United States Department of Agriculture
Agricultural Marketing Service
Fruit and Vegetable Programs

Fresh Products Branch Directive

FPB 703
08/04/08

I. Purpose

Il. Background

Ill. Definitions

IV. Policy

Fresh Products Branch Good Agricultural Practices and Good Handling
Practices (GAP&GHP) Audit Appeals, Complaints and Dispute
Procedures

To outline the management requirements of the Fresh Products Branch (FPB) appeals,
complaints and dispute procedures for GAP&GHP audit programs.

The AMS Industry Services Audit and Accreditation Programs (ISSAP) committee
developed guidance documents for Audit Management Program procedures for AMS
Branches that provide audit services. AMS Branch Audit Management Program
(AMS 2) Section 7 outlines AMS Branch requirements to address appeals, complaints
and disputes brought before the Branch by applicants or other parties.

Appeal: A formal complaint contesting the results or findings of the audit brought
before the Branch by applicants or other parties.

Complaints: Discontent or unhappiness about a situation, interpretation or
performance of an audit, auditor(s) and/or policy brought before the Branch by
applicants or other parties.

Dispute: Disagreement or argument about a situation, interpretation or performance
of an audit, auditor(s) and/or policy brought before the Branch by applicants or other
Parties.

Audit Review Board: The Audit Review Board (ARB) shall consist of a minimum of
3 members as designated by the Branch Chief. Members must be FPB headquarters
staff (including Federal Program Managers) that is an Audit Program evaluator in
good standing.

1. Application for Appeals

An appeal may only be requested by the original applicant and/or auditee. A
formal request for an appeal must be in writing on company letterhead from
the company or person requesting the appeal. The request shall include all
necessary information including the date, location, and scopes addressed on
the original audit being appealed, and the specific item(s) under dispute for
the appeal request. Appeals must be submitted to ARB within 3 calendar
days from the date the audit was performed.

Distribution: FM, FPM, HQ, SPM, OIC
Originating Office: Field Operations Section
File Maintenance Instructions: File in Directive Binder


FPB 703
Page 2
07/02/08

Policy, Continued

o

2. Performance of Appeals

GAP&GHP audit appeals shall be performed by the ARB. The ARB will
meet as needed to review all GAP&GHP audit appeals.

The ARB shall have the authority to sustain or reverse audits that are under
appeal. The results of the appeal will be provided by the ARB to all parties in
the appeal process within 14 calendar days of receipt of the request. A copy
of the appeal results shall be made part of the audit record.

2. Complaints and Disputes

It is the responsibility of all licensed auditors to forward all complaints and
disputes through the normal channels to the ARB for review. All complaints
and disputes regarding GAP&GHP audits, auditor(s) and/or polices brought
before the Branch by applicants or other parties shall be reviewed by the
ARB.

3. Documentation
The Branch shall keep a record of all appeals, complaints, disputes and
subsequent actions taken relative to GAP&GHP audits. Review and

evaluation of effectiveness of all appeals, complaints, disputes and
subsequent actions shall be performed on a regular basis.

Branch Chief