Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

FY 2010 Chief FOIA Officer Report for the U.S. Railroad Retirement Board (RRB)

The RRB submits this report for FY 2010 in response to the request in the United States 

Department of Justice Office of Information Policy FOIA Post, “Guidelines for 2011 Chief 

FOIA Officer Reports to the Department of Justice, Pursuant to Attorney General Holder’s 

FOIA Guidelines.” The report has been prepared by Steven A. Bartholow, General 

Counsel/Chief FOIA Officer, RRB. 

I. Steps Taken to Apply the Presumption of Openness. 

1. Description 

The RRB is a small, independent agency in the Executive Branch of the 

Federal government. As the RRB’s General Counsel/Chief FOIA Officer, 

I am responsible for the RRB’s overall FOIA program. I have made 

certain that all FOIA staff are properly trained concerning the President’s 

FOIA memorandum and the Attorney General’s FOIA guidelines and are 

responsible in carrying out those responsibilities as they respond to all 

FOIA requests. We continue to make discretionary releases when possible 

and have taken actions to make additional proactive disclosures, such as 

posting additional financial and statistical information relating to the 

RRB’s core mission of paying benefits, on both the RRB’s agency and 

FOIA websites. 

2. Disclosure Comparisons 

The number of full grants to requests has continued to increase since FY 

2007 to the present, i.e., from 34 in FY 2007 to 53 in FY 2009. In FY 

2008, the agency released 48 full grants and 5 partial grants. In FY 2009, 

the agency released 55 full grants and 15 partial grants. In FY 2010, the 

agency released 62 full grants and 4 partial grants. 

II. Steps Taken to Ensure that the RRB has an Effective System for Responding 

to Requests. 

The RRB’s system for responding to requests is set forth in some detail 

below. Because of the average number of requests received annually, we 

believe this centralized process is the most effective FOIA-administration 

structure. We continue to monitor and assess our information technology 

to ensure that FOIA professionals have sufficient information technology 

support to perform their required functions. 

 

III. Steps Taken to Increase Proactive Disclosures. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

The RRB reviewed and upgraded the FOIA web pages as part of the agency’s 

website redesign in 2005. We continue to monitor FOIA webpage content to 

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make sure it remains timely and consistent with current law. FOIA staff have 

the responsibility and authority to update the RRB website as necessary. The 

website offers access to copies of the agency’s procedure manuals, final 

decisions of the three-member Board which heads the agency, rulings of the 

Board and legal opinions. Other information is available to the public without 

filing a FOIA request in the Federal Register and the RRB Group Information 

Locator System (GILS) website. An example of additional material provided 

since the issuance of the new FOIA Guidelines include a more comprehensive 

list of the agency’s procedural manuals. Additionally, five data sets of 

statistical information have been added to the RRB’s Open Government 

Initiative located at http://www.rrb.gov/open/default.asp. 

High-Value Data Sets 

The RRB identified and published online in an open format five high-value 

data sets and registered those data sets via Data.gov. Going forward, the RRB 

will consider existing published data for conversion to open format for 

publication to Data.gov. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 -3- 

High Value Information and Data Set Inventory 

The RRB High-Value Information and Data Set Inventory details the 

underlying data sets that are in an open format and accessible directly via 

Data.gov. 

High-Value Information and Data Set Inventory 

Information/Data Set 

Name 

Description URL 

Active Employees and 

Railroad Retirement Act 

Beneficiaries by State, 

2008 

A breakdown of Active 

Employees and Railroad 

Retirement Act 

Beneficiaries by State 

http://www.data.gov/details/1331

Longevity of Railroad 

Retirement Beneficiaries 

Calculations of life 

expectancies of Railroad 

Retirement beneficiaries. 

http://www.data.gov/details/1332

Railroad Retirement Act 

Annuitants and Active 

Railroad Employees by 

Congressional District 

A breakdown of Railroad 

Retirement Act 

Annuitants and Active 

Railroad Employees by 

Congressional District. 

http://www.data.gov/details/1330 

Total Number of Railroad 

Employees by State and 

Last Railroad Employer, 

2007 

A breakdown of Railroad 

employees by State and 

Last Railroad Employer. 

http://www.data.gov/details/455 

Total Railroad 

Employment by State and 

County, 2007 

A breakdown of Railroad 

employees by State and 

County. 

http://www.data.gov/details/456 

Open Government Webpage 

The RRB’s Open Government Webpage (www.rrb.gov/open) serves as the 

gateway for agency activities related to the Open Government Directive. The site 

allows the public to provide input about the agency’s Open Government Plan, 

give feedback regarding the quality of published information, and provide input 

about what information should be prioritized for publication to RRB staff via Email. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 -4- 

Transparency 

The RRB’s long history of transparency is evident by the extensive amount of 

information frequently published on its website (www.rrb.gov). To uphold and 

advance this strong commitment to transparency in the future, the RRB 

willcontinue to publish information in support of its mission to administer 

retirement/survivor and unemployment/sickness insurance benefit programs for 

railway workers and their families under the Railroad Retirement Act and the 

Railroad Unemployment Insurance Act. 

Agency Plans, Management and Reports 

The RRB Strategic Plan details the RRB’s long and distinguished history of 

excellent customer service and the continuation of that tradition by calling for the 

attainment and maintenance of high levels of accuracy and timeliness in paying 

retirement, survivor, unemployment and sickness insurance benefits. The Agency 

Management and Reports webpage provides information on the RRB’s structure, 

responsibilities to the public, and communication methods. The RRB Annual 

Report provides information on agency operations that are distributed to officials 

of railway management and labor, members of Congress, officials of the Federal 

Government, and requesting libraries 

http://www.rrb.gov/general/plan_rpt_inv.asp#fair

http://www.rrb.gov/mep/agency_mgt.asp 

http://www.rrb.gov/opa/AnnualRprt/Ann_Rpt_toc.asp

Agency Procedure Manuals 

The Agency Procedure Manuals webpage is an index of the chapters in the 

various manuals used by the RRB in the processing of claims under either the 

Railroad Retirement or Railroad Unemployment Insurance Acts. 

http://www.rrb.gov/general/admin_manuals_index.asp

Board Coverage Decisions 

Board Coverage Decisions are the determinations of the three-member Board as 

to the status of various companies or persons with respect to coverage as 

employers or employees under the Railroad Retirement and Railroad 

Unemployment Insurance Acts. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

http://www.rrb.gov/blaw/bcd/cov_introduction.asp

 -5- 

Congressional Requests 

The Congressional Inquiry Section of the RRB's Office of Administration is 

responsible for responding to all inquiries from congressional offices concerning 

constituents, benefit claims or applications filed with the agency. 

Questions about proposed railroad retirement legislation, the status of pending 

legislation, or congressional schedules, hearings or committee jurisdiction should 

be directed to the Office of Legislative Affairs (ola@rrb.gov). 

http://www.rrb.gov/opa/rrbcongress_contacts.asp 

Federal Register 

The Federal Register is the official daily publication for rules, proposed rules, and 

notices of Federal agencies and organizations, as well as executive orders and 

other presidential documents. Descriptions of agency organization, procedures for 

the public to obtain information, statements of agency function, rules of 

procedure, descriptions of agency forms, substantive rules of general applicability 

and statements of general policy, and any changes in material required to be 

published are available through the Office of the Federal Register, National 

Archives and Records Administration (NARA). 

http://www.gpoaccess.gov/fr/index.html 

http://www.rrb.gov/irm/fedreg_notices.asp 

http://www.rrb.gov/irm/fedreg_regs.asp 

Financial, Actuarial and Statistical Data 

The RRB Financial, Actuarial and Statistical Data webpage consists of the 

following sections: 

Annual Railroad Retirement Act and Railroad Unemployment Insurance Act Data 

Budget and Financial Reports: Current and Projected 

Earnings Limits, Tax Rates and COLA's 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

Monthly and Quarterly Railroad Retirement Act and Railroad Unemployment 

Insurance Act Data 

 -6- 

Performance and Accountability Reports 

http://www.rrb.gov/mep/fin_act_stat.asp 

Forms and Publications 

The Railroad Retirement Handbook provides a comprehensive single source of 

authoritative information on the development and character of the railroad 

retirement and railroad unemployment insurance systems. The Benefit Forms and 

Publications webpage provides information on Unemployment & Sickness 

Benefits, Retirement & Survivor Benefits, Medicare, Income Tax, Protests and 

Appeals, and Work/Earnings. The Employer Forms and Publications webpage 

provides content from the Exhibits Section of the Labor Reporting, Employer 

Reporting and Sickness Reporting Instructions, and publications in the format of 

Employer Exchange Newsletters and Office of the Labor Member Questions and 

Answers. 

http://www.rrb.gov/general/handbook/toc.asp 

http://www.rrb.gov/mep/ben_forms.asp

http://www.rrb.gov/mmo/rail_forms.asp

Freedom of Information Act (FOIA) 

The RRB is required under the Freedom of Information Act (FOIA) to disclose 

records requested in writing by any person. However, we may withhold 

information under certain exemptions and exclusions provided by the statute. In 

addition, the Railroad Retirement Act, the Railroad Unemployment Insurance 

Act, and the Privacy Act restrict disclosure of information about individuals. 

http://www.rrb.gov/blaw/foia/foia.asp

Information Dissemination 

In accordance with Section 3506(d) of the Paperwork Reduction Act and Section 

515 of Public Law 106-554 the RRB has developed a procedure to allow one to 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

seek and obtain correction of certain information RRB maintains and 

disseminates. Procedures to seek correction of information under section 515 do 

not replace other established procedures for challenges to disseminated 

information. Challenges to information disseminated in the course of rulemaking 

should be made through the channels established for that purpose. 

http://www.rrb.gov/bis/section515/introduction.asp 

http://www.rrb.gov/bis/section515/guidelines.asp

 -7- 

http://www.rrb.gov/bis/section515/correct.asp 

IMPAC Credit Card Holders List 

The RRB receives frequent requests under the Freedom of Information Act for a 

list of the IMPAC credit card holders at the agency. In accord with section 4 of 

the Electronic Freedom of Information Act Amendments of 1996 (P.L. 104-231), 

the RRB posts the list of credit card holders. 

http://www.rrb.gov/general/impac.asp

News Releases 

The RRB News webpage provides access to periodic news releases distributed to 

editors of railway publications and major newspapers, officials of railway 

management and labor, and requesting agencies and organizations in and outside 

of the Federal Government. 

http://www.rrb.gov/mep/news_releases.asp 

Paperwork Reduction Act 

The RRB is essentially compliant with the information dissemination 

requirements of the PRA. 

Privacy Act - Privacy Act Systems of Records 

The RRB Privacy Act webpage provides information on one’s right to records 

which the RRB maintains about individuals, including individuals in the railroad 

industry. The text of all of the RRB's Privacy Act Systems of Records, as 

published in the Federal Register, are available for study. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

http://www.rrb.gov/bis/privacy_act/introduction.asp 

http://www.rrb.gov/bis/privacy_act/SORNList.asp 

Records Management 

The RRB records schedules are in transition. We will post updated RRB records 

schedules to www.rrb.gov upon completion of all remaining NARA Bulletin 

2006-02-related RRB/NARA appraisal work later in FY 2010. 

 -8- 

RRBVision 

The RRBVision service allows users to view video presentations with 

accompanying training materials, such as PowerPoint presentations or online 

screens. Presentations can be viewed in real time or saved for later viewing. These 

presentations covered instructions in filing for sickness and unemployment 

benefits under the Railroad Unemployment Insurance Act, filing for retirement 

benefits under the Railroad Retirement Act, completing a variety of 

compensation-reporting forms and navigating the Board’s Web site. 

http://www.rrb.gov/rrbvision/video_library.asp

IV. Steps Taken to Greater utilize Technology. 

1.) Electronic receipt of FOIA receipts: 

Yes, the RRB receives requests electronically via mail, fax and email 

through its E-FOIA system created by the RRB’s Bureau of Information 

Services. 

2.) Electronic tracking of FOIA requests: 

The RRB tracks requests electronically through its E-FOIA system created 

by the RRB’s Bureau of Information Services and the Office of General 

Counsel’s assignment control log. 

 

 3.) Electronic processing of FOIA requests: 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

Currently, the RRB does not use technology to process requests. Due to 

the average number of requests received within a given year, currently 

around 100, the RRB has determined that utilizing an electronic system for 

responding to requests is unnecessary at this time. We will continue to 

evaluate this option. However, to the extent practical and subject to valid 

restrictions, the RRB will continue to use its website to disseminate useful 

information, rather than waiting for specific requests under FOIA. 

4.) Electronic preparation of your Annual FOIA Report: 

No, the RRB does not use technology to prepare its Annual FOIA 

Report. We currently utilize an off-the-shelf data-processing system to 

prepare our annual report. We do not currently see a need for the use of 

additional automated processing technologies. 

 

 -9- 

Due to the average number of requests received within a given year, 

currently around 100, the RRB has determined that utilizing technology in 

preparing its Annual FOIA Report is unnecessary and would not be costeffective. We will continue to monitor this process to provide effective 

and efficient processing of FOIA requests. 

V. Steps Taken to Reduce Backlogs and Improve Timeliness of Responding

to Requests. 

1. Agency Backlog 

At the close of FY 2010, the RRB had a backlog of one pending request. 

At the close of FY 2010, the RRB did not have any pending appeals. In 

FY 2008, the RRB had a backlog of 5 requests. In FY 2009, the RRB did 

not have a backlog of requests or appeals. 

 

2. Reduction in Agency Backlog 

The one pending request at the close of FY 2010 is due to the complexity 

of the request received concerning a request for access to the agency’s 

entire travel database. 

3. Improving Timeliness 

To improve timeliness, the RRB will reach out to requesters to narrow the 

scope of overbroad requests and if necessary, develop alternative 

timeframes for processing of complex requests. etc. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 

Spotlight on Success 

Flagship Initiative - American Customer Satisfaction Index Web-Based Survey 

Starting in May 2010, working in collaboration with Foresee Results and the Federal 

Consulting Group, the Railroad Retirement Board will be participating in the American 

Customer Satisfaction Index survey of visitors to the agency’s website. The survey will 

specifically measure the visitors’ perception of “Online Transparency” among other 

things. Unlike previous ACSI surveys the agency has conducted at a single point in time, 

this survey will be ongoing for at least a year. Each month, the survey questions can be 

adjusted to obtain customer feedback on potential enhancements thus providing a vehicle 

for customer participation. Each quarter we will receive an analytical report which will 

help us determine which website improvements will yield the greatest return on 

satisfaction and on our investment. This approach will also allow us to determine the 

importance of website elements to our customers—based on their input—so we can make 

informed decisions about website improvements and other online investments. The 

 -10- 

ability to adjust both the survey and the website along the way provides an ongoing 

measure of improved transparency and effectiveness. Depending on the level of public 

participation, funding availability, and the RRB’s ability to respond to the feedback, we 

will consider extending the survey for another year or more, and/or obtaining additional 

analytical services to further improve website performance and openness, and ultimately 

efficiency and effectiveness of operations, as well as customer satisfaction. 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 -11- 

ADDENDUM BY THE 

RAILROAD RETIREMENT BOARD 

 GENERAL COUNSEL 

 (AGENCY CHIEF FOIA OFFICER) 

At the RRB, we are committed to more than just compliance with both President 

Obama’s FOIA Memorandum and Attorney General Holder’s FOIA Guidelines Order, as 

well as any other law applicable to the FOIA. Among other things: 

• We are committed to working with our FOIA requesters, and the public in general, 

to continuously improve our FOIA operations; 

• We are committed to processing FOIA requests in an efficient, timely, and 

appropriate manner and to continuously achieving tangible, measurable 

improvements in FOIA processing; 

• We are committed to responding to, and servicing, our FOIA requesters in a 

courteous, polite, and respectful manner; 

• We are committed to providing FOIA requesters, and the public in general, with 

citizen-centered ways to learn about the FOIA process; 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

• We are committed to providing FOIA requesters, and the public in general, with 

timely information about agency records that are publicly available; 

• We are committed to providing FOIA requesters, and the public in general, with 

timely information and about the status of an individual’s FOIA request and 

appropriate information about the agency’s response; 

• We are committed to substantially increasing the number of agency documents, 

particularly those that are frequently-requested, made available on our website 

so that the public does not need to resort to a FOIA request to gain access to 

these agency documents and to making those documents available in an 

organized and intelligible manner; 

• We are committed to a proactive and thoughtful approach to information 

disclosure; 

• We are committed to the use of technology to track, and expedite the processing 

of, FOIA requests; 

• We are committed to utilizing creative and innovative approaches to substantially 

reduce any future backlog of FOIA requests; 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 -12- 

• We are committed to improving communication with our FOIA requesters and to 

more proactively understanding and clarifying FOIA requests; and 

• We are committed to a citizen-centered and results-oriented approach. 

As the designated Chief FOIA Officer for the RRB, I am pleased to submit this report, 

which includes the commitments listed above and presents the review of the RRB’s 

current FOIA operations. This report is directed to ensuring that the RRB’s 

administration of the FOIA is not only, at a minimum, in compliance with the law and the 

policies set forth in the President’s Memorandum, but also that the RRB strives to 

continuously improve its FOIA operations and exceed the expectations of its FOIA 

requesters. 

/s/ Steven A. Bartholow 

RRB General Counsel/Chief FOIA Officer 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

 -13- 

Overall Nature of RRB’s FOIA Operations 

In the 1930’s, Congress established the RRB as an independent agency in the executive 

branch of the federal government. The primary duty of the RRB is to administer 

retirement/survivor and unemployment/sickness insurance benefit programs under the 

Railroad Retirement Act and the Railroad Unemployment Insurance Act. These 

programs provide income protection during old age and in the event of disability, death 

or temporary unemployment and sickness. The RRB also administers aspects of the 

Medicare program and has administrative responsibilities under the Social Security Act 

and the Internal Revenue Code. 

During fiscal year 2010, retirement-survivor benefits of some $10.8 billion were paid to 

about 582,000 beneficiaries, while net unemployment-sickness benefits of $160 million, 

including over $20 million in temporary extended unemployment benefits under the 

American Recovery and Reinvestment Act of 2009 and the Worker, Homeownership, 

and Business Assistance Act of 2009, were paid to more than 38,000 claimants. At the 

end of fiscal year 2010, the average annuity paid to retired rail employees was some 

$2,215 a month, spouse benefits averaged $815 a month, and benefits for aged 

widow(er)s averaged $1,330 a month. The maximum biweekly rate for unemployment 

and sickness benefits was $660. 

 

The RRB staff currently includes approximately 969 employees as of December 31, 

2010. The agency’s headquarters is located at 844 North Rush Street, Chicago, Illinois 

60611-2092 and the agency has 53 field offices nationwide. The agency’s small size and 

concise mission result in on average around 100 FOIA requests annually. Our average 

processing time for FOIA requests last year was around 12.14 days. In 2005, the RRB 

launched a redesigned website (www.rrb.gov) that is more user-friendly and makes 

publicly available many of the categories of documents that used to result in FOIA 

requests. 

 

Internet availability of these documents has reduced the number of FOIA requests. This 

allows us to focus on the remaining requests, which tend to be somewhat more complex. 

Information available from the RRB under the FOIA includes the agency’s procedure 

manuals, final decisions of the three-member Board which heads the agency, rulings of 

the Board and legal opinions. Legal opinions since 1997 and Board Coverage Decisions 

are periodically posted to the RRB web site and available without a request under the 

Freedom of Information Act. 

Because the RRB administers a comprehensive program of railroad retirement, 

unemployment, and sickness benefits for railroad workers, it also maintains information 

about individuals which may not be disclosed in response to a FOIA request. The 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

Railroad Retirement Act, the Railroad Unemployment Insurance Act, and the Privacy Act 

restrict the disclosure of information about individuals. If a request is made for 

 -14- 

information about an individual, as a general rule, the requester must provide the RRB a 

written authorization signed by the individual who is the subject of that record. 

 

RRB’s FOIA operations are centralized in the RRB’s headquarters location. The RRB 

officials who have primary responsibility for the administration of program areas are 

located at RRB Headquarters in Chicago, Illinois. Numerous programs, however, are 

administered at the local level through 12 Networks, headed by Network Managers who 

oversee the operation of all RRB program areas in their jurisdiction. RRB’s primary 

FOIA operation is located in the FOIA Requester Service Center located within the 

Office of General Counsel (OGC). The OGC is comprised of ten attorneys (a General 

Counsel, an Assistant General Counsel, an Assistant to the General Counsel and 7 staff 

attorneys), a paralegal specialist, and three administrative support personnel. One General 

Attorney is primarily responsible for reviewing incoming FOIA requests, providing the 

requestor with an acknowledgment of the request, determining whether documents are 

likely to be located at Headquarters, and either initiating a search at RRB Headquarters’ 

program offices or refer the request to a Network Manager, or non-Headquarters 

program-specific office, as appropriate. The General Attorney is also responsible for 

reviewing the program office’s recommendation concerning the releasability of 

documents, redacting material subject to FOIA exemptions, and preparing a draft 

response letter to the requester for the General Counsel/Chief FOIA Officer. Two 

additional General Attorney’s have secondary responsibility to provide back-up 

assistance to the primary General Attorney for FOIA requests. The three support staff 

personnel at Headquarters are responsible for logging in the average 100 or so FOIA 

requests received at Headquarters annually, including inputting pertinent information into 

an electronic tracking system. Support staff also perform ancillary functions, such as 

filing, record archiving, and time and attendance. 

The Headquarters primary FOIA attorney handles all legal issues related to Headquarters 

FOIA requests, including researching and reviewing issues related to the applicability of 

exemptions, resolving fee waiver determinations, deciding requests for news media 

status, and responding to questions from Headquarters program staff. The primary FOIA 

attorney is responsible for resolving all issues that arise within Headquarters regarding 

responsiveness and adequacy of search by Headquarters offices. In addition, the 

Headquarters FOIA legal staff serves in an advisory role to the over 53 decentralized 

RRB offices, responding to challenging questions on processing, applicability of 

exemptions, interpretation of the FOIA, and the handling of non-routine FOIA requests. 

The Headquarters FOIA attorneys are also responsible for supervising the Headquarters 

FOIA Specialist processing staff, including the review and editing of all of the 

approximately 100 plus FOIA response letters sent by Headquarters annually. All FOIA 
Chief FOIA Officer Report 

 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago Illinois, 60611-2092 

 

 

Phone: (312) 751-7139 

TTY: (312) 751-4701 

Web: 

 

http://www.rrb.gov

responses are signed by the General Counsel/Chief FOIA Officer of the OGC. 

Supervisory duties performed by one attorney in the Headquarters FOIA Requester 

Service Center include assignment of cases to the FOIA attorneys, preparation of 

performance appraisals, progress reviews and all other personnel functions related to 

supervision of the non-attorneys in the FOIA Requester Service Center. 

 -15- 

RRB’s FOIA operations outside of Headquarters are administered or supervised by OGC. 

Each Network Manager has responsibility to forward all FOIA requests related to 

documents physically located within either the Network Office or district field offices 

within the Network Manager’s jurisdiction. 

It should also be noted that due to the independent nature of the RRB’s Office of 

Inspector General (OIG), handling and reporting statistics concerning FOIA requests 

received by that office, is the responsibility of the OIG. However, those statistics are 

reflected herein for purposes of this report.