The “Alcohol Consumption” criterion under the Adjudicative Guidelines For Determining Eligibility for Access To Classified Information affects many security clearance applicants, particularly those who have received alcohol counseling and those who have been involved in alcohol-related incidents, such as drunk driving, disorderly conduct, and public intoxication.
Others who have been cautioned by a superior about alcohol use or experienced work, social, legal, financial, or health problems as a result of drinking can also be affected.
The adjudicative guidelines state that “Excessive alcohol consumption often leads to the exercise of questionable judgment or the failure to control impulses, and can raise questions about an individual’s reliability and trustworthiness.” Simply stated, alcohol abusers are more likely than others to engage in careless or impulsive behavior that can create an increased risk of unauthorized disclosure of classified information.
EVALUATING ALCOHOL CONSUMPTION
When does drinking become a security concern? Alcohol is legal and its consumption, regardless of quantity, does not by itself trigger a security concern. Alcohol consumption becomes a concern when there has been:
- Alcohol-related incident or other evidence of impaired judgment or misconduct while under the influence of alcohol.
- Negative impact on work/school performance, finances, personal or professional relationships.
- Failure to comply with court-ordered alcohol education, evaluation, treatment, or abstinence.
- Diagnosis of alcohol abuse or alcohol dependence by a qualified medical professional.
- Relapse after completion of an alcohol treatment program.
Absent a diagnosis of alcohol abuse or alcohol dependence, investigators and adjudicators look for indicators of current abuse or dependence. These indicators include:
- Attempts or perceived need to cut down on drinking.
- Annoyance or anger when criticized about drinking.
- Feelings of guilt about drinking and how it affects other aspects of life.
- Drinking first thing in the morning to steady nerves or get rid of a hangover.
- Claims of high tolerance for alcohol.
- Drinking prior to social events.
- Drinking extensively alone.
- Drinking that causes or increases social, work, school, financial, legal or heath problem.
MITIGATING SECURITY CONCERNS
The following conditions may mitigate alcohol consumption concerns:
Problem is not serious. A single recent alcohol-related incident (or even two incidents spaced a few years apart) may not suggest a serious alcohol problem, provided there has not been a diagnosis of alcohol abuse or dependence and there are no other indicators of current abuse or dependence.
Problem is not recent. Absent any current indications of abuse, serious problems that occurred 2 to 5 years ago (depending on seriousness/number and change in drinking habits/lifestyle) may no longer be an issue.
Positive changes in behavior. The applicant acknowledges their alcohol dependence or abuse and has demonstrated consistent abstinence (if alcohol dependent) or responsible use (if alcohol abuser). There have been positive lifestyle changes and other actions to overcome the problem. These could involve alcohol education, avoiding people, places, and activities associated with drinking, changing residences, leaving school and entering the workforce, changing jobs, getting married, having children, as well as involvement with healthy recreational activities or volunteer/social organizations. At least 6 months of positive changes in drinking habits and lifestyle may mitigate 1 or 2 recent serious alcohol incidents.
Rehabilitation. Successful completion of a treatment program (including any required aftercare program), consistent pattern of reduced consumption or abstinence in accordance with treatment recommendations for at least 12 months after treatment, and a favorable prognosis by a qualified medical professional may mitigate security concerns. When there has been no formal treatment, persuasive evidence of abstinence or consistent responsible alcohol use for at least 12 months may also mitigate security concerns.
Alcohol problems involving people who already have a security clearance may be sufficiently mitigated, if they participate in a treatment program with satisfactory progress and have no previous history of treatment and relapse.
Interim clearances can be declined when any potential security issue exists. Disclosure of alcohol-related counseling or any alcohol-related incident (criminal or non-criminal) on the clearance application form can create a presumption of an alcohol consumption issue. Often this issue can be mitigated by the information collected during a security clearance investigation. But interim clearances require issue mitigation before the investigation is completed. The clearance application form (Questionnaire for National Security Positions, Standard Form 86—SF86) asks about alcohol-related counseling, incidents, and “negative impact,” but it does not ask for information that might mitigate alcohol concerns. Applicants are allowed to include mitigating information in their SF86 (or its electronic equivalent known as eApp) by using the “Continuation Space” at the end of the paper version or by using the “Comment Section” following each question on the eApp version. Including mitigating information in this manner is often a determining factor in the granting of an interim clearance.
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