In Matter of Fink v. Lefkowitz, 47 NY2d 567 [1977] the Court distinguished agency records compiled for law enforcement purposes, which illustrate investigative techniques, from the documents which articulate the agency's understanding of the rules and regulations it is empowered to enforce. The Court stated that records which "merely clarify procedural or substantive law must be disclosed" since such information in the hands of the public does not impede effective law enforcement. "Indicative, but not necessarily dispositive, of whether the investigative techniques are non-routine is whether disclosure of those procedures would give rise to a substantial likelihood that violators could evade detection by deliberately tailoring their conduct in anticipation of avenues of inquiry to be pursued by [law enforcement] personnel."