Comment Number: | OL-10504718 |
Received: | 3/10/2005 9:19:00 AM |
Subject: | Notice of Proposed Rulemaking, Request for Comment |
Title: | National Security Personnel System |
CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
No Attachments |
Comments:
In discussing the process by which NSPS was developed, the developers indicate that substantial employee input was garnered. Perhaps that is true, but this office did not hear anything about it until it was announced that NSPS was going to be implemented. Even then, we did not know the substance until it was published on the web. On page 7555 of the Federal Register, there is a significant amount of discussion about *senior* this and *senior* that; it is apparent that the workforce was not really represented, especially in the Working Group. There was a lot of management representation and representation by self-described subject matter experts, but very little workforce representation. There seems to have been a little bit of involvement of the unions, but very little workforce involvement. You know ... not everyone subscribes to the union beliefs and practices. In fact, employees are conspicuously absent from the development of NSPS. That is really a shame because the smartest people do not always rise to the top or choose to go beyond the workforce level. This substantial lack of involvement of the workforce is apparent in the way that NSPS is management-centric.