF or externally.

5. If the information collection impacts small businesses or other small entities, describe any methods used to minimize burden.

This information collection does not have a significant impact on small entities.

6. Describe the consequences to federal programs or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Collecting this information is necessary for ATF training program personnel to verify and defend the qualifications of its incoming instructors. The collected information supports training records required for ATF’s continued training accreditation, as decided by the FLETA Board established by the Office of Management and Budget and funded through congressional appropriations. The FLETA Board is comprised of representatives from federal law enforcement agencies, who meet to set standards for delivering and administering federal law enforcement training.

If ATF does not collect the designated information, it would not meet the FLETA requirements and would be unable to offer law enforcement training. In addition, individuals already trained pursuant to ATF courses would no longer be able to validate their training and expertise in court cases. ATF collects the information only once per instructor or when the instructor submits an update to their information, so collecting the information less frequently would result in the same impact as not collecting it at all.

7. Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with 5 CFR 1320.6.

There are no special circumstances associated with this information collection, which is conducted in a manner consistent with 5 CFR 1320.6.  However, in situations in which a previously scheduled instructor is unexpectedly unavailable, a new candidate may need to complete the form in a timeframe less than 30 days, so ATF can select and schedule a replacement instructor in a timely manner prior to the training.

8. If applicable, provide a copy, and identify the date and page number, of the agency’s notice published in the Federal Register, as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submitting to OMB.

The 60-day notice was published in the Federal Register on 10/16/2026 (91 FR 65779). The comment period ended on 12/15/2026. ATF received no comments. ATF published the 30-day notice on [DATE] (xx FR xxxxx), with an OMB comment period ending on [DATE].

9. Explain any decision to provide any payments or gifts to respondents, other than remuneration of contractors or grantees.

ATF does not provide payments or gifts in connection with this collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

ATF has not assured respondents of confidentiality. However, the information being collected includes PII and is thus protected by the Privacy Act. The information is maintained by ATF in a system of records, Justice/ATF-10, Training and Professional Development Record System. The form that accompanies this ICR includes a Privacy Act statement that covers this information and informs respondents of the system of records, routine uses, etc.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

This information collection does not ask questions or require information of a sensitive nature.

12. Provide estimates of the information collection’s hour burden.

There are ten respondents annually who provide information covered by this ICR. Each respondent provides information one time, so the annual number of responses is also ten. The form takes 30 minutes (0.5 hours) to complete. Therefore, the total annual burden associated with this collection is five hours (10 respondents * 0.5 hours (30 minutes)).

To calculate hourly wage burdens for this ICR, ATF used the wage rates for Police and Sheriff's Patrol Officers for May 2023, as determined by the U.S. Department of Labor, Bureau of Labor Statistics (BLS).1 BLS determined the average hourly pay for private sector workers to be $36.80. They also determined that a load rate of 1.42 was appropriate to account for benefits, making the loaded wage rate $52.27 ($36.80 * 1.42).2,3,4 The monetized value for this ICR is therefore $261.35 annually (rounded) ($52.27 loaded hourly wage rate * 5 hours).

Activity
Number of respondents
Frequency
Total annual responses
Time per response (hours)
Total annual burden (hours)
Hourly rate*
Monetized value of respondent time
Completing instructor form
10
1
10
0.5
5
$52.27
$261.35


13. Provide an estimate of the total annual cost burden to respondents or record-keepers resulting from the information collection. (Do not include the cost of any hour burden shown in items 12 and 14).

There are no start-up or other additional costs associated with this information collection and respondents submit the form electronically so there are no postage costs.

14. Provide estimates of the annualized cost to the federal government.

There are no costs to the federal government associated with this collection. This is due to the current staffing and administrative capacity already in place to complete any marginal processing required under this information collection, with long-term staffing capacity serving as a sunk cost.

15. Explain the reasons for any program changes or adjustments.

ATF is making no program changes or revisions to this information collection or the form. However, there has been an overall decrease in the number of annual respondents, from 20 during the last approval of this ICR to 10 now. This has therefore resulted in a corresponding decrease in the annual total hourly burden from ten hours to five hours. ATF has also made minor edits to the form for plain writing purposes.

16. For information collections whose results will be published, outline plans for tabulations and publication.

ATF does not publish the results of this collection.  
17. If seeking approval to not display the expiration date for the information collection, explain the reasons that display would be inappropriate.

ATF intends to display the OMB expiration date for this information collection.

18. Explain each exception to the certification statement.

This information collection does not include any exceptions to the certification statement.

B. INFORMATION COLLECTIONS EMPLOYING STATISTICAL METHODS.

This collection does not employ statistical methods.