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Interactive Public Docket

COMMENT BY: Missouri Department of Labor and Industrial Relations
SUBJECT:Against proposed revision to OMB Circular A-110
DATE:March 15, 1999

Dear Mr. Charney:

The Missouri Department of Labor and Industrial Relations has the following comment to the proposed revision of OMB Circular A-110.

The revision that permits public access to data used by the federal government places a large and unnecessary burden on the federal government to review documents from other sources to determine if they are confidential.

For example, Missouri state law prohibits the public disclosure of earnings reports from employers that identify employees by name. However, such information may be used to analyze the success of the Missouri Unemployment Insurance Program. If the report was prepared using grant money from the federal government, then all the underlying data would have to be forwarded to a federal agency when a FOLA request is received. The federal agency would then have to determine if the data is subject to an exempt