On June 18, 2013, the Office of Hearings and Appeals (OHA) issued a decision remanding an appeal (Appeal) from a Freedom of Information Act (FOIA) determination issued by the Department of Energy’s Richland Operations Office (ROO). The Appellant, Hanford Atomic Metals Trade Council, contested the ROO’s invocation of Exemption 5 to the redactions it made in the released documents. The released documents contained communications regarding the DOE’s contractors’ labor negotiations with the Appellant, a union. The OHA reviewed the withheld information and the ROO’s justifications for its redactions, and determined that the documents were either not inter- or intra-agency documents or that they did not involve a deliberative process. Therefore, the OHA remanded the Appeal to issue a new determination.