Complaints, Feedback, Corrective and Preventive Action

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1 PAGE 1 of 7 PROCESS OBJECTIVE : To effectively manage all feedback (as defined in QM / 02) and associated correction and corrective action in an effective and objective manner. Feedback includes complaints which is recognised as an important element of customer focus and satisfaction. COMPLAINTS EFFECTIVENESS METRICS SET BY NSAI BOARD: Critical Complaints: Target set by NSAI Board = 0 All complaints to be corrected within 7 calendar days 70% of all corrective action to be completed within 30 days 90% of all corrective action to be completed within 90 days Total number of Certification/NSAI Inc. customer complaints to be less than 0.75% of client facing days OTHER FEEDBACK METRICS External accreditation: Action is to be agreed in writing with the AB within 30 calendar days (or other timeframe as mandated).* External accreditation: Agreed corrective action to be completed and signed-off by the AB within 90 days (complete with evidence) or other timeframe as agreed.* Internal audit corrective action to be completed within 30 calendar days unless alternative target date specifically agreed. * - Note: complete submissions are to be submitted at least two weeks before any deadline to ensure timely closure. STANDARDS The process for complaints management meets ISO 10002:2002

2 PAGE 2 of Definitions Feedback Positive or negative observation (including customer complaints) on a product or service supplied by NSAI or its clients. Feedback sources include customer complaints, customer surveys, observations from staff, nonconformities raised during internal or Third Party audits etc. Nonconformity Correction Corrective Action Preventive Action Continual Improvement Complaint Third Party Complaint The non-fulfilment of a need or expectation that is stated, generally implied or obligatory (ISO 9000:2005) The absence of, or the failure to implement and maintain as effective, one or more required management system elements, or a situation which would, on the basis of available objective evidence, raise significant doubt as to the capability of the Management System to achieve the policies and objectives of the NSAI or the quality of an NSAI product or service. Action to eliminate a detected nonconformity or negative observation raised by feedback Action to eliminate the root cause of a detected nonconformity or negative observation raised by feedback Action taken to eliminate the cause of a potential occurrence, or reduce the risk of potential occurrence, of an undesirable outcome of NSAI operations. Action taken to improve the effectiveness of an area of NSAI operations which is currently performing without non-conformity. Any expression of dissatisfaction, whether justified or not. Complaints need not be made formally. Any written expression of dissatisfaction by a customer of an NSAI Registered Company, whether justified or not. 0.2 Complaint Categories NOTE: Complaint categorisation is the responsibility of NSAI and is normally determined, initially, by the Quality Officer. However, as more information is gathered, the categorisation of the complaint may be changed to reflect the perceived severity. Category 0 Critical Breaches of confidentiality Lack of appropriate accreditation / mandate Action damaging to NSAI s business or reputation

3 PAGE 3 of 7 Category 1 Major A nonconformity i.e. the absence of, or the failure to implement and maintain, one or more required management system elements, or a situation which would, on the basis of available objective evidence, raise significant doubt as to the capability of the Management System to achieve the policies and objectives of the NSAI or the quality of an NSAI product or service. Likelihood of loss of business Category 2 Minor A failure to comply with the requirements of the scheme, that is less significant than, and does not meet the definition of a Category 1 finding. This includes issues which can be readily resolved or which do not cause excessive inconvenience to the customer. Unlikely to result is loss of business Category 3 Observation A comment, an opportunity for improvement or request for clarification. Category 4 Invalid Feedback which, following investigation, is deemed to be unreasonable, or outside the scope of NSAI services, and/or where no correction or corrective action is required. 1.0 Customer complaints/feedback A dedicated address, feedback@nsai.ie, may be used for all feedback submissions and communication with NSAI. This address can be used for any feedback whether it be internally generated, continual improvement suggestion or preventive action proposal. An acknowledgement letter, AD-01-14, shall be used when the complaint is by letter. Written complaints will be acknowledged as soon as possible after receipt (this can be accompanied by the correction). Internal issues requiring corrective action are logged on Q-Pulse and are handled the same as internal audit non-conformities. All issues will be forwarded to the relevant Manager to ascertain validity and to confirm categorisation. Valid issues will be subject to root cause analysis to ensure that corrective and preventive actions are effective. If the Manager is personally involved In the subject of the complaint, the matter will be addressed to his/her Director. Complaints involving a Director will be handled by the CEO. Accreditation Issues: All accreditation non-conformities are to be brought to the attention of the relevant Manager or CEO, NSAI Inc. who will agree responsibility for ownership.

4 PAGE 4 of 7 The relevant manager is responsible for the resolution of all issues raised by the feedback, including: Correction investigation to find the root cause agreeing and assigning correction and corrective actions to resolve and prevent re-occurrence, deciding and obtaining the resources for resolution, specifying and obtaining evidence of effectiveness, deciding deadlines for completion of investigation, reporting the final outcome. NOTE: 1. and Continual Improvement are discussed at management meetings and are not seen as part of the closure of a complaint or item of feedback. 2. The NSAI staff member reporting the feedback issue (or complaint) is always informed upon closure. 3. In general, because of NSAI s confidentiality agreement with its clients, complaints will not be made public. If the complainant puts the complaint in the public domain (e.g. through radio interview or letter to newspaper), NSAI will meet with the client to determine to what extent the complaint and its resolution should be made public. NSAI will record this decision and how the information is to be released to the public domain. 4. The person responding to the complainant is not to be a person involved directly with the complaint. Normally, a manager responds to the complainant but, if the manager is involved directly with the complaint, the response ids to be sent by the Technical Services Manager. 5. For Certification, copies of all correspondence are to be placed on Goldmine (linked to the company) and reviewed at next on-site audit activity and/or re-assessment.

5 PAGE 5 of Third Party Complaints On receipt of a complaint about an NSAI registered company or certified product, NSAI shall request that it be submitted in writing. All written third party complaints will investigate the complaint with the Registered Company concerned. NSAI issue a standard letter (AD-01-15) to the third party reporting the complaint which advises: That NSAI s policy is not to become involved directly in issues / disputes between a Registered Company and one of their customers. However, NSAI will follow-up and ensure that the complaint is being resolved in a fair and business-like manner and will consider the effectiveness of the client s management system. That NSAI will ensure that the Registered Company is handling the matter in accordance with the relevant management system standard and their procedures for handling complaints. That the Small Claims Court may be the right place to take any action to seek any compensation for poor service or product That NSAI thank the third party for reporting the issue to NSAI. That NSAI will inform the complaint of the outcome of their investigation bearing in mind the balance between client confidentiality and openness in complaint resolution. NSAI write to the company which is the subject of the complaint notifying them of the complaint and that NSAI will be investigating the circumstances and action taken.(standard letter AD-01-16) Unless authorised by a manager, there should be no direct communication between the auditor and the complainant. Communications should be from a member of Management. Although openness is encouraged, this should be at a technical level and, as the complaint is with the company, no company staff names should be included in correspondence from NSAI unless they are mentioned by the complainant or, if not, without written permission from the company or the staff member. This applies whether the names are in the public domain or not. Copies of all correspondence are to be placed on Goldmine (linked to the company) and reviewed at next on-site audit activity and/or re-assessment. NSAI, during its next on-site audit activity, will check that the complaint has been adequately addressed. This includes:

6 PAGE 6 of 7 That the company has a complaints procedure. the complaint is on file and the procedure has been followed. the complaint has been adequately addressed and the correction and corrective actions are in hand. The auditor will report back to the Operations Manager, the outcome of the investigation, and any recommendations regarding further action. The Operations Manager will update the corrective action on Q-Pulse. A letter will be sent by the Operations Manager to the complainant advising them of the outcome of the investigation (as noted above) Where a Third Party is unhappy with NSAI s final response, the matter will be escalated to the Director of Certification or CEO, NSAI Inc.. The decision of the Director of Certification or CEO, NSAI Inc. is final. The correction is considered complete when the final letter is issued to the Third Party. 4.0 Communication to staff Complaints are reported to staff as part of the technical presentation at certification staff meetings.

7 PAGE 7 of 7 Revision Rev /11/05 Rev /11/05 Rev /01/06 Rev May 2006 Rev Sept. 06 Rev May 2007 Rev June 2007 Rev Aug 2007 Rev Nov Rev Dec. 07 Rev Jun 2008 Rev /11/08 Rev Jan. 09 Rev Feb. 09 Rev May 2009 Rev July 12 Details Last 5 revisions only Emphasis given to accreditation non-conformity closure process. Minor amendment to determination of closure of CAR Quality Committee deleted from item 2 Changed DQM reference. Added requirement for root cause analysis Added requirement for the relevant Manager to agree validity Changes for ISO Balance between openness and confidentiality Standard letters Terminology corrected as per UKAS audit finding Incorporating SCC document review comments Person responding to the complaint can not be involved directly with the complaint. Minor changes to Third Party complaint procedure Copies of complaint correspondence to be placed on Goldmine and physical file. Replace Client Services with Certification New logo Minor changes following internal audit Amendments to policy concerning 3 rd Part Complaints Re-drafted flow diagrams Auditee to agree closure targets for internal audit issues Staff training through communication at staff meetings Manager to confirm categorisation Changes made to escalation reporting Deleted Process Flow Charts; Updated procedure to take account of new organiazational structure; Updated to include references to Q-Pulse.