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Office of the Solicitor

U.S. Department of Labor Freedom of Information Act Annual Report for Fiscal Year 2005

U.S. DEPARTMENT OF LABOR
FREEDOM OF INFORMATION ACT ANNUAL REPORT
FOR FISCAL YEAR 2005 [1]

October 1, 2004 through September 30, 2005

The Department received a total of 23,505 initial requests for records during fiscal year 2005.

  1. Basic Information Regarding Report

  1. For questions concerning this report, please contact Joseph J. Plick, Counsel for FOIA/FACA/Privacy Act, Office of the Solicitor, Room N-2428, U.S. Department of Labor, 200 Constitution Avenue, N.W., Washington, D.C. 20210, telephone number (202) 693-5527.

  2. The electronic address for this report is on the World Wide Web at http://www.dol.gov/dol/foia/main.htm.

  3. You may obtain a paper copy of this report by writing to Mr. Plick at the above address.

  1. How to Make a FOIA Request

The Department of Labor is organized into divisions and agencies often referred to as "components." Within the Labor Department, each component processes its own FOIA requests. Therefore, a request will receive the fastest possible response if it is addressed directly to the disclosure officer for the component that a requester believes has the records.

Requesters who cannot determine the proper disclosure officer to which the request should be addressed may direct the request to the Office of Assistant Secretary for Administration and Management, U.S. Department of Labor, 200 Constitution Avenue, N.W., Room S-5526, Washington, D.C. 20210. Due to an update in the Department's FOIA regulations, after June 30, 2006, these requests should be directed to the Counsel for FOIA, Office of the Solicitor, Division of Management and Administrative Legal Services, 200 Constitution Avenue, N.W., Room N-2428, Washington, D.C. 20210 or by e-mail to foiarequest@dol.gov.

  1. The following list contains the names, addresses, and telephone numbers of the individual agency components and offices in the national and regional offices of the Department of Labor. The heads of each component shall make available for inspection and copying, in accordance with the provisions of the FOIA, records in their custody or in the custody of component units within their organizations, either directly or through their authorized representative in particular offices and locations. Unless otherwise specified, the mailing address for the following national office components is as follows:

U.S. Department of Labor
200 Constitution Avenue, N.W.
Room SL-33
Washington, DC 20210

  1. Office of the Secretary of Labor, (202) 693-7277.

  2. Office of the Solicitor of Labor, (202) 693-5527.

  3. Office of the Administrative Law Judges, 800 K Street, N.W., Suite N-400, Washington, D.C. 20001-8002, (202) 693-7440.

  4. Office of the Assistant Secretary for Administration and Management, (202) 693-7277.

  5. Office of the Assistant Secretary for Congressional and Intergovernmental Affairs, (202) 693-4630.

  6. Office of the Inspector General, (202) 693-5113.

  7. Office of the Assistant Secretary for Policy, (202) 693-5082.

  8. Office of the Assistant Secretary for Public Affairs, (202) 693-4654.

  9. Bureau of International Labor Affairs, (202) 693-4790.

  10. Bureau of Labor Statistics, Postal Square Building, Room 4040, 2 Massachusetts Avenue, N.E., Washington, D.C. 20212-0001, (202) 691-7628.

  11. Employment Standards Administration, (202) 693-0256.

  12. Employment and Training Administration, (202) 693-3140.

  13. Mine Safety and Health Administration, 1100 Wilson Boulevard, 21st Floor, Arlington, Virginia 22209, (202) 693-9424.

  14. Occupational Safety and Health Administration, (202) 693-1897.

  15. Office of the Assistant Secretary for Disability Employment Policy, (202) 693-4930.

  16. Employee Benefits Security Administration, formerly known as the Pension and Welfare Benefits Administration, (202) 693-8655.

  17. Office of the Chief Financial Officer, (202) 693-6806.

  18. Office of the Assistant Secretary for Veterans' Employment and Training, (202) 693-4745.

  19. Employees' Compensation Appeals Board, (202) 693-5028.

  20. Office of Adjudicatory Services, (202) 693-5028.

  21. Benefits Review Board, (202) 693-5028.

  22. The Office of Small Business Programs, (202) 693-6474.

  23. Women's Bureau, (202) 693-6735.

The addresses and telephone numbers for the various regional offices are presented below. The telephone number which is listed is for the Department's Office of Administration and Management (OASAM) for that region. That office can provide the requester with a more specific telephone number for the respective component. Unless otherwise specified, the mailing address for these regional offices by region, shall be:

Region I:

U.S. Department of Labor
John F. Kennedy Federal Building
One Congress Street
Boston, Massachusetts 02203
(617) 565-1991

(For Wage and Hour only: Contact Region III)

Region II:

U.S. Department of Labor
201 Varick Street
New York, New York 10014
(212) 337-2215

(For Wage and Hour only: Contact Region III)

Region III:

U.S. Department of Labor
The Curtis Center, Suite 600 East
170 S. Independence Mall West
Philadelphia, Pennsylvania 19106-3305
(215) 861-5030

Region IV:

U.S. Department of Labor
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, Georgia 30303
(404) 562-2018

(OWCP Only)

U.S. Department of Labor
214 N. Hogan Street, Suite 1006
Jacksonville, Florida 32202
(904) 357-4725

Region V:

U.S. Department of Labor
Kluczynski Federal Building
230 South Dearborn Street
Chicago, Illinois 60604
(312) 353-8373

(FECA only)

U.S. Department of Labor
1240 East Ninth Street, Room 851
Cleveland, Ohio 44199
(216) 357-5372

Region VI:

U.S. Department of Labor
525 Griffin Square Building
Griffin & Young Streets
Dallas, Texas 75202
(214) 767-6800

Region VII:

U.S. Department of Labor
City Center Square Building
1100 Main Street
Kansas City, Missouri 64105-2112
(816) 426-3891

(For Wage and Hour only: Contact Region V)

(OFCCP only)

U.S. Department of Labor
1100 Main Street, Suite 860
Kansas City, Missouri 64105
(816) 502-0370

Region VIII:

U.S. Department of Labor
1999 Broadway
Denver, Colorado 80202
(303) 844-1700

(For Wage and Hour and OFCCP: Contact Region VI)

(OWCP only)

U.S. Department of Labor
1999 Broadway, Suite 600
Denver, Colorado 80201
(720) 264-3038

The mailing address for the Director of the Regional Bureau of Apprenticeship and Training in Region VIII is:

Bureau of Apprenticeship and Training
U.S. Custom House
721 ‑ 19th Street, Room 465
Denver, Colorado 80202
(303) 844-4791

Region IX:

U.S. Department of Labor
71 Stevenson Street
San Francisco, California 94105
(415) 975-4057

Region X:

U.S. Department of Labor
1111 Third Avenue
Seattle, Washington 98101-3212
(415) 975-4057

(For Wage and Hour: Contact San Francisco)

  1. Agency response-time.

The agency's response-time ranges generally from five to fifty days. Complex requests usually take more time.

  1. Why some requests are not granted.

A FOIA request can be made for any agency record. This does not mean, however, that the Labor Department will disclose every record sought. There are statutory exemptions that authorize the withholding of certain information. In addition, the agency cannot comply with a FOIA request if there are no responsive records.

Another reason for not granting a FOIA request is that the FOIA does not require agencies to do research for the requester, to analyze data, to answer questions, or to create records in order to respond to a FOIA request.

  1. Definitions of Terms and Acronyms Used in the Report (To be included in each report)

  1. Agency-specific acronyms or other terms.

ALJ

Administrative Law Judges

ASP

Office of the Assistant Secretary for Policy

OPA

Office of Public Affairs

CFO

Office of the Chief Financial Officer

EBSA

Employee Benefits Security Administration

ESA

Employment Standards Administration

ETA

Employment and Training Administration

ILAB

Bureau of International Labor Affairs

BLS

Bureau of Labor Statistics

MSHA

Mine Safety and Health Administration

OSHA

Occupational Safety and Health Administration

OAS

Office of Adjudicatory Services

OASAM

Office of the Assistant Secretary for Administration and Management

OCIA

Office of Congressional and Intergovernmental Affairs

ODEP

Office of Disability Employment Policy

OIG

Office of the Inspector General

OSBP

Office of Small Business Programs

SOL

Office of the Solicitor

VETS

Veterans' Employment and Training Service

WB

Women's Bureau

  1. Basic terms, expressed in common terminology.

  1. FOIA/PA request - Freedom of Information Act/Privacy Act request. A FOIA request is generally a request for access to records concerning a third party, an organization, or a particular topic of interest. A Privacy Act request is a request for records concerning oneself; such requests are also treated as FOIA requests. (All requests for access to records, regardless of which law is cited by the requester, are included in this report.)

  2. Initial Request - a request to a federal agency for access to records under the Freedom of Information Act/Privacy Act.

  3. Appeal - a request to a federal agency asking that it review at a higher administrative level a full denial or partial denial of access to records under the Freedom of Information Act/Privacy Act, or any other FOIA determination such as a matter pertaining to fees.

  4. Processed Request or Appeal - a request or appeal for which an agency has taken a final action on the request or the appeal in all respects.

  5. Multi-track processing - a system in which simple requests requiring relatively minimal review are placed in one processing track and more voluminous and complex requests are placed in one or more other tracks. Requests in each track are processed on a first-in/first-out basis. A requester who has an urgent need for records may request expedited processing (see below).

  6. Expedited processing - an agency will process a FOIA request on an expedited basis when a requester has shown an exceptional need or urgency for the records which warrants giving priority to his or her request over other requests that were made earlier.

  7. Simple request - a FOIA request that an agency using multi-tracking processing places in its fastest (non expedited) track based on the volume and/or simplicity of records requested.

  8. Complex request - a FOIA request that an agency using multi-track processing places in a slower track based on the volume and/or complexity of records requested.

  9. Grant - an agency decision to disclose all records in full in response to a FOIA request.

  10. Partial grant - an agency decision to disclose a record in part in response to a FOIA request, deleting information determined to be exempt under one or more of the FOIA's exemptions; or a decision to disclose some records in their entireties, but to withhold others in whole or in part.

  11. Denial - an agency decision not to release any part of a record or records in response to a FOIA request because all the information in the requested record is determined by the agency to be exempt under one or more of the FOIA's exemptions, or for some procedural reason (such as because no record is located in response to a FOIA request).

  12. Time limits - the time period in the Freedom of Information Act for an agency to respond to a FOIA request (ordinarily 20 working days from proper receipt of a perfected FOIA request).

  13. A perfected request - a FOIA request for records which adequately describes the records sought, which has been received by the FOIA office of the agency or agency component in possession of the records, and for which there is no remaining question about the payment of applicable fees.

  14. Exemption 3 statute - a separate federal statute prohibiting the disclosure of a certain type of information and authorizing its withholding under FOIA subsection (b)(3).

  15. Median number - the middle, not average, number. For example, of 3, 7, and 14, the median number is 7.

  16. Average number - the number obtained by dividing the sum of a group of numbers by the quantity of numbers in the group. For example, of 3, 7, and 14, the average is 8.

  1. Exemption 3 Statutes

  1. List of Exemption 3 statutes relied on by this agency during fiscal year 2005.

  1. The Occupational Safety and Health Administration withheld the map of a U.S. Army Depot pursuant to the requirements of the Homeland Security Act. That component also withheld information pursuant to Title 49 CFR part 1520, which is enforced by the Transportation Security Administration.

  2. The Office of Labor-Management Standards invoked section 304(a) of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) (29 U.S.C. 464(a)) to protect the identity of a complainant in a trusteeship investigation.
    This office also withheld grand jury material pursuant to Rule 6(e) of the Federal Rules of Criminal Procedure.

  3. The Mine Safety and Health Administration withheld the name of a person who requested a safety inspection pursuant to the Federal Mine Safety and Health Act of 1977, section 103(g)(1) (30 U.S.C.813(g)(1)). It also withheld information to protect the confidentiality of coal mine maps pursuant to section 312(b) of the statute (30 U.S.C. 872(b)).

  4. The Office of the Inspector General withheld grand jury information pursuant to Rule 6(e) of the Federal Rules of Criminal Procedure.

  5. The Bureau of Labor Statistics withheld confidential business data pursuant to the authority of the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA)(44 U.S.C. 3541note). This statute prohibits federal agencies from releasing in identifiable form information acquired under a pledge of confidentiality for exclusively statistical purposes.

  1. The use of Rule 6(e) of the Federal Rules of Criminal Procedure was upheld by a court in the case of Senate of Puerto Rico v. United States Department of Justice, 823 F.2d 574 (D.C. Cir. 1987). The use of the other statutes, cited above, has not been litigated.

  1. INITIAL FOIA/PA ACCESS REQUESTS

  1. NUMBERS OF INITIAL REQUESTS.

 

NUMBER OF REQUESTS PENDING AS OF END OF PRECEDING YEAR

NUMBER OF REQUESTS RECEIVED IN CURRENT YEAR

NUMBER OF REQUESTS PROCESSED IN CURRENT YEAR

NUMBER OF REQUESTS PENDING AS OF END OF CURRENT YEAR

OSHA

196

11,425

11,368

253

ESA

183

7875

7,925

133

MSHA

41

1,067

1,061

47

ETA

41

567

369

239

EBSA

43

1,748

1,715

76

OASAM

12

185

187

10

ALJ

0

212

212

0

VETS

8

104

107

5

OIG

15

71

75

11

BLS

4

55

54

5

OAS

1

51

52

0

WB

1

20

21

0

ODEP

0

23

23

0

ASP

3

15

17

1

OCIA

0

0

0

0

ILAB

1

25

26

0

CFO

0

8

8

0

OPA

0

8

8

0

OSBP

0

22

22

0

SOL

10

24

34

0

TOTALS

559

23,505

23,284

780

  1. DISPOSITION OF INITIAL REQUESTS.

 

NUMBER OF TOTAL GRANTS

NUMBER OF PARTIAL GRANTS

NUMBER OF DENIALS

OTHER REASONS FOR NONDISCLOSURE (Subtotal) [2]

OSHA

784

5,443

1,313

3,828

ESA

5,946

951

212

816

MSHA

320

282

231

228

ETA

152

63

0

154

EBSA

1,400

77

33

205

OASAM

78

20

0

89

ALJ

169

12

4

27

OIG

20

22

5

28

BLS

7

8

6

33

VETS

25

68

0

14

OAS

21

0

1

30

ASP

0

1

0

16

WB

3

2

0

16

ODEP

0

0

0

23

OCIA

0

0

0

0

ILAB

12

2

0

12

CFO

0

0

0

8

OPA

0

0

0

8

OSBP

0

0

0

22

SOL

1

8

3

22

TOTALS [3]

8,938

6,959

1,808

5,579

  1. EXEMPTIONS CLAIMED UNDER THE FREEDOM OF INFORMATION ACT; EACH EXEMPTION IS COUNTED ONLY ONCE PER REQUEST

 

(1)

(2)

(3)

(4)

(5)

(6)

(7)(A)

(7)(B)

(7)(C)

(7)(D)

(7)(E)

(7)(F)

(8)

(9)

TOTAL

OSHA

0

548

3

3,693

3,473

1,409

1,313

0

4,340

2,743

554

0

0

0

18,076

ESA

0

152

2

358

790

136

212

0

829

286

178

0

0

0

2,943

MSHA

0

8

2

6

104

171

231

0

62

33

0

0

0

0

617

ETA

0

0

0

46

7

12

0

14

0

0

0

0

0

0

79

EBSA

0

7

0

8

25

40

33

0

31

6

25

0

0

0

175

OASAM

0

4

0

3

9

17

0

0

0

0

0

0

0

0

33

ALJ

0

0

0

2

3

10

0

0

0

0

0

0

0

0

15

OIG

0

0

5

3

2

2

13

4

0

11

14

3

0

0

57

BLS

0

0

0

6

6

2

5

0

0

0

0

0

0

0

19

VETS

0

5

0

4

36

28

0

0

19

4

6

0

0

0

102

OAS

0

0

0

0

0

1

0

0

0

0

0

0

0

0

1

ASP

0

1

0

0

0

1

0

0

0

0

0

0

0

0

2

WB

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

ODEP

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

OCIA

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

ILAB

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

CFO

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

OPA

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

OSBP

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

SOL

0

3

0

1

3

6

0

0

2

1

0

0

0

0

16

TOTALS

0

728

12

4,130

4,458

1,835

1,807

18

5,283

3,084

777

3

0

0

22,135

  1. OTHER REASONS FOR NONDISCLOSURE (cont.)

 

This column totals up all of the numbers set forth to the right [4]

NO RECORDS

REFERRALS

REQUEST WITHDRAWN

FEE RELATED REASON

RECORDS NOT REASONABLY DESCRIBED

NOT A PROPER FOIA REQUEST

NOT AN AGENCY RECORD

DUPLICATE REQUEST

OTHER (specify**

OSHA

3,828

2,257

1,020

106

115

66

17

119

128

0

ESA

816

528

64

33

8

6

17

41

82

37

MSHA

228

174

4

17

11

7

3

5

6

1

ETA

154

48

24

3

27

0

1

9

18

24

EBSA

205

79

16

32

1

50

13

2

12

0

OASAM

89

7

4

13

0

0

0

35

15

15

ALJ

27

9

5

1

0

0

0

0

1

11

OIG

28

25

0

1

2

0

0

0

0

0

BLS

33

18

10

2

0

0

0

1

0

2

VETS

14

4

6

0

0

0

0

0

1

3

OAS

30

14

1

4

2

0

0

6

2

1

ASP

16

10

0

2

0

0

0

0

2

2

WB

16

14

1

1

0

0

0

0

0

0

ODEP

23

21

2

0

0

0

0

0

0

0

OCIA

0

0

0

0

0

0

0

0

0

0

ILAB

12

10

0

2

0

0

0

0

0

0

CFO

8

8

0

0

0

0

0

0

0

0

OPA

8

8

0

0

0

0

0

0

0

0

OSBP

22

20

0

1

0

0

0

0

1

0

SOL

22

14

4

4

0

0

0

0

0

0

TOTALS

5,579

3,268

1,161

222

166

129

51

218

268

96

** EXPLANATION OF DISPOSITION OF FOIA/PA INITIAL REQUESTS: OTHER REASONS FOR NONDISCLOSURE (COLUMN MARKED "OTHER")

 

Number of Times

Reason(s)

ESA

37

Closed administratively

MSHA

1

Closed administratively

ETA

24

Closed administratively

OASAM

15

Closed administratively

ALJ

11

Closed administratively

BLS

2

Closed administratively

VETS

3

Closed administratively

OAS

1

Closed administratively

ASP

2

Closed administratively

  1. Appeals of Initial Denials of FOIA/PA Requests

  1. Numbers of appeals.

  1. Number of appeals received during fiscal year 2005: 364

  2. Number of appeals processed during fiscal year 2005: 188

  1. Disposition of appeals.

  1. Number completely upheld: 36

  2. Number partially reversed: 48

  3. Number completely reversed: 10

  1. number of times each FOIA exemption was used (counting each exemption once per appeal)

(1) Exemption 1: 0
(2) Exemption 2: 7
(3) Exemption 3: 0
(4) Exemption 4: 17
(5) Exemption 5: 31
(6) Exemption 6: 7
(7) Exemption 7(A): 21
(8) Exemption 7(B): 0
(9) Exemption 7(C): 48
(10) Exemption 7(D): 28
(11) Exemption 7(E): 4
(12) Exemption 7(F): 1
(13) Exemption 8: 0
(14) Exemption 9: 0

  1. Other reasons for nondisclosure (total): 94

  1. no records: 6

  2. referrals: 5

  3. appeal withdrawn: 36

  4. fee-related reason: 2

  5. records not reasonably described: 0

  6. not a proper FOIA appeal for some other reason: 10

  7. not an agency record: 0

  8. duplicate request: 8

  9. other (specify): closed administratively, 27

  1. COMPLIANCE WITH TIME LIMITS/STATUS OF PENDING REQUESTS

  1. MEDIAN PROCESSING TIME FOR REQUESTS PROCESSED DURING THE YEAR.

 

Simple Requests

Complex Requests

Requests For Expedited Processing

Number of Requests Processed

Median Number of Days to Process

Number of Requests Processed

Median Number of Days to Process

Number of Expedited Requests Granted

Median Number of Days to Process

OSHA

7,855

13

3,431

45

82

18

ESA

6,948

13

904

37

73

9

MSHA

0

0

1,058

20

3

7

ETA

270

20

94

30

5

10

EBSA

1,456

7

257

34

2

10

OASAM

151

13

35

26

1

4

ALJ

206

10

0

0

6

3

VETS

87

10

19

39

1

8

OIG

47

28

28

50

0

0

BLS

54

17

0

0

0

0

OAS

52

6

0

0

0

0

WB

19

10

2

25

0

0

ODEP

23

30

0

0

0

0

ASP

16

20

1

60

0

0

OCIA

0

0

0

0

0

0

ILAB

24

7

2

14

0

0

CFO

8

7

0

0

0

0

OPA

8

7

0

0

0

0

OSBP

22

10

0

0

0

0

SOL

30

14

3

30

1

2

TOTALS

17,276

 

5,834

 

174

 

  1. STATUS OF PENDING REQUESTS.

 

NUMBER OF REQUESTS PENDING AS OF THE END OF FISCAL YEAR

MEDIAN NUMBER OF DAYS PENDING

OSHA

253

91

ESA

133

18

MSHA

47

32

ETA

239

30

EBSA

76

46

OASAM

10

30

ALJ

0

0

VETS

5

28

OIG

11

38

BLS

5

6

OAS

0

0

WB

0

0

ODEP

0

0

ASP

1

60

OCIA

0

0

ILAB

0

0

CFO

0

0

OPA

0

0

OSBP

0

0

SOL

0

0

TOTALS

780

 

  1. COSTS/FOIA STAFFING

 

Staffing Levels

Total Costs (Including Staff and all Resources)

Number of Full Time Personnel

Number of Personnel With Part Time or Occasional FOIA Duties (In Total Work-Years)

Total Number of Personnel (In Work-Years)

FOIA Processing (Including Appeals) (Estimated)

Litigation Related Activities (Estimated)

Total

OSHA

10

64

74

$6,216,000

$ 0

$6,216,000

ESA

17

44

61

5,124,000

0

5,124,000

MSHA

1

17

18

1,512,000

0

1,512,000

ETA

0

5.1

5.1

428,400

0

428,400

EBSA

4

4.43

8.43

708,120

0

708,120

OASAM

1

1.56

2.56

215,040

0

215,040

ALJ

0

2.9

2.9

243,600

0

243,600

VETS

0

1.5

1.5

126,000

0

126,000

OIG

1

0

1

84,000

0

84,000

BLS

0

.7

.7

58,800

0

58,800

OAS

0

.7

.7

58,800

0

58,800

WB

0

.3

.3

25,800

0

25,800

ODEP

0

.3

.3

25,800

0

25,800

ASP

0

.2

.2

16,800

0

16,800

OCIA

0

0

0

0

0

0

ILAB

0

.4

.4

33,600

0

33,600

CFO

0

.1

.1

8,400

0

8,400

OPA

0

.1

.1

8,400

0

8,400

OSBP

0

.3

.3

58,800

0

58,800

SOL

4

8.5

12.5

1,075,000

175,000

1,250,000

TOTALS

38

152.09

190.09

$16,027,360

$175,000

$16,202,360

  1. FEES

  1. TOTAL AMOUNT OF FEES COLLECTED BY AGENCY FOR PROCESSING REQUESTS.

The Department collected $180,690.20 in fees.

  1. PERCENTAGE OF TOTAL COSTS: 1.12%

  1. FOIA Regulations (Including Fee Schedule)

The electronic address for accessing the Department's FOIA regulations, 29 C.F.R Part 70, is on the Department's web site at http://www.dol.gov/dol/foia/main.htm. In addition, they can be accessed on the World Wide Web at GPO Access, a service of the U.S. Government Printing Office, at: http://www.gpoaccess.gov/nara/index.html.

Signed at Washington, D.C. this 5th day of June, 2006

___signed___________
Howard M. Radzely
Solicitor of Labor


Footnotes

[1]    The numbering and lettering of sections corresponds to the Department of Justice, Office of Information and Privacy's "Annual Report Guidance Outline,"; FOIA Update Vol. XVIII, No. 3, 1997.

[2]    This column is repeated in Column 2 of the table on page 12.

[3]    These numbers when added together equal 23,284, which corresponds to the total of Column 3 of Table V.A. above.

[4]    This column is a repeat of the information contained in column 4 of the table on page 10