Guidelines & Policies
- Audit Process
- Certification Process
- Complaints Handling Process
- Appeals Handling Process
- Impartiality Policy
- Confidentiality Policy
- Use of Certification Marks & Logos
- TRC, A DNV Management System Certification Program Terms & Conditions
Audit Process
INITIAL CERTIFICATION PROCESS-
- Clients, who through the application and audit process satisfy the terms of the TRC Management System Certification Program and the requirements of the applicable standard, will be granted a Certificate. Certificates are subject to the terms of this program, the applicable standard, and any additional requirements imposed by sector specific organizations.
- Upon acceptance of the application and Program agreement, TRC will:
- Coordinate Stage 1 audit activity based on client timelines and expectations for certification;
- Finalize selection of audit personnel. Client has the right to request information regarding proposed team members and may object to the use of any individual. TRC will take into consideration any request made for specific audit personnel provided such individuals meet TRC requirements for auditing;
- Require submission of any necessary documented information for offsite review prior to Stage 1;
- Conduct the Stage 1 Certification Audit. During the Stage 1 audit, the audit team will assess the organization’s overall preparedness for initial certification. The team will assess the implementation of the documented system against the requirements of the applicable standard and any requirements the client has established within the management system. At the conclusion of the audit, the audit team will provide a report identifying the fulfilment of the stage 1 objectives and any area(s) of concern that could be classified as a nonconformance during the Stage 2 audit. The report will also outline the readiness for the Stage 2 Audit.
- Confirm Stage 2 audit activities based on client timelines, Stage 1 audit results, and expectations for certification.
- Conduct Stage 2 certification audit. During the Stage 2 audit, the audit team will conduct an in-depth evaluation through interview and review of documented information to assess the overall effectiveness of the management system to meet the requirements of the applicable standard;
- Perform a closing meeting, at the conclusion of the Stage 2 certification audit, providing the client with a verbal report of any nonconformities and/or opportunities for improvement identified during the audit. The client will have the opportunity to ask questions and/or address any nonconformance prior to the exit of the audit team. The audit team will provide the client with their conclusion, recommendation for certification, and any requirements for follow-up;
- For aerospace sector audits, provide the client with copies of any applicable Nonconformance Reports (NCRs) and Process Effectiveness Assessment Reports (PEARs) associated with those NCRs;
- Upon completion of Stage 2 activities, provide a final written report along with requirements for any actions from the Client, within two weeks of the closing date of the audit;
- As required, coordinate scheduling of visits for closure of nonconformities or re-audit.
- Client will:
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- Identify primary point of contact for TRC for audit coordination, awareness of complaints, and corrective action responses, as well as acting as a liaison for audit personnel;
- Provide access by audit personnel to all facilities, work areas, records, etc. that support the proposed certification;
- Make available required documented information to support the management system;
- Make available copies of internal audit, management review, and complaints and their resolutions;
- ISO 14001 audits may require copies of licenses/permits, records of compliance with regulatory and/or legal requirements, records/evidence of determination of environmental aspects and impacts, environmental objectives and links with associated targets, data, responsibilities, etc.
- ISO 45001 audits may require copies of licenses/permits, records of compliance with regulatory and/or legal requirements, etc.
- Provide timely response as is required to all nonconformities in the form of correction/corrective action;
- Nonconformities identified following initial certification activities are documented on a nonconformity report (NCR) and must be responded to by the due date identified on the NCR.
- Client is required to provide the correction, root cause and take appropriate and effective action so as to eliminate the cause of the identified nonconformity.
- For clients whose certification is for AS9100 or related sector schemes, when the nature of the nonconformity needs immediate containment action, the audit team leader shall require the organization to: describe the immediate actions taken to contain the nonconforming situation/conditions and to control any identified nonconforming products. Containment shall always be recorded and reported within 7 calendar days after the audit.
- Evidence of actions taken is required in support of closure of NCR’s. Onsite verification of effective implementation may be required in order to demonstrate closure.
- Certificates will not be issued to any client while an NCR remains open.
- For clients whose certification is for AS9100 or related sector schemes, verification of effective implementation of all corrective action is required prior to issuance of certificates.
- Client may make an appeal to TRC for any nonconformity issued for which it does not agree in accordance with TRC Appeals Handling Process.
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- internal audit and management review;
- a review of actions taken on nonconformities identified during the previous audit;
- complaints process and any current complaints;
- progress of planned activities aimed at continual improvement;
- continuing operational control;
- review of any changes;
- use of marks and/or any other reference to certification; and
- effectiveness of the management system with regard to achieving the certified client’s objectives and the intended results of the respective management system(s).
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Certification Process
ISSUANCE, RESTORATION, SUSPENSION AND WITHDRAWAL OF CERTIFICATIONS-
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- Purpose
- The purpose of this procedure is to provide a process for granting, refusing, maintaining, renewing, suspending, restoring, withdrawing or verifying certifications and expanding or reducing the scope of certification.
- Initial Certifications and Recertifications
- Upon completion of the audit review process and a certification decision indicating recommendation for initial certification/recertification the Certification Coordinator will process the certification in accordance with Flow Chart 6 – Certificate Issuance.
- Should the certification request be refused, the Chief Compliance and Accreditation Officer shall prepare a written communication for the client stating the reason for refusal and resulting action.
- If recertification activities are not successfully completed prior to expiry of existing certification, including verification of implementation of corrections and corrective actions for any major nonconformance(s), then recertification shall not be recommended and the validity of the certificate shall not be extended. The Chief Compliance and Accreditation Officer will inform the client of the decision and any consequences in writing.
- Any disputes or appeals arising from the results of the review for decision on certification shall be handled in accordance with TBP 11 Client Appeals.
- Scope Extension/Reduction
- Requests for extensions/reductions of scopes shall be reviewed by the Chief Compliance and Accreditation Officer who will determine whether any audit activities are necessary to decide whether the extension/reduction may be granted. Any necessary audit activities may be conducted in conjunction with a regularly scheduled audit, or a special audit may be conducted. Following the completion of the audit activities, the audit review process will be followed as outlined in Flow Chart 4 and Flow Chart 5.
- If the Chief Compliance and Accreditation Officer determines that audit activities are not required prior to scope extension/reduction, the decision will be recorded on FRM 50 Certificate Revision Request and the Certification Coordinator will process the revision to the certification document.
- Restoring Certification
- Following expiration of certification, a client’s certification may be restored within 6 months from date of expiration provided that the outstanding recertification activities are completed within that time.
- If recertification activities are not completed within 6 months of expiration of certification, at least a Stage 2 audit shall be conducted.
- The effective date of the restored certificate shall be the recertification decision date.
- The expiry date of the restored certificate shall be based on the prior certification cycle.
- The original certification date may be kept on the restored certificate provided that the following dates are also included:
- The current certification cycle start and expiry dates;
- The last certification cycle expiry date; and
- The date of the recertification audit.
- Following expiration of certification, a client’s certification may be restored within 6 months from date of expiration provided that the outstanding recertification activities are completed within that time.
- Suspension and Withdrawal
- Recommendations to suspend or withdraw certification resulting from an audit follow the audit review process as outlined in Flow Chart 4 and Flow Chart 5. If the recommendation for suspension or withdrawal is upheld following Certification Decision, the Chief Compliance and Accreditation Officer shall prepare a Letter of Suspension or Letter of Withdrawal and forward to the client.
- A Letter of Suspension includes the reason for suspension, the conditions of suspension, the terms for removal of suspension and restoration of certification, and information regarding the appeals process.
- When the client has fulfilled the conditions for removal of the suspension, TRC will inform the client in writing that the suspension has been lifted. If the client is unable to comply with the terms and conditions for removal of the suspension, the certification will be processed for withdrawal.
- Failure by the client to resolve the issues that have resulted in suspension within 6 months will result in withdrawal or reduction of the scope of certification, in most cases.
- A Letter of Withdrawal includes the reason for withdrawal, the conditions of withdrawal, and information regarding the appeals process.
- When a client voluntarily requests suspension or withdrawal of their certification, the Chief Compliance and Accreditation Officer reviews the request and processes the suspension or withdrawal as stated above.
- Suspension or withdrawal of certification may also be initiated by TRC outside of an audit activity for reasons including, but not limited to:
- Client is unable or unwilling to allow access to their facility/site by TRC and/or audit personnel;
- Client is unable or unwilling to address environmental concerns or issues associated with the facility/site;
- Client is unable or unwilling to comply with new requirements for the Program or standard;
- Client is found to be in violation of the terms and rules for use of the marks and/or certificate;
- Client is unable or unwilling to meet financial obligations;
- Client ceases to supply the products/services under the scope of certification; or
- Client no longer complies with the TRC Management System Certification Program Terms and Conditions.
- Suspended and withdrawn certificates are identified in TRC Scan & Verify.
- The OASIS database will be updated within 14 calendar days from suspension or withdrawal of a client’s certificate.
- The IAF CertSearch database will be updated by end of business day upon suspension or withdrawal of a client’s certificate.
- Upgrading/Transitioning to New/Revised Standards
- When upgrading to a revised standard, the client will be required to have an on-site audit conducted to verify their conformity; additional requirements from each sector will be taken into consideration when planning for the on-site evaluation (ISO, IAF, IAQG, ANAB, etc.). The client’s certification will be revised following completion of the audit review process.
- When a client transitions from one standard to another (i.e. ISO 9001 to AS) the client must go through the initial certification process as defined by each standard.
- Verification of Certificate Status
- The status of TRC certification documents may be verified in the following ways:
- Scanning the QR code on a TRC Scan & Verify certificate or on the client’s TRC Scan & Verify Certification mark
- Searching the company name in the IAF CertSearch database
- Searching the company name in the IAQG OASIS Certified Suppliers Directory (AS9100 series standards, only)
- Sending a request for verification through www.theregistrarco.com
- The Scan & Verify Administrator responds in writing to all requests received through the website
- Sending a request for verification to any TRC staff member
- All such requests must be forwarded to the Scan & Verify Administrator to provide a written response
- The status of TRC certification documents may be verified in the following ways:
- Purpose
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Complaints Handling Process
CUSTOMER COMPLAINTS-
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- Purpose
- The purpose of this procedure is to outline the process and responsibility for the handling of customer complaints.
- Responsibility and Authority
- TRC retains responsibility for all decisions at all levels of the complaints-handling process. In certain cases, involving Aerospace related issues only, complaints that cannot be resolved by TRC may be referred to ANAB for resolution. The Chief Compliance and Accreditation Officer has the responsibility for ensuring that complaints are documented and processed in accordance with this procedure and that the decision to be communicated to the complainant is made by, or reviewed and approved by, an individual not previously involved in the subject of the complaint. If the subject of a complaint does not allow the Chief Compliance and Accreditation Officer to conduct an impartial investigation, handling of the complaint will be assigned to another member of top management. If the subject of a complaint cannot be impartially investigated by any member of top management, then the handling of the complaint will be assigned to the TRC Impartiality Committee.
- Complaints Procedure
- Complaints Filed Against TRC
- Any client or other interested party may file a complaint with TRC regarding any matter related to: the certification process, TRC staff and/or management, or TRC auditors.
- Complaints may be submitted to any TRC staff member and are accepted in writing, over the phone, via the OASIS database (for Aerospace related issues only), and via the TRC website. Complaints can be made anonymously.
- All Complaints made against TRC by current clients are documented by the CEO on the Client Feedback Excel Spreadsheet and processed in accordance with FC 08 – Customer Satisfaction.
- Clients who desire to dispute audit or certification decisions shall be advised to submit an appeal in writing in accordance with TBP 11 – Client Appeals.
- Complaints against an auditor’s performance or conduct will be documented by the CEO on the Client Feedback Excel Spreadsheet and reviewed with the auditor. They will also be used as an input to the auditor’s annual evaluation, competency and risk review.
- All other complaints are documented and discussed with Top Management at the next Operations Meeting.
- Complaints Filed Against TRC Clients
- Any interested party may file a complaint with TRC regarding any matter related to: a certified client’s management system, and/or product related issues that may be a result of the management system.
- Complaints may be submitted to any TRC staff member and are accepted in writing, over the phone, via the OASIS database (for Aerospace related issues only), and via the TRC website. Complaints can be made anonymously.
- Upon receipt of a customer complaint, the Chief Compliance and Accreditation Officer will review the complaint and confirm whether the complaint relates to certification activities under the responsibility of TRC. If the complaint relates to certification activities controlled by TRC, the Chief Compliance and Accreditation Officer will open an investigation. If the complaint does not relate to certification activities controlled by TRC, the Chief Compliance and Accreditation Officer will inform the complainant and the complaint will be closed.
- If the complaint relates to a TRC certified client, then examination of the complaint will consider the effectiveness of the certified management system.
- Investigation of complaints and required follow-up actions are documented on Record of Complaint (FRM 31) and tracked on the TRC Complaints Log.
- The Chief Compliance and Accreditation Officer will determine the actions required to validate and investigate each complaint and will decide what actions need to be taken in response to each complaint, on a case-by-case basis.
- Any valid complaint about a certified client will be communicated by TRC to the certified client in question at an appropriate time. When informing the client about the complaint submitted (and in all instances during the process) confidentiality requirements shall be taken into consideration.
- Wherever possible, TRC will provide the complainant with progress reports regarding the investigation of the complaint.
- Unless otherwise noted, closure of complaints including the provision of feedback (and actions to be taken) to the complainant is due 60 days from date of receipt.
- Complaints/Feedback received through the OASIS Database (Aerospace only) will be investigated and responded to within 30 days of receipt. In the case that a Special Surveillance or Short Notice Audit is necessary, it will be conducted within 90 calendar days of receipt of the complaint.
- Wherever possible, TRC will provide formal notice of the end of the complaints handling process to the complainant.
- TRC will determine, in consultation with the certified client and the complainant, whether the subject of the complaint and its resolution will be made public, and if so, to what extent.
- Once the investigation has concluded, the Chief Compliance and Accreditation Officer or delegate will review the outcome and determine if correction and corrective action are necessary. If required, corrective action(s) will be processed in accordance with TBP 06 – Corrective Action.
- Complaints Filed Against TRC
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Appeals Handling Process
CLIENT APPEALS-
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- Purpose
- To define the actions taken to process and adjudicate client appeals.
- Responsibility and Authority
- TRC retains responsibility for all decisions at all levels of the appeals-handling process. The Chief Compliance and Accreditation Officer or delegate is responsible for selecting members of the Appeals Committee and chairing meetings. The Chief Compliance and Accreditation Officer or delegate is responsible for ensuring that the persons engaged in the appeals-handling process are different from those who carried out the audits and made the certification decisions. Members of the Appeals Committee are responsible to remove themselves from the appeals-handling process where a conflict of interest would prevent impartiality.
- Right to Appeal
- All clients have the right to appeal any decision made with regard to the certification or audit process. The client must make an appeal to TRC in writing within 30 days of being notified of an impending action, including but not limited to: suspension, withdrawal, reduction of scope, or audit nonconformities. Submission, investigation and decision on appeals shall not result in any discriminatory actions against the appellant.
- Procedure
- Upon receipt of an appeal from a client, the Chief Compliance and Accreditation Officer will acknowledge receipt of the appeal in writing. Additionally, a progress report will be provided to the appellant within two weeks of receipt.
- Upon receipt of an appeal from a client, the Chief Compliance and Accreditation Officer will appoint three contract auditors to serve on the Appeals Committee. Members will not have participated in the evaluation or certification under appeal. The Chief Compliance and Accreditation Officer will serve as the fourth member of the Committee (non-voting) and act as Chair. Selection of members of the Appeals Committee shall take into consideration representation of program or scheme for the appellant (i.e. aerospace, environmental, etc.).
- Following selection and acceptance of the Appeals Committee members, a record of the appeal and supporting documentation is forwarded to each Committee member, allowing sufficient time for review.
- The Appeals Committee will review all documentation for specific items that are under appeal and may request to interview any involved party to resolve any conflicting issues.
- The Chief Compliance and Accreditation Officer will convene a meeting of the Appeals Committee.
- After review and discussion of the appeal, the Appeals Committee will vote upon the appeal. A majority vote is required to act upon an appeal. The vote shall include recommendation for actions to be taken by either TRC or the client in response to the appeal.
- After a majority vote on the appeal, the Chief Compliance and Accreditation Officer will advise the client in writing of the result and advise the client of right to further appeal, as applicable. The email to the client with the results of the appeal shall be saved with the appeal documentation.
- Upon receipt of the decision of the Appeals Committee the client may contest the decision of the Appeals Committee to the Chief Compliance and Accreditation Officer. The Chief Compliance and Accreditation Officer will convene a second Appeals Committee, as per the process above, consisting of participants not involved in the first Appeals Committee. The decision of the second Appeals Committee is final.
- Appeals are documented on the Client Appeal Report (FRM 19) and tracked on the TRC Appeals Log.
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Impartiality Policy
TRC IMPARTIALITY POLICY-
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- TRC, in understanding the importance of impartiality, ensures the program and all certification activities are carried out objectively and free from any conflict of interest. All staff, management, and audit personnel are required to communicate any potential risks to conflict of interest and impartiality directly to TRC. The TRC Impartiality Committee oversees impartiality. Client is required to assist TRC in ensuring that activities are free from conflict of interest by communicating to TRC any relationships with staff, management, or audit personnel that would pose a risk to the impartiality of the certification process. This includes any other personnel involved with the certification process, to include: sector organizations, accreditation body personnel, consultants, and internal auditors.
- TRC ensures that all information about the client, whether gathered during audit activities or provided directly to TRC by the client, remains confidential. No staff, management, or audit personnel will divulge information regarding the client to any party without written consent. This does not include providing information to third parties, such as accreditation bodies or sector specific organizations that require sharing of information regarding certified organizations as part of the certification scheme. If the client’s certification requires such sharing of information, signing of the TRC Proposal grants TRC consent to provide such information. When TRC is required by law or authorized by contractual arrangements (such as with the accreditation body) to release confidential information, the client shall, unless prohibited by law, be notified of the information provided.
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Confidentiality Policy
TRC CONFIDENTIALITY POLICY-
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- TRC ensures that all information about the client, whether gathered during audit activities or provided directly to TRC by the client, remains confidential. No staff, management or audit personnel will divulge information regarding the client to any party without written consent. This does not include providing information to third parties, such as accreditation bodies or sector specific organizations that require sharing of information regarding certified organizations as part of the certification scheme. If the client’s certification requires such sharing of information, signing of the TRC Proposal grants TRC consent to provide such information. When TRC is required by law or authorized by contractual arrangements (such as with the accreditation body) to release confidential information, the client shall, unless prohibited by law, be notified of the information provided.
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Use of Certification Marks & Logos
RULES FOR USE OF MARKS/CERTIFICATE Upon Certification, the client is entitled to use the TRC Mark, the accreditation body symbol, and the certificate as evidence of certification.-
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- The Certified Organization is henceforth referred to as “certified”. Any and all reference to the certificate is considered a “Certification”. The term certified should not at any time be used in conjunction with product or service. When referring to the Certification, it is advisable to refer directly to the Management System to eliminate any misunderstanding regarding the product or service the organization provides
- The TRC Mark MAY NOT, under any circumstances, be used directly on or closely associated with products in such a manner as to imply that the products themselves are certified.
- Organizations whose product/service includes test, calibration, or inspection reports may not use the TRC or accreditation body marks on their reports or certificates.
- When the TRC Mark is used, it must always be in conjunction with the company’s name and location.
- The TRC Mark may only be used on correspondence, advertising, and promotional materials which are related to the goods or services referenced in the scope of the company Certification.
- Certified clients are permitted to use a statement on product packaging or in accompanying information that the certified client has a certified management system, providing that the statement in no way implies that the product, process or service is certified by this means and that the statement includes reference to all of the following: identification (e.g. brand or name) of the certified client; the type of management system (e.g. quality, environmental) and the applicable standard; and the certification body issuing the certificate. Product packaging is considered as that which can be removed without the product disintegrating or being damaged. Accompanying information is considered as separately available or easily detachable.
- The Client shall immediately, upon written notification, cease and desist use of the TRC Mark in any manner which TRC interprets as misleading.
- The Certified Organization shall immediately, upon written notification, cease all use of the TRC Mark upon suspension or cancellation of their certificate.
- Any misuse of the TRC Mark is cause for suspension or cancellation of the Certified Organization’s Certificate.
- When reproducing the TRC Mark, no changes may be made to the colour or format of the mark. The size shall be such that all features of the symbol are clearly distinguishable, the length of a side being no less than one-fourth inch, and there shall be no distortion of its dimensions.
- The Certified Organization has the responsibility to take care of the use or representation of the Certificate. No Certified Organization may, at any time, infer that the certificate is applicable to any other location or site of the organization other than the one(s) indicated on the certificate.
- The ANAB accreditation symbol shall only be used in conjunction with TRC’s mark on the Certified Organization’s stationery and literature and in its advertising, subject to the following conditions and TRC’s
conditions for use of its mark as stated in items 1-11.
- An organization certified by ANAB-accredited management systems certification bodies shall use only approved accreditation symbols provided by its ANAB-accredited certification body.
- The ANAB accreditation symbol shall be reproduced on a background that will not impede readability:
- In black or in blue (PMS 286 or equivalent) and red (PMS 485 or equivalent) on a white or light coloured background;
- In a size that makes all features of the symbol clearly distinguishable; and
- Without distortion of its dimensions.
- The certified organization may not place the ANAB accreditation symbol in isolation from the certification body’s mark, and the size of the ANAB symbol must not exceed the size of the certification body’s mark.
- ANAB’s accreditation symbol shall not be used on a product or in such a way as to suggest that the certification body and/or ANAB have certified or approved any product, process, or service of a certified organization, or in any other misleading manner.
- If packaging, etc., used for transportation includes the approved accreditation and certification symbols, a clear statement must be included to the effect that the product contained therein was manufactured in a facility with [specify] management systems certified as being in conformity with [specific standard].
- Upon withdrawal of the ANAB-accredited certification or the certification body’s ANAB accreditation,
the organization shall immediately discontinue use of ANAB’s accreditation symbol, ANAB’s name, and
claims of accredited certification in any medium, including letterhead, electronic media, etc., and
return or destroy any ANAB-accredited certification documents as required by the certification body
or ANAB.
- If an organization continues to use the ANAB accreditation symbol or reference to ANAB, ANAB will publish a notice on its website indicating that the organization is making a false claim of ANAB accredited certification, and ANAB may take legal action.
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