Complaints & Appeals

OPG remains open and willing to process negative feedback with as much enthusiasm as positive feedback. Through the formal review and processing of complaints and appeals, OPG can only improve.

For the purposes of its accredited certification services, the following distinctions are understood:

  • “Complaints” refer to reports by clients or any third party of some perceived problem with OPG, its processes, staff or services. These are not limited to clients, but may be filed by any third party, including the public. For client feedback, the complaint procedure is only used if the issue does not fit either the category of a nonconformity contest or appeal. These are discussed in section 5 below.
  • “Appeals” refers to specific requests by clients to review a formal decision issued by OPG, typically related to certification or a nonconformity contest. Appeals would not be submitted by any other third-party. These are discussed in section 6 below.

In all cases, the confidentiality of client information and OPG intellectual property and trade secrets must be protected when responding to complaints or appeals.

In all cases, the assignment of persons for processing complaints or appeals shall ensure impartiality, per the procedure Management of Impartiality.

Complaints

Intake and Acknowledgment

Incoming complaints are routed to the COO. If the complaint was received from an existing client, the complaint is filed within the client file; otherwise the original complaint is filed in a generic set of records for complaints from other interested parties.

If the complainant has provided contact information, the COO or designate will notify the complainant that the complaint was received and is being processed. This acknowledgment must be submitted to the complainant within 10 business days of receipt.

If the complainant has not provided any contact information, then acknowledgment is impossible and need not be performed. The complaint must be processed per the rules below, regardless.

Initial Review

The COO or designate will perform an initial review, to determine:

  1. If the complaint is in reference to duties performed by the COO and/or if the complaint specifically identifies the COO as a subject of the complaint. If so, the COO must pass the complaint on to the Certification Review Committee (CRC) for processing and recuse themselves from further action on the complaint.
  2. If the complaint has sufficient details to allow OPG to understand the issue. If not, the COO or designate will contact the complainant to obtain additional information to better understand the issue. Complaints that are unclear, and for which the complainant is not named, cannot be processed since there is no way to clarify the matter. In such cases, the complaint may be closed without action.
  3. If any conflicts of interest arise which would prohibit OPG from processing the complaint. If so, then the problem must be communicated to the complainant and an alternate method of handling the complaint can be negotiated. This may be suggesting to the complainant where they can file the complaint, with an independent third party, or suggesting alternative complaint resolution methods. A conflict of interest preventing OPG from processing a complaint is extremely unlikely, however.
  4. If the issue is related to a nonconformity contest; if so, then the COO or designate will notify the client that the issue must be processed as a nonconformity contest per the procedure Conformity Assessment Procedure, and cannot be processed as a complaint.
  5. If the issue is not related to OPG certification services, but instead about one of OPG’s certified clients. If so, then OPG will instruct the complainant to raise the issue directly with the certified client; OPG may also refer the complaint directly to the certified client. If the complainant provides evidence that they already raised the issue with the certified client, and wishes to “escalate” the matter to OPG, then it may be processed by OPG. In all cases, OPG should note the matter as related to the OPG client, and consider whether the matter should be addressed in a future audit of the client by OPG.

If the review steps above allow the complaint to be processed normally, then the COO or designate will open a CAR per the procedure Corrective & Preventive Action. The rules for processing the CAR will then be followed.

At the COO’s discretion, the COO or designate may notify the complainant that a CAR has been filed, and give them the CAR number for future reference.

Complaints filed as CARs do not have hard response date or time requirements, as each issue may require a different level of effort – and thus additional time – to resolve.

Investigations

The investigation into the complaint must be done per the procedure Corrective & Preventive Action. This requires root cause analysis and corrective action to resolve all identified root causes. The investigation may discover that no action is necessary, however, if the complaint is deemed invalid or unwarranted after investigation.

The decision to be communicated to the complainant shall be made by, or reviewed and approved by, individual(s) not previously involved in the subject of the complaint.

Any investigations and decisions related to the complaint, including verification of effectiveness, must be made by individuals not previously involved in the subject of the complaint. OPG may utilize the Certification Review Committee or independent experts in the investigation and processing of a complaint, as deemed appropriate.

Updating the Complainant

As is reasonable, the COO or designate should update the client periodically on the status of the complaint, especially in cases where the issue may take more than 3 months to resolve. It is recommended that an update be sent monthly.

Updates must comply with confidentiality rules per the procedure Management of Confidentiality.

Resolution and Closure

Once a complaint-related CAR is closed, the complainant shall be notified. The level of detail of the notification shall be subject to the confidentiality rules per the procedure Management of Confidentiality. OPG should endeavor to provide sufficient detail and evidence to satisfy the complainant, however, provided confidentiality rules are not violated. “Confidentiality” should not be used as an excuse to deny the complainant details as they may need to feel satisfied that the issue was properly investigated and resolved by OPG.

OPG may opt to make some complaints and resolutions public, to the extent that the complainant allows this and considering confidentiality rules per the procedure Management of Confidentiality. In some cases, public disclosure may be prohibited by applicable regulatory or legal requirements.

Escalation

If the complainant is not satisfied with the result of a complaint investigation and any final decisions made, the COO or designate will inform the complainant that two “escalation” paths are open to them:

Escalation to Full CRC

The complainant may request an escalation of the issue to the full Certification Review Committee. In this case, the CRC will convene a special session comprised of at least three members, and review the associated CAR. Any CRC members involved in any way with the original CAR must recuse themselves, but the CRC must be re-populated with three members. The CRC will review the actions taken and issue a report on any suggested changes or deficiencies in the CAR and final decision. If there are issues or deficiencies, the CAR will be re-opened to process the concerns accordingly. If the decision by the CRC is to uphold the decision as originally determined, the COO or designate will notify the complainant accordingly.

Escalation to Accreditation Body

The complainant may raise the issue with OPG’s accreditation body. The COO or designate will provide the complainant with the proper contact method to do so.

Appeals

Intake & Acknowledgment

Clients may appeal a certification decision, such as a decision to deny, suspend, withdraw or reduce the scope of certification.  In addition, a client may use the appeal process to appeal a decision related to a nonconformity contest.

Appeals are not applicable to complaints; instead, these are “escalated” per section 5.6 above.

Appeals are forwarded to the COO. The COO or designate will notify the appellant that the appeal was received and is being processed. This acknowledgment must be submitted to the appellant within 10 business days of receipt.

Submission, investigation and decision on appeals may not result in any discriminatory actions against the appellant.

Initial Review

The COO or designate will perform an initial review, to determine if the appeal has sufficient details to allow OPG to understand the issue and validate the appeal. If not, the COO or designate will contact the appellant to obtain additional information to better understand the issue.

Investigations

The COO or designate will then convene an ad hoc Appeals Committee to investigate the matter. The Appeals Committee may not be comprised of any CRC members or OPG personnel who were involved in the original decision under appeal, including any persons involved in any audit related to the appeal. The Appeals Committee must be comprised of three or five individuals with sufficient knowledge and background to properly investigate the appeal. OPG may use independent third parties for this role.

The CAR system may be used for processing appeals, but a unique CAR must be filed for such appeals; existing CARs related to any issues mentioned in the appeal must remain apart from an appeal-related CAR. In some cases, the CAR system may not prove useful or effective for processing appeals, so this is not mandatory.

The Appeals Committee will review the information and take additional steps, as needed, to investigate the matter.

Updating the Appellant

As is reasonable, the COO or designate should update the appellant periodically on the status of the appeal, especially in cases where the issue may take more than 3 months to resolve. It is recommended that an update be sent monthly.

Updates must comply with confidentiality rules per the procedure Management of Confidentiality.

Resolution & Closure

The Appeals Committee will make a final decision based on this information, and document this in a formal appeals notice.  This decision must be signed by all three of the Appeals Committee members, and must be unanimous. Failure to obtain a unanimous decision will result in the original issue being withdrawn.

The appeals decision will then be provided to the COO or designate, who will provide this to the appellant.

Escalation

If the appellant is not satisfied with the result of an appeal, their only escalation avenue is to file a complaint against OPG with its accreditation body. The COO or designate will provide the complainant with the proper contact method to do so.