Guidelines & Policies


  1. Audit Process
  2. Certification Process
  3. Complaints Handling Process
  4. Appeals Handling Process
  5. Impartiality Policy
  6. Confidentiality Policy
  7. Use of Certification Marks & Logos
  8. TRC Management System Certification Program Terms & Conditions

Audit Process

AUDIT & REGISTRATION OF MANAGEMENT SYSTEMS

  1. Purpose
    1. The purpose of this procedure is to identify the responsibility and authority and provide a process for planning, conducting and reporting of initial, surveillance or re-registration audits for issuance of certificates of registration.
  2. Responsibility
    1. The TRC Client Services Manager is responsible for ensuring assignment of qualified audit personnel to perform audit activities; the VP of Accreditation shall remain accountable.
    2. TRC Qualified Reviewers are responsible for making decisions or authorizing decisions with regard to the granting, renewing, suspending, or withdrawing of client registrations.
    3. For Aerospace Audits: TRC Aerospace Client Services Manager shall be responsible for ensuring required audit data is entered into the OASIS database, per AS 9101 and the AS 9104/1 Appendix C “Information To Be Uploaded Into The Online Aerospace Supplier Information System Database”.
  3. Definitions
    1. Nonconformity – the absence of, or the failure to implement and maintain one or more quality management system requirements, or a situation that would, on the basis of objective evidence, raise significant doubt as to the quality of what the organization is supplying.
        1. Major Nonconformity is either: a) the absence or total breakdown of a quality management system element that results in failure to meet a specified requirement; or b) a nonconformance that judgment and experience indicate is likely either to result in the failure of the quality management system or to materially reduce its ability to assure controlled processes, products or services or c) where the effect is judged to be detrimental to the integrity of the product, processes or service or d) an instance or multiple instances where compliance to legal or regulatory requirements are not addressed and has a negative impact on the environment.
        2. Minor Nonconformity is either: a) a single observed lapse in following one item of a company’s quality management system; or b) a nonconformance that judgment and experience indicate is not likely to result in the failure of the quality management system or reduce its ability to assure controlled processes, products or services; or c) a single system failure or lapse in conformance with a procedure relating to the AQMS standard or d) an instance or multiple instances where compliance with legal or regulatory requirements are not addressed but do not have an impact on the environment.

      NOTE 1: a number of minor nonconformities against one requirement can represent a total breakdown of the system and this can be considered as a major nonconformity.

      NOTE 2: if during an EMS audit an organization is observed as having a noncompliance against a legal requirement, the lapse is written as nonconformity against a clause of the ISO 14001 Standard, not against a law or regulation the organization fails to meet.

      1. Stage 1 – The combined assessment of the client’s documented management system and preparedness for the Stage 2 audit. Typically, this consists of a 0.5 day review, which can be either off-site or on-site contingent upon the agreement obtained from both the client and Lead Auditor, of Tier 1 & 2 documents and an on-site assessment of the client facility to plan and prepare for Stage 2.
      2. Stage 2 – An assessment performed on-site at a client’s facility to confirm the organization’s management system adheres to policies, procedures, and objectives of the applicable standard or normative documents and to assess the overall implementation and effectiveness of the management system to a defined scope of activities.
  4. Assigning of New Clients
    1. Once the Sales Manager has effectively won a new contract with a new client they submit the signed proposal and signed Terms & Conditions to the VP of Accreditation for review and assignment of Client Services Manager.
    2. The VP of Accreditation reviews all relevant documents and assigns the Client Services Manager based on workload, audit scheme and location.
    3. The VP of Accreditation signs the Terms & Conditions and returns a fully executed copy to the Client Services Manager for distribution to the client.
  5. Planning Audits
    1. Prior to the Stage 1 Audit, an audit programme for the full certification cycle will be developed to clearly identify the audit activities required to demonstrate that the client’s management system fulfils the requirements for certification to the selected standard(s) or normative document(s).
      1. The audit programme will be documented and will include a two-stage initial audit, surveillance audits in the first and second years, and a recertification audit in the third year prior to expiration of certification.
        1. Determination of the audit programme and any subsequent adjustments shall consider the following:
          1. Size of the client organization;
          2. The scope and complexity of its management system;
          3. Products and processes as well as the demonstrated level of management system effectiveness; and
          4. The results of any previous audits.
    2. All audits are planned/scheduled in accordance with Work Instruction 9-02-D.
    3. Planning for multiple site registrations is conducted based on Work Instruction 9-02-D and Quality System Procedure 09-05.
    4. Auditors are assigned in accordance with Work Instruction 9-02-D.
  6. Initial Certification Audit
    1. Stage 1 Audit
      1. Client’s Documented Management System (QMS, EMS, AQMS)
        1. A detailed review of the client’s documented management system, Tier 1 and Tier 2 (manual and procedures respectively) is conducted to determine conformance with the applicable management system requirements.
        2. The documented system must be reviewed and approved prior to the Stage 2 assessment.
        3. The assigned, qualified individual performs this review in accordance with the applicable TRC Audit Report.
        4. For AS 9100/9120 audits, the review shall be performed by a qualified aerospace auditor and will include any additional quality system processes established to meet customer needs.
        5. For EMS document review, the review shall be conducted by a qualified EMS auditor and shall include:
          1. EMS documentation, including procedures;
          2. A description of the organization and its on-site processes;
          3. An indication of environmental aspects and their associated impacts and the determination of significant environmental aspects (at minimum at least one significant environmental aspect must be identified);
          4. The means by which the concept of continual improvement is realized;
          5. An overview of the applicable regulations (including licenses/permits), and any agreements with Authorities;
          6. Internal audit programs and reports.
          7. Reviewing and ensuring the organization has established procedures to define the criteria by which environmental aspects and their associated impacts are identified as significant.
          8. Ensure the documented system describes the EMS and makes clear any relationship, where applicable, to any other related management system in operation in the organization or having an influence on the EMS subject to certification. Where the organization combines the documentation for environmental and other management systems (such as for quality or health and safety), the components of the EMS must be clearly identified together with the appropriate interfaces to the other systems.
        6. A report of the results of the document review will be prepared and the client notified of any omissions or deviations from the requirements with a request that revisions meeting those requirements be submitted for review and approval.
        7. When it is determined that the client’s documented management system meets the applicable quality system requirements, the client is notified that the manual and subsequent Tier 2 documents are approved.
        8. Readiness Review (QMS & AQMS)
          1. In nearly all cases the readiness review will occur on-site at the client’s facility.
          2. Where the readiness review is conducted by more than one auditor, the Lead Auditor has the responsibility for coordinating and documenting the activities of the audit team.
          3. The Lead Auditor will be responsible for documenting and communicating any nonconformities found during the Stage 1 Audit, including identification of any areas of concern that could be classified as nonconformity during the Stage 2 audit.
            1. The Lead Auditor has complete responsibility for conducting the audit in accordance with WI 9-02-E.
        9. Readiness Review (EMS)
          1. In nearly all cases the readiness review will occur on-site at the client’s facility.
          2. Where the readiness review is conducted by more than one auditor, the Lead Auditor has the responsibility for coordinating and documenting the activities of the audit team.
          3. The Lead auditor will gain an understanding of the EMS in the context of the organization’s environmental aspects and associated impacts, policy and objectives, and the overall preparedness for the Stage 2 audit by reviewing the extent to which:
            1. The EMS includes an adequate process for identification of environmental aspects and subsequent determination of their significance (at minimum at least one significant environmental aspect must be identified);
            2. The relevant activities of the organization, environmental licenses are in place.
            3. The EMS is designed to achieve the organization’s environmental policy.
            4. The EMS implementation program justifies proceeding to the audit (Stage 2).
            5. The internal audit conforms to the requirements of the EMS standard.
            6. Management reviews are being conducted and cover the continuing suitability, adequacy and effectiveness of the EMS.
            7. The EMS documents and responds to relevant communication from external interested parties.
            8. Additional documentation has to be reviewed and/or what knowledge has to be obtained in advance.
          4. The Lead Auditor will document the information required above and ensure submission of documentation to TRC in a timely manner.
    2. Stage 2 Audit (QMS & AQMS)
      1. Based on the results of the Stage 1 audit, Stage 2 will be planned in accordance with WI 09-02-D.
        1. The Lead Auditor has complete responsibility for conducting the audit in accordance with WI 9-02-E.
      2. For AS 9100/9120 sector audits, the Lead Auditor has the responsibility:
        1. To prepare and present the audit results, stating the conclusions on conformance and effectiveness of the quality system;
        2. To ensure closure and verification of effectiveness of corrective action(s).
    3. Stage 2 Audit (EMS)
      1. Based on the results of the Stage 1 audit, an audit plan is prepared and forwarded to the client.
      2. The objective of the Stage 2 EMS audit is to:
        1. confirm the organization adheres to its own policies, objectives and procedures.
        2. confirm that the EMS conforms with all the requirements of the EMS standard and is achieving the organization’s policy objectives.
      3. The Lead Auditor has the responsibility to conduct the audit in accordance with Work Instruction 9-02-E and to ensure the implementation of all elements of the standard (except those fully and successfully audited in Stage 1) and in particular focus on the organization’s:
        1. identification of environmental aspects and subsequent determination of their significance (at minimum at least one significant environmental must be identified);
        2. procedures to ensure compliance with legal and other requirements;
        3. objectives and targets derived from the evaluation process;
        4. operational control;
        5. performance monitoring, measuring, reporting and review against the objectives and targets;
        6. identification and evaluation of nonconformities and completion of corrective/ preventive actions;
        7. internal auditing and management review;
        8. management responsibility for the environmental policy;
        9. links between policy, environmental aspects and their associated environmental impacts, objectives and targets, responsibilities, programs, procedures, performance data, internal audit and review.
      4. Where the EMS Stage 2 audit is combined with another management system audit, the Lead Auditor shall ensure the roles of all team members along with the criteria to be audited are clearly defined.
      5. The Lead Auditor shall also ensure that the quality of the audit is not adversely affected by the combining of the different management system audits.
  7. Audit Package
    1. The audit package will be submitted to TRC by the Lead Auditor within seven working days from completion of the audit and shall include items identified on the Audit Review and Cert Decision Document and any necessary supporting documentation.
    2. The Lead Auditor shall ensure the audit package is complete and includes the recommendations, as applicable, for certification.
    3. If the recommendation is to defer registration, reason(s) will be summarized.
  8. Audit Report Preparations And Review
    1. See WI 9-02-F for Audit Report Preparation and Review requirements.
  9. Issuance Of The Certificate
    1. Once the formal audit report is reviewed and approved and it has been determined that the client has met all the requirements for registration, TRC shall ensure issuance of the certificate, valid for three years in accordance with Work Instruction 9-02-C.
    2. In cases of AS 9100/9120 sector audits, all identified items of nonconformance must be closed and verified for implementation and effectiveness before issuance of the registration certificate. In some cases, this may require additional on-site audit time.
      1. The issuance of the registration certificate will not occur until the client has met all requirements in accordance with AS 9104, including but not limited to submitting the required information in the IAQG OASIS Database to set up the Supplier Administrator.
      2. In addition, any certification documents issued as a result of a combined audit, shall be issued as either one single certificate referencing all AQMS standards, or separate certificate for each AQMS standard.
    3. For all other registrations, corrective action plans and root cause analysis for items of nonconformance must be accepted prior to issuance of the registration certificate. Verification may occur during the subsequent surveillance activity, unless otherwise noted by the Lead Auditor.
    4. The client’s name is entered into TRC’s Registration Listing (Certification Log) and, where applicable, the OASIS database.
    5. When a certificate is being issued for the first time, TRC operations will add the certificate number to the client’s Terms and Conditions and resend to the client.
  10. Surveillance Audits
    1. Surveillance audits are performed on-site (not necessarily full system audits) at least once per calendar year, scheduled from the date of the last audit activity. The date of the first surveillance audit following initial certification shall not be more than 12 months from the certification decision date. At a minimum, all areas of the Client’s quality management system shall be audited within a two-year period so that TRC can maintain confidence that the certified management system continues to fulfill requirements between recertification audits.
    2. Surveillance audits are performed to:
      1. Verify the continued implementation and effectiveness of the QMS, EMS, and AQMS;
      2. Ensure that representative areas and functions covered by the scope of the management system are monitored on a regular basis;
      3. Take into account, changes to the certified client and their management system;
      4. Assess the client’s management system’s fulfillment of specified requirements with respect to the standard to which the certification is granted.
    3. Surveillance audit programme shall include, at least:
      1. Review of the organization’s Management Review and Internal Audit processes;
      2. A Review of the corrective and preventive action program(s) including any actions taken on nonconformities identified during the previous audit;
      3. Customer complaints, changes in the documented system, and any other areas subject to change; and
      4. Continued effectiveness of established procedures for receiving, documenting, and responding to relevant communications from external parties as required by the management system;
      5. Effectiveness of the management system with regard to achieving the certified client’s objectives;
      6. Progress of planned activities aimed at continual improvement;
      7. Functioning of procedures for periodic evaluation and review of compliance with relevant environmental legislation and regulations;
      8. Continuing operational control; and
      9. Use of marks and/or any other reference to certification.
      10. (EMS Only) A Review of a client’s environmental aspects and impacts to ensure that they have identified those that have a higher value, significance, or importance, and use these resultant aspects and impacts to appropriately address the requirements of the standard for objectives and targets, personnel training and awareness, communication, operational controls, and monitoring and measurement (as evidenced in procedures or processes).
    4. Upon receipt of the surveillance audit package, TRC Operations ensures that the client is notified of the results of the audit including a request for corrective action of any findings.
    5. Where surveillance is performed on combined management systems, reporting shall clearly indicate all aspects relevant to each applicable management system.
    6. See WI 9-02-F and QSP 1-2-02 for requirements related to the review of Surveillance Audit activities.
  11. Special Audits
    1. A special audit could take place as a result of a request generated by:
      1. The client for the purpose of addressing scope changes;
        1. Based on a review of the request, the VP of Accreditation will decide whether to accept the scope revision or to schedule a visit to audit the client’s revised scope.
      2. The client for the purpose of addressing extensions to scope, in which case a review of the request will be conducted and any necessary audit activities will be determined (this can be conducted in conjunction with a surveillance audit);
      3. TRC Auditors for the purpose of follow-up for closure or verification of nonconformance corrective action;
      4. TRC for the purpose of addressing complaints/concerns raised by the registered client’s customer (i.e. AAQG, OEM, etc.);
        1. Upon approval, the results of the audit will be forwarded to the applicable party.
      5. TRC for the purpose of addressing any changes; or
      6. TRC for the purpose of following-up on suspended clients.
    2. Upon scheduling, TRC Operations will ensure preparation and delivery of an audit plan, if applicable, identifying the areas or processes that will be the subject of the assessment.
    3. Upon completion, the VP of Accreditation or delegate will ensure preparation and timely delivery of a formal audit report; if applicable.
  12. Renewal Of Client’s Registration
    1. A re-certification audit is conducted to confirm the continued conformity and overall effectiveness of the management system in its entirety, and its continued relevance and applicability for the scope of certification. It is conducted prior to the expiration of the client’s registration certificate.
    2. The Client Services Manager has the responsibility of issuing a new proposal and executing the Terms & Conditions in accordance with procedure (QSP 9-01). Prior to proceeding with the re-certification assessment the Client Services Manager must ensure this has been completed and all relevant documents have been returned by the client.
      1. Once the forms are returned they are sent to the VP of Accreditation for review and the Terms & Conditions are signed and returned to the client by the VP of Accreditation.
    3. The re-certification assessment is an on-site audit of the client’s full system which considers the performance of the management system over the period of certification, and includes the review of previous surveillance audit reports.
      1. In situations where there have been significant changes to the management system, the client, or the context in which the management system is operating, a recertification audit may need to include a Stage 1 audit.
    4. The re-certification audit shall include an on-site audit that addresses the following:
      1. The effectiveness of the management system in its entirety in the light of internal and external changes and its continued relevance and applicability to the scope of certification;
      2. Demonstrated commitment to maintain the effectiveness and improvement of the management system in order to enhance overall performance;
      3. Whether the operation of the certified management system contributes to the achievement of the organization’s policy and objectives;
    5. For all recertification audits, planning must take into consideration time needed for any required follow-up to ensure renewal can be granted prior to the expiration of the registration certificate.
      1. In the case of multiple sites or certification to multiple standards, the planning for the audit shall ensure adequate on-site audit coverage to provide confidence in the certification.
  13. Changes To The Client’s Quality Management System
    1. The client shall be responsible for promptly informing TRC about proposed changes to their quality management system or any other changes which may affect conformance to the requirements of registration.
      1. The VP of Accreditation or delegate shall review the proposed changes for conformance to the registration requirements and recommend accepting or rejecting the changes, and/or recommending if an audit or investigation is required. The final decision shall be communicated to the client.
    2. If a client fails to report these changes to TRC, the VP of Accreditation or delegate will determine the action to be taken in accordance with QSP 1-2-02.
  14. Changes To The System Rules
    1. Dependant on the nature of changes in system rules, the VP of Accreditation or delegate shall:
      1. Notify clients of any changes impacting them;
      2. Specify an effective date for the change to allow time for clients to revise their quality management system;
      3. Notify all clients affected by the changes of the effective date of the change and actions required by them;
      4. For clients certified to an AS standard, an upgrade to a new revision of said standard must be conducted in accordance with the requirements conveyed by TRCs governing bodies (IAQG, etc.).
    2. If the client fails to take the required action by the effective date, the VP of Accreditation will determine the action to be taken in accordance with QSP 1-2-02.

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Certification Process

REVIEW, ISSUANCE, SUSPENSION & WITHDRAWAL OF REGISTRATIONS

  1. Purpose
    1. The purpose of this procedure is to provide a system and instruction for granting, refusing, maintaining, renewing, suspending, restoring or withdrawing of registrations or expanding or reducing the scope of certification.
  2. Initial Registrations and Re-Registrations
    1. Upon completion of the audit review process and a certification decision indicating
      recommendation for initial registration/re-registration the Certification Coordinator will
      process the certificate of registration in accordance with Flow Chart 6 Certificate Issuance.
    2. Should the registration request be refused, the VP of Accreditation shall prepare a letter for the client stating the reason for refusal and resulting action.
    3. If re-registration 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 VP of Accreditation will inform the client of the decision and any consequences in writing.
    4. Any disputes or appeals arising from the results of the review for decision
  3. Scope Extension/Reduction
    1. Requests for extensions/reductions of scopes shall be reviewed by the VP of Accreditation 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.
    2. If the VP of Accreditation determines that audit activities are not required prior to scope extension/reduction, the Certification Coordinator will revise the certificate of registration and record the actions on Form 49B Certificate Revision Record.
  4. Restoring Certification
    1. 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.

      1. If recertification activities are not completed within 6 months of expiration of certification, at least a Stage 2 audit shall be conducted.
    2. The effective date of the restored certificate shall be the recertification decision date.
    3. The expiry date of the restored certificate shall be based on the prior certification cycle.
    4. The original certification date may be kept on the restored certificate provided that the following dates are also included:
      1. The current certification cycle start and expiry dates;
      2. The last certification cycle expiry date; and
      3. The date of the recertification audit.
  5. Suspension and Withdrawal
    1. Recommendations to suspend or withdraw registration 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 VP of Accreditation shall prepare a Letter of Suspension or Letter of Withdrawal and forward to the client.
    2. 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.
    3. 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.
    4. Failure by the client to resolve the issues that have resulted in suspension within 6 months shall result in withdrawal or reduction of the scope of certification.
    5. A Letter of Withdrawal includes the reason for withdrawal, the conditions of withdrawal, and information regarding the appeals process.
    6. When a client requests voluntarily suspension or withdrawal of their certificate of registration, the VP of Accreditation reviews the request and processes the suspension or withdrawal as stated above.
    7. Suspension or withdrawal of registration may also be initiated by the VP of Accreditation outside of an audit activity for reasons including, but not limited to:
      1. Client is unable or unwilling to allow access to their facility/site by TRC and/or audit personnel;
      2. Client is unable or unwilling to address environmental concerns or issues associated with the facility/site;
      3. Client is unable or unwilling to comply with new requirements for the Program or standard;
      4. Client is found to be in violation of the terms and rules for use of the marks and/or certificate;
      5. Client is unable or unwilling to meet financial obligations;
      6. Client ceases to supply the products/services under the scope of certification; or
      7. Client no longer complies with the TRC Management System Certification Program Terms and Conditions.
    8. Suspended and withdrawn certificates are tracked on the TRC Certification Log.
    9. The OASIS database will be updated within 14 calendar days from suspension or withdrawal of a client’s certificate.
  6. Upgrading/Transitioning to New/Revised Standards
    1. 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 certificate of registration will be revised following completion of the audit review process.
    2. 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.

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Complaints Handling Process

CUSTOMER COMPLAINTS

  1. Purpose
    1. The purpose of this procedure is to outline the process and responsibility for the handling of customer complaints.
  2. Responsibility and Authority
    1. 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 Vice President of Operations 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 Vice President of Operations 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.
  3. Procedure
    1. Complaints Filed Against TRC
      1. 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.
      2. 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 www.theregistrarco.com. Complaints can be made anonymously.
      3. All Complaints made against TRC by current clients are documented by the Vice President of Operations on the Client Feedback Excel Spreadsheet and processed in accordance with FC 08 – Customer Satisfaction.
      4. 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.
      5. Complaints against an auditor’s performance or conduct will be documented by the Vice President of Operations 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.
      6. All other complaints are documented and discussed with Top Management at the next Operations Meeting.
    2. Complaints Filed Against TRC Clients
      1. 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 system.
      2. 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 www.theregistrarco.com. Complaints can be made anonymously.
      3. Upon receipt of a customer complaint, the Vice President of Operations 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 Vice President of Operations will open an investigation. If the complaint does not relate to certification activities controlled by TRC, the Vice President of Operations will inform the complainant and the complaint will be closed.
        1. If the complaint relates to a TRC certified client, then examination of the complaint will consider the effectiveness of the certified management system.
      4. Investigation of complaints and required follow-up actions are documented on Record of Complaint (Form 31) and tracked on the TRC Complaints Log.
      5. v. The Vice President of Operations 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.
      6. 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.
      7. Wherever possible, TRC will provide the complainant with progress reports regarding the investigation of the complaint.
      8. 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.
        1. 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.
      9. Wherever possible, TRC will provide formal notice of the end of the complaints handling process to the complainant.
      10. 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.
      11. Once the investigation has concluded, the Vice President of Operations 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.

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Appeals Handling Process

CLIENT APPEALS

  1. Purpose
    1. To define the actions taken to process and adjudicate client appeals.
  2. Responsibility and Authority
    1. TRC retains responsibility for all decisions at all levels of the appeals-handling process. The VP of Accreditation or delegate is responsible for selecting members of the Appeals Committee and chairing meetings. The VP of Accreditation 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.
  3. Right to Appeal
    1. 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.
  4.  Procedure
    1. Upon receipt of an appeal from a client, the VP of Accreditation will acknowledge receipt of the appeal. Additionally, a progress report will be provided to the appellant within two weeks of receipt.
    2. Upon receipt of an appeal from a client, the VP of Accreditation will appoint three contract auditors to serve on the Appeals Committee. Members will not have participated in the evaluation or registration under appeal. The VP of Accreditation willserve 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.).
    3. 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 to complete review.
    4. The Appeals Committee will review all documentation for specific items that are under appeal and may interview any involved party to resolve any conflicting issues.
    5. The VP of Accreditation will convene a meeting of the Appeals Committee.
    6. 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.
    7. After a majority vote on the appeal, the VP of Accreditation will advise the client in writing of the result and advise the client of right to further appeal, as applicable.
    8. Upon receipt of the decision of the Appeals Committee the client may contest the decision of the Appeals Committee to the VP of Accreditation. The VP of Accreditation will convene a second Appeals Committee 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 (Form 19) and tracked on the TRC Appeals Log.

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Impartiality Policy

TRC IMPARTIALITY POLICY

  1. Purpose
    1. The purpose of this procedure is to provide a method by which TRC manages impartiality and conflict of interest in providing certification services. TRC shall not provide certification when a relationship poses an unacceptable threat to impartiality.
  2. Responsibility and Authority
    1. VP of Accreditation has the overall authority and responsibility for ensuring impartiality. VP of Accreditation has the responsibility to analyze and document perceived or potential areas that could impact impartiality or conflict of interest and ensure that decisions of the Impartiality Committee are carried out. The Impartiality Committee has the responsibility to review decisions and provide oversight to TRC.
  3. Definition
    1. Conflict of Interest: Any interest of an individual, their family, or trust, in an organization which may affect an individual’s ability to objectively perform evaluations of or render decisions concerning an organization. Their interest may be financial (other than less than 1% stock ownership in a publicly traded company), employee/employer relationship, a consultant/client relationship, a teacher/client relationship, conducting of internal audits for clients or any other relationship which may be perceived as a conflict of interest. Such relationships that have been terminated for more than two years may be excluded.
  4. TRC Policy on Impartiality
    1. As an accredited certification body, TRC fully understands the importance of maintaining impartiality in providing management system certification services to its clients. TRC’s top management are committed to ensuring the impartiality of its certification services, the adherence to procedures for maintaining independence and objectivity, and the proactive management of any threat of actual or perceived conflicts of interest affecting certifications. TRC’s impartiality is monitored by a dedicated committee that assures impartiality of its certification services.
  5.  Impartiality and Conflict of Interest
    1. The requirement for safeguarding impartiality is applied at three levels: the structure and operation of TRC, personnel (including employees, contractors, and subcontractors), and relationships with other bodies.
      1. TRC is committed to ensuring impartiality of all management system certifications. TRC does not provide management system consultancy in whole or in part during the course of its business or certification activities.
      2. TRC identifies, analyzes and documents perceived or potential areas of conflict of interest to ensure that any risk of impartiality is eliminated as a result of its relationships, both internal and external.
      3. TRC ensures that all activities of other bodies do not affect the confidentiality, objectivity and impartiality of its certifications. TRC avoids any situation that would create a conflict of interest or the appearance of a conflict of interest arising from the activity of another body.
      4. TRC does not certify the management systems of clients that have received management system consultancy or internal audit services where the relationship between the consultancy body and TRC poses an unacceptable threat to the impartiality of the certification.
      5. TRC does not market management system consultancy and certification services together, nor market its services as linked to an organization that provides management system consultancy.
      6. TRC does not outsource audit activities to organizations that provide management system consultancy.
      7. TRC does not offer management systems certification to other certification bodies.
      8. All personnel, either internal, external, or committees, who would influence the certification activities of TRC shall act impartially and not allow commercial, financial or other pressures to compromise impartiality.
      9. TRC ensures that personnel who have provided management system consultancy, including those acting in a managerial capacity, are not assigned to take part in an audit or in the certification process if they have been involved in management system consultancy on the same management system of any TRC client within two years.
      10. TRC personnel, internal and external, are required to reveal any situation known to them that may present them or the certification body with a conflict of interest. This information is used as input in identifying potential threats to impartiality arising from activities of such personnel or by the organization that employs them. TRC does not use such personnel, internally or externally, unless it can be demonstrated that no conflict of interest exists.

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Confidentiality Policy

TRC CONFIDENTIALITY POLICY

  1. 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 

  1. Upon Certification, the client is entitled to use the TRC Mark, the accreditation body logo/mark, and the certificate of registration as evidence of certification.
    1. The Registered Firm is henceforth referred to as “registered”. 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.
    2. 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 Registered.
    3. Organizations whose product/service includes test, calibration or inspection reports may not use the TRC or accreditation body marks on their reports or certificates.
    4. When the TRC Mark is used, it must always be in conjunction with the company’s name and location.
    5. 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.
    6. 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.
    7. The Client shall immediately, upon written notification, cease and desist use of the TRC Mark in any manner which TRC interprets as misleading.
    8. The Registered Firm shall immediately, upon written notification, cease all use of the TRC Mark upon suspension or cancellation of their certificate.
    9. Any misuse of the TRC Mark is cause for suspension or cancellation of the Registered Firm’s Certificate of Registration.
    10. 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 ANAB mark shall be reproduced only in black on a white or light-colored background or in blue (PMS 286 or equivalent) and red (PMS 485 or equivalent).
    11. If a Registered Firm desires to use the symbol of the Accreditation Body (ANAB) in conjunction with the TRC Mark, the use of the accreditation symbol shall be governed in accordance with items a through 1.10 above. The Accreditation Body’s symbol may only be used if it accompanies the TRC Mark, with the marks as equal in size as possible. The size of the ANAB accreditation symbol must not exceed the size of the TRC Mark.
    12. The Registered Firm has the responsibility to take care of the use or representation of the Certificate of Registration. No Registered Firm 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.
  2. TRC will review the use of marks and/or certificates during surveillance and recertification activities. In the event the client is found to be out of compliance of requirements for use of the marks and/or certificates, TRC will require immediate action or the discontinued use of the marks and/or certificate. Representation of the certification is limited to the scope and locations identified on the certificate. If the client is unable to comply with the requirements for use of the marks and/or certificates, TRC may suspend or withdraw certification.

 TRC will review the use of marks and/or certificates during surveillance and recertification activities. In the event the client is found to be out of compliance of requirements for use of the marks and/or certificates, TRC will require immediate action or the discontinued use of the marks and/or certificate. Representation of the certification is limited to the scope and locations identified on the certificate. If the client is unable to comply with the requirements for use of the marks and/or certificates, TRC may suspend or withdraw certification as indicated in Section XVII and Section XIX of the TRC Management System Certification Program Terms and Conditions.

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TRC Management System Certification Program Terms & Conditions

View the TRC Management System Certification Program Terms & Conditions document

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