dissenting:

Plaintiff has been the victim of the kind of nightmare those of us involved in administering our penal system take great pains to avoid — undeserved punishment because of a bureaucratic blunder. Justice would no doubt be served by compensating him for the time he has been wrongly imprisoned. But whatever claims he may have do not run against the defendants. They did not make the error in calculating his foreign jail credits; they were not the ones *1400 responsible for keeping him in prison beyond what turned out to be his proper release date. Defendants merely implemented a decision made by the Bureau of Prisons’ Central Office, which was charged by applicable regulations with the responsibility for making this decision. My colleagues reach the contrary conclusion only by hammering a square peg into a round hole.

As I see it, the Bureau of Prisons made a wholly rational decision to centralize foreign jail credit determinations; local prison officials do not have the power to reverse those decisions once made, are fully entitled to rely on them in responding to complaints by prisoners and are shielded from liability when they act in accordance with the Central Office’s determinations.

By reaching the contrary conclusion, the majority severely undermines the chain of authority established by the Bureau of Prisons for handling the complex and sensitive matter of foreign jail credits. More broadly, it places a serious burden on prison officials to second-guess decisions made by their superiors, at the risk of personal liability should those decisions turn out to be wrong. While the majority opinion deals only with decisions involving foreign jail credits, it applies far more broadly to all manner of Bureau of Prisons determinations over which local prison officials have no control. After today, prison officials in this circuit will no longer feel safe in relying on Central Office determinations, but will feel compelled to revisit those decisions lest they be hit with crushing financial liability for failing to “investigate” a prisoner’s claim that the Central Office was wrong.

I

The majority glosses over the point I see as pivotal in this case: that the Central Office (and only the Central Office) can determine eligibility for foreign jail credits and award such credits. Perrill and Rivera had no authority to grant Alexander’s request for time served in Germany or to second-guess the decision of officials in Washington.

The majority suggests that the Central Office does not have exclusive authority over claims for foreign jail credit. Maj. at 1399. This is simply not so. Under 18 U.S.C. § 3568 , 1 the Attorney General and the Bureau of Prisons are responsible for computing sentences and awarding prisoners credit for jail time already served. United States v. Clayton, 588 F.2d 1288, 1292 (9th Cir.1979); see also Brown v. Rison, 895 F.2d 533, 535 (9th Cir.1990). The Bureau of Prisons has delegated the task of awarding foreign jail credits to the Central Office: “Inquiries or requests for foreign jail time credit ... must be sent to the central office Chief of Administrative Systems [Central Office] for verification and monitoring purposes.” Bureau of Prisons Program Statement No. 5880.24, at 5c(1)(a) (emphasis added). Verification in this context can only mean one thing: The Central Office determines whether requests for foreign jail credit are justified and has the final say as to whether a particular prisoner is awarded credit. Program Statement 5880.24 is thus a delegation of authority to the Central Office on matters of foreign jail credit, and a concomitant withdrawal of such authority from local prison officials who are presented with such requests.

The record bears out this interpretation of the Program Statement. According to Edgar Haynes, Chief of Administrative Systems when Alexander filed this lawsuit, his office was responsible for “reviewing sentence computations for a final determination as to correctness.” Declaration of Edgar Haynes, CR 1, Exhibit A, at 1 (emphasis added). 2 He further stated that the Central Office researches the requests: “Through the Bureau of Prisons’ Office of *1401 General Counsel and the Department of Justice’s Office of International Affairs, Criminal Division, we request from the Department of State verification of the time credit to be applied for foreign custody.” Id. See also Declaration of William Perrill, CR 23, Exhibit 1, at 1 (“I am not personally responsible for the computation of inmate sentences or the determination of any applicable jail credit thereof. Federal Bureau of Prisons’ policy requires that jail credit from a foreign jail be verified and monitored by the Chief of Administrative Systems, Central Office.”); Declaration of Louie Rivera, CR 23, Exhibit 2, at 1 (“Included in my duties is the responsibility for the computation of sentences and any applicable jail time credit thereof of inmates confined at PCI, Tucson. I have no responsibility, however, for computing foreign jail credit. Federal Bureau of Prisons’ policy requires that this be done by our Central Office.”) (emphasis in original).

Thus, the undisputed evidence shows that the Central Office makes the determinations and handles the difficult tasks involved therein: contacting other government agencies to obtain documents which are often written in foreign languages, interpreting these documents in light of their meaning in foreign legal systems and applying the relevant regulations to make a calculation.

The exclusive authority of the Central Office in the area of foreign jail credits was well-known to all of the parties. Alexander filed a Request for Administrative Remedy while he was incarcerated at FCI-Terminal Island on December 9, 1985 (before he entered defendants’ charge on June 23, 1986) and received the following reply from his warden:

CR Habeas 19, Exhibit 2. Plaintiff has not disputed that the Bureau of Prisons delegated authority in this manner. Indeed, in his habeas petition, he acknowledged that “the matter of jail credits for foreign jails is a matter of decision with the Central Office.” CR Habeas 1, at 24.

In sum, both the law and the undisputed evidence establish that the Central Office makes authoritative determinations on foreign jail credit. Prison officials such as Perrill and Rivera have no role in making the calculations or awarding the credit.

II

The majority is right that under the Bureau of Prisons Administrative Remedy Procedure, local prison officials such as defendants are responsible for investigating complaints brought in the prison system to which they are assigned. 28 CFR § 542.11 (a)(3). But the defendants’ duty to investigate does not mean that they must do somebody else’s job or second-guess the decisions entrusted to the Central Office. Defendants fulfilled their duty to investigate Alexander’s complaint by determining that the Central Office had evaluated his claim and by relying on its decision. This is so for two reasons.

A. First, in analyzing the defendants’ duty to investigate in this situation, we must consider the administrative scheme set up by the Bureau of Prisons. 3 The *1402 Bureau of Prisons has made a wholly rational decision to centralize the administration of foreign jail credit matters. 4 As the district court recognized, foreign jail credit issues are often quite complex, see RT at 21, requiring an understanding not only of our country’s prison regulations, but those of numerous other nations as well. The Bureau of Prisons has made what it considers to be an efficient division of labor. Rather than requiring officials at 66 separate facilities to master the complexities involved, the Bureau has assigned the task of resolving these difficult and often sensitive issues to experts in the Central Office. Maintaining records regarding foreign jail credit at a central location facilitates monitoring and ensures correct and consistent application of the regulations.

Because the Bureau of Prisons has assigned to its Central Office the task of investigating claims for foreign jail credit, it was reasonable for Perrill and Rivera to rely on the Central Office’s determination and defer to its expertise. 5 Defendants did not have the necessary knowledge and training to perform an independent investigation of Alexander’s claim or to evaluate his documentation. Under the Bureau of Prisons’ administrative scheme, any such investigation would have duplicated the Central Office’s efforts and functions.

The majority’s only remaining argument is that defendants were under a duty to determine whether the Central Office had copies of documents that Alexander claimed to possess. Maj. at 1399 and n. 12. It cites 5c(l)(a) of Program Statement No. 5880.24, which says that prison officials must send copies of a prisoner’s documentation to the Central Office. The majority seems of the view that defendants should have checked to see that Alexander’s Central Office file was complete because nothing in the record suggests “that the defendants had reason to believe that the Central Office had seen any of Alexander’s material before coming to its conclusion.” Id. at 1399 .

The record does not support this argument. In his complaint, Alexander does not claim that he alerted defendants to any specific deficiencies in his Central Office file. Instead, he quotes the following from the September 12, 1986, Request for Administrative Remedy he submitted to defendant Perrill: “I am entitled to full credit against my sentence, as detailed in the papers already submitted to the Central Office.” CR 1, at 14 (emphasis added). 6 Alexander’s claim for relief thus does not rest on the majority’s rationale; in fact, he asserts that he told defendants the Central Office already had his documentation.

The rest of the record similarly refutes the majority’s implicit assumption that the Central Office made its July 2, 1986, determination without seeing all of Alexander’s documentation. During his incarceration at Terminal Island, Alexander submitted several sets of documents to the Bureau of Prisons. See Declaration of Cleo A. Lehen-bauer, Administrative Systems Manager of Federal Correctional Institution, Terminal Island, CR 31, Exhibit G; Declaration of Edgar Haynes, CR 1, Exhibit A, at 1-3. The Warden at Terminal Island stated the following in responding to Alexander’s December 9, 1985, Request for Administrative Remedy:

CR Habeas 19, Exhibit 2.

There is nothing in the record to suggest that Alexander claimed to have any “new” documents to present to the Central Office when he arrived at defendants’ facility in Tucson on June 23. Alexander has not pointed to a single document which he had and which defendants failed to pass on to the Central Office, either before or after it made its July 2 determination. Since plaintiff bears the burden of showing that defendants violated his rights, his failure-in this regard is fatal to his claim. 7

B. Second, because it was not within defendants’ authority to grant Alexander’s claim or make a binding determination as to foreign jail credits, we are precluded from holding that defendants were under a constitutional duty to investigate his claim. A government official can be liable in a Bivens action only if a constitutional violation occurs within the scope of his authority. See Otto v. Heckler, 781 F.2d 754, 757 , amended 802 F.2d 337 (9th Cir.1986). Government officials are not responsible when the actions of others cause the plaintiffs rights to be violated. Rauschenberg v. Williamson, 785 F.2d 985, 988 (11th Cir.1986); Leonhard v. United States, 633 F.2d 599 , 621 n. 30 (2d Cir.1980), cert. denied 451 U.S. 908 , 101 S.Ct. 1975 , 68 L.Ed.2d 295 (1981); see Tallman v. Reagan, 846 F.2d 494, 495 (8th Cir.1988) (per curiam).

In Rauschenberg , for example, a former parolee brought a Bivens action against his former parole officer, alleging, inter alia, that the officer had improperly recommended to the parole board that he undergo psychiatric treatment. The court rejected his claim on the ground that only the parole board, not the individual parole officer, had authority to require the parolee to submit to treatment. The court concluded, “a parolee should not be entitled to damages from a parole officer for the officer’s role in recommending or administering a parole condition.” 785 F.2d at 988 .

Here, defendants had no authority to determine whether Alexander was entitled to foreign time-served credit. His rights were violated because Central Office personnel, acting pursuant to a delegation of authority made by applicable regulations, incorrectly calculated his sentence. Since the Central Office authorized the improper confinement of Alexander, defendants cannot be held liable in a Bivens action. Alexander cannot obtain damages from two local prison officials for the Central Office’s mistake.

Ill

By short-circuiting the administrative scheme set up by the Bureau of Prisons, the majority obscures another crucial point: Even if defendants failed to fulfill their responsibilities under applicable regulations, Alexander cannot claim any injury because it made no difference in this case. Even if defendants had asked Bureau of Prisons officials to review the calculation or had inquired as to whether the Central Office file was complete, Alexander still would have been incarcerated improperly. We know this for two reasons.

First, as discussed above, the record suggests that the Central Office had all of Alexander’s documents when they made *1404 their authoritative determination. See pp. 1402-1403. Hence, any failure to verify that his file was complete simply didn’t matter; the file, in fact, was complete.

Second, any failure by defendants to notify Bureau of Prisons officials that Alexander thought his sentence had been improperly calculated didn’t matter; he had the right to bring the matter directly to their attention. The Bureau of Prisons administrative remedy procedure allows inmates to appeal adverse decisions by prison officials. 8 If Alexander felt that defendants had ignored his request or failed to handle it properly, his remedy was to present any and all documents in his possession to the Regional Director and, if still not satisfied, to the General Counsel.

We require prisoners to exhaust this administrative appeals process, which was designed to check the actions of local prison officials, because it will correct many of their errors. See Chua Han Mow v. United States, 730 F.2d 1308, 1313 (9th Cir.1984) (“It is only when a prisoner has exhausted his administrative remedies that he becomes entitled to litigate the matter in ... court.”), cert. denied, 470 U.S. 1031 , 105 S.Ct. 1403 , 84 L.Ed.2d 790 (1985). The district court denied Alexander’s first petition for habeas corpus because he had not pursued his remedies within the Bureau of Prisons. CR Habeas 17.

Alexander subsequently pursued the Bureau of Prisons appeal procedure without success, 9 renewed his petition for a writ of habeas corpus, and succeeded in getting the writ. In Alexander’s case, the Regional Director and General Counsel failed to correct the Central Office’s mistake. The district court finally calculated his sentence properly. We are faced with the fact that the Central Office, and then the Regional Director and Office of the General Counsel, simply got it wrong, even with all the information in hand. The internal review process, unfortunately, is not foolproof.

This is regrettable. But the fact is, Alexander was improperly incarcerated because a number of Bureau of Prisons officials made bad calls in resolving a complex matter. Defendants actions were not the source of the error, and their failure to ask anyone else to look into the situation or to pass on documents did not make any difference; the Bureau of Prisons officials who had the power to correct the error did not do so, even when they were notified of Alexander’s claim and had the complete file to review. Alexander thus cannot claim any injury from defendants’ actions, and they cannot be held liable for damages in a Bivens actions.

IV

The majority’s conclusion that defendants are not entitled to summary judgment on the issue of qualified immunity will have repercussions far beyond this case. By finding that prison officials are not entitled to qualified immunity when they show that they followed all applicable regulations and that other officials were responsible for the calculation, the majority undermines the Bureau of Prisons’ administrative scheme for making foreign jail credit determinations. The scheme provides for Central Office handling of the substantive determinations. Yet the ma *1405 jority implies that it is not enough for prison officials to fulfill their duty under Bureau of Prisons regulations and forward information to the Central Office, leaving the calculations to the Central Office. It is not clear to me what prison officials are now supposed to do when prisoners are dissatisfied with Central Office determinations. It will certainly not be clear to prison officials, who will probably try to second-guess Central Office determinations in order to protect themselves from crushing financial liability. So much for the Bureau of Prisons’ sensible decision to centralize the handling of foreign jail credit matters.

More broadly, the majority’s analysis extends to all manner of Bureau of Prisons determinations over which local wardens and other officials have no control. The majority’s failure to respect Bureau of Prisons regulations allocating responsibility for foreign jail-time credit determinations renders the rest of the administrative scheme vulnerable. Whenever a prisoner claims that Central Office officials were wrong about something, local prison officials will revisit those decisions in order to avoid personal liability, despite the fact that they are ill-equipped to do so. The majority essentially inverts the Bureau of Prisons chain of command, requiring local officials to check and second-guess the decisions of their superiors — decisions which they do not have the expertise to evaluate or the authority to reverse. This places a serious burden on local prison officials and throws a monkey wrench into an administrative scheme designed to bring expertise to bear in the most efficient way possible.

Conclusion

I sympathize with the majority’s frustration with the prison bureaucracy and certainly regret that Alexander was the victim of a bureaucratic mistake that cost him nine months of freedom. But it wasn’t the defendants’ mistake. The only mistake in this case was made by Central Office employees; if they violated a clearly established right, Alexander might have a Bivens claim against them.

The majority stretches the term “investigate” beyond all recognition by using it to support a Bivens claim against defendants for Alexander’s improper incarceration. The duty to investigate is simply part of the Bureau of Prisons’ internal procedure for handling complaints. A Bivens remedy based on the duty to investigate, as construed by the majority, makes local prison officials personally liable for the full range of constitutional violations that may occur in the prison system, whether or not they have any responsibility for or ability to prevent those errors. The Bureau of Prisons surely never meant for local officials to bear this burden of liability by requiring them to operate a grievance procedure.

In attempting to do justice to Alexander, we must not do an injustice to Rivera and Perrill. By ignoring the record and the distribution of responsibility in the prison system, the majority holds two local officials liable for harm they did not cause and which they were helpless to prevent.

. Section 3568 was repealed by the Sentencing Reform Act of 1984, Pub.L. No. 98-473, Title II, Chapter II, § 212(a)(2), 98 Stat. 1976 , 1987. This repeal, however, does not affect this case because it only applies to offenses committed after November 1, 1987. See 98 Stat. 2031 (1984).

. The clerk's record in this action is referred to as "CR." The clerk’s record in Alexander’s ha-beas action, CIV 86-429-TUC-RMB, District of Arizona, is referred to as "CR Habeas.”

. My colleagues marvel that neither of the parties cited Haygood v. Younger, 769 F.2d 1350 (9th Cir.1985) (en banc), cert. denied sub nom Cranke v. Haygood, 478 U.S. 1020 , 106 S.Ct. 3333 , 92 L.Ed.2d 739 (1986), on which the majority places great weight. The parties did not miss a great case; Haygood is not cited by anyone because it is not on point. In Haygood, the defendants were charged with making the relevant sentencing computation; the authority had not been delegated to other officials. Thus, the prison officials could not argue that the responsibility for making the computation belonged to another office and that they had verified that this office had in fact made a determination. The prison officials did rely on an attorney general’s opinion. Id at 1353. But an advisory opinion is not the same thing as a determination by the office that has binding authority on an individual matter. The prison officials in Haygood remained fully responsible *1402 for the calculation. Haygood may be factually similar, but legally has little to do with this case.

.“[W]e must accord substantial deference to an interpretation of section 3568 by the agency charged with its administration.... ” Brown, 895 F.2d at 535 ; see Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842-43 , 104 S.Ct. 2778, 2781-82 , 81 L.Ed.2d 694 (1984). The majority fails to give deference to the Bureau of Prisons’ policy of delegating foreign jail credit decisions to officials at the Central Office. It also fails to explain why this administrative scheme is an unreasonable interpretation of section 3568; I doubt that it could.

. See Guerra v. Sutton, 783 F.2d 1371, 1375 (9th Cir.1986) (government officials may reasonably rely on the decisions of other officials).

. Defendant Perrill, on behalf of the institution, responded to Alexander’s Request on the bottom half of the form as follows:

Your request for relief is denied. CR Habeas 23, Exhibit A.

. Also, as discussed below, even if defendants had failed to pass on some documents, Alexander cannot claim any injury. See p. 1404. Defendants’ actions did not make any difference because Alexander could have appealed their determination within the Bureau of Prisons and presented any and all documents that he possessed via the administrative appeals process.

. 28 CFR § 542.15 outlines the appeal procedure:

. Alexander submitted proof to the district court that he had filed the necessary appeals with the Bureau of Prisons and had been denied at each stage. On September 12, 1986, he filed a Request for an Administrative Remedy that was denied by Perrill on September 16. CR Habeas 23, Exhibit A. On September 17, 1986, he submitted a Regional Administrative Remedy Appeal, which was denied by the Regional Director on September 29. Id, Exhibit B. On October 4, 1986, Alexander filed his final Bureau of Prisons appeal with the General Counsel. CR Habe-as 24, Attachment. This appeal was denied on November 7, 1986. Id.