| Comment Number: | OL-9800000 |
| Received: | 2/14/2005 1:44:47 PM |
| 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:
The Confidential Employee definition in Subpart I at Fed. Reg. pages 7569, 7570, 7595, 7598 needs to be expanded to include all personnel who have access to the automated communications between management officials and their technical advisors. The computer technicians at Departmental information management organizations are the effective key custodians of the computer networks that contain management draft documents and confidential communications and emails. It is a conflict of interest for bargaining unit members to have this breadth of access to privileged management information. This is consistent with the rationale for excluding clerical personnel workers and lawyers.