Chapter 3 – Intake and Initial Processing of Complaints

I. Scope

This Chapter explains the general process for receipt of discrimination (whistleblower) complaints under HRS § 396-8(e), screening and docketing of complaints, initial notification to Complainants and respondents, and recording the case data in OSHA’s OIS-Whistleblower. The procedures outlined in this chapter are designed to ensure that cases are efficiently evaluated to determine whether an investigation is appropriate; that HIOSH achieves a reasonable balance between accuracy in screening decisions and timeliness of screening; and to determine when it is appropriate to investigate complaints in which unlawful retaliation may have occurred.

II. Incoming Complaints

A. Flexible Filing Options

1. Who May File
   Any employee, former employee, or their authorized representative is permitted to file a whistleblower complaint with HIOSH. This applies to individuals seeking employment who have reason to believe that they have been subjected to blacklisting or discriminatory practices by their former employer, union, or any person with the capacity to engage in discriminatory conduct. Any allegations asserting that a prospective employer is engaging in discriminatory practices in contravention of HRS § 396-8(e) will be assessed on an individual basis. Such evaluations may involve consultation with the DAG.
2. How to File
   No particular form of complaint is required.
   HIOSH will accept the complaint in any language.
   A complaint may be filed orally or in writing.
   1. Written Complaints
      HIOSH accepts electronically-filed complaints on federal OSHA’s website at https://www.osha.gov/whistleblower/WBComplaint.html. HIOSH also accepts written complaints delivered by other means, such as through HIOSH’s email [email protected] or [email protected], or through U.S. mail.
      
      Complaints where the initial contact is in writing do not require the completion of an HIOSH- 87 form, as the written filing will constitute the complaint.
   2. Oral Complaints
      For oral complaints, when a complaint is received, the receiving officer must accurately record the pertinent information on an HIOSH-87 form or another appropriate intake worksheet and immediately forward it to the supervisor. Whenever possible, the minimum complaint information on the HIOSH-87 form or other appropriate intake worksheet should include for each Complainant and respondent: full name, mailing address, email address, and phone number; date of filing; and date of adverse action. In every instance, the date of the initial contact must be recorded. Although HRS § 396-8(e) states that complaints must be filed “in writing,” that requirement is satisfied by HIOSH’s practice of reducing all orally filed complaints to writing.

B. Receiving Complaints

All complaints received by the Whistleblower Unit must be logged in OIS-Whistleblower to ensure delivery and receipt by the investigative unit. Even those complaints that on their face are untimely or have been wrongly filed with HIOSH (e.g., a complaint alleging racial discrimination) must be logged. Also, materials indicating the date the complaint was filed must be retained for investigative use. Such materials include envelopes bearing postmarks or private carrier tracking information, emails, and fax cover sheets. Per government recordkeeping rules, electronically scanned copies of these documents are acceptable. Complaints are usually received at the field office level but may be referred by federal OSHA or other State of Hawaii government offices.

Upon receipt of a complaint, a diary sheet (which will become the Case Activity Log should the complaint be docketed) documenting all contact with Complainant must be initiated and maintained.

C. Complaints Forwarded by Other Agencies

When HIOSH receives a complaint alleging retaliation in violation of HRS § 396-8(e) that an employee originally filed with another agency (i.e., the other agency has sent HIOSH a referral rather than a courtesy notification), HIOSH must contact the employee to verify whether the employee wishes to pursue a retaliation complaint with HIOSH. In determining whether such a complaint is timely, HIOSH will first evaluate whether the other agency or HIOSH has received the complaint within the applicable filing period, which is 60 days from the adverse action for HRS § 396-8(e)¹.

If the other agency received the complaint within the applicable filing period but HIOSH did not (i.e., the complaint would be untimely based on the date HIOSH received it), HIOSH will consider whether the other agency that originally received the complaint has authority to provide personal remedies to the employee for the retaliation.

1. If the other agency cannot award personal remedies for the retaliation alleged in the complaint, HIOSH will regard the complaint as mistakenly filed in the wrong forum and, under equitable tolling principles, may regard the date of filing with the other agency as the date of filing.
2. If the other agency can award personal remedies to the employee for the retaliation alleged in the complaint, HIOSH will regard the complaint as untimely (unless there is some other basis for equitable tolling). HCRC and WSD are examples of agencies that in some circumstances may be able to provide personal remedies for unlawful retaliation alleged in a whistleblower complaint.

D. Complaint Requirements

The complaint, supplemented as appropriate with information obtained in the screening interview (described below) and any additional information, should ultimately contain the following:

1. Complainant’s name and contact information, and if applicable, name and contact information of Complainant’s representative. If represented, HIOSH should facilitate scheduling the interview with the representative rather than directly with Complainant unless the representative authorizes direct access to Complainant.
2. Respondents’ name(s) and contact information (if multiple Respondents, then all contact information should be present).
3. Worksite address (if different from employer address).
4. The current or final job Complainant performed for Respondent(s).
5. An allegation of retaliation for having engaged in activity that is at least potentially protected by the HIOSH whistleblower protection statute (i.e., a prima facie allegation). That is, the complaint, supplemented as appropriate by the screening interview and any additional information, should contain an allegation of:
   1. Some details that could constitute a protected activity or activities under the HIOSH whistleblower statute
   2. Some details indicating that the employer knew or suspected that Complainant engaged in the protected activity or activities;
   3. Some details indicating that an adverse action occurred and the date of the action; and
   4. Some details indicating that the adverse action was taken at least in part because of the protected activity or activities.

If any of the above information is missing after the screening interview (or after reasonable attempts (see Chapter 3.IV.A.2 below for guidance on reasonable attempts) to contact Complainant for a screening interview), HIOSH will preserve the filing date for timeliness purposes and inform Complainant that he/she/they needs to provide the missing information (HIOSH should be specific as to what is missing).

• If Complainant provides the missing information, HIOSH will either docket the complaint or administratively close the complaint if the Complainant agrees.
• If Complainant does not provide the missing information within a reasonable amount of time (usually 10 days)², HIOSH may administratively close the complaint. See Chapter 3.IV.A.2 below for the requirements to administratively close a complaint in these conditions.
• If Complainant resumes communication with HIOSH after a complaint has been administratively closed and indicates a desire to pursue the complaint, see Chapter 3.IV.A.2.c for instructions on how to proceed.

III. Screening Interview and Docketing Complaints

A. Overview

HIOSH is responsible for properly determining whether a complaint is appropriate for investigation. All complaints must be evaluated (“screened”) before they can be docketed.

Complaints will be docketed for investigation if the complaint (as supplemented by the screening interview and any additional information) complies with statutory time limits (including time limits as modified by equitable tolling), meets coverage requirements, and sufficiently sets forth all four elements of a prima facie allegation.

Complaints that are not filed within statutory time limits (including time limits as modified by equitable tolling), fail to meet coverage requirements, and/or do not adequately contain all four elements of a prima facie allegation will be administratively closed if Complainant agrees. If Complainant does not agree to administrative closure, the complaint closing letter will have notification of the right to object or request review. See Chapter 3.IV.A, Administrative Closures, below for more information.

Complainant need not explicitly state the statute(s) implicated by the complaint. HIOSH is responsible for properly determining the statute(s) under which a complaint is filed and make appropriate referrals to federal OSHA.

B. Complaint/Case Assignment

It is the supervisor’s responsibility to ensure that the complaint is timely, that HIOSH has coverage, and that the complaint is evaluated to determine whether all elements of a prima facie allegation are addressed.

The supervisor will approve the case for docketing and assign for investigation based on the needs of the division. It is recommended that one investigator handle the case from screening interview to closing conference. While the case assignment may happen before or after the screening interview, the case must be assigned to an investigator no later than the completion of the screening.

C. Initial Contact/Screening Interviews

As soon as possible upon receipt of the potential complaint, the available information should be reviewed for timeliness of filing, appropriate coverage requirements, and the presence of a prima facie allegation. HIOSH must contact Complainant to confirm the information stated in the complaint and, if needed, to conduct a screening interview to obtain additional information. Screening interviews will typically be conducted by phone, video conference, such as Microsoft Teams, or in person. Whenever possible, the evaluation of a complaint should be completed by the investigator whom the supervisor assigns, or anticipates assigning, to the case. If the investigator determines before or during the screening interview that the complaint is likely to be docketed, the investigator may conduct the more detailed Complainant interview at that time. See Chapter 4.IX, Complainant Interview and Contact, for more information.

The screening interview must be properly documented by either a memorandum of interview, a signed statement, a screening worksheet, or a recording. Recorded interviews must be documented in the file (e.g., noted in the phone/chronology log, or in a memo to file). If the screening interview is recorded, HIOSH personnel will advise Complainant that the interview is being recorded and document Complainant’s acknowledgement that the interview is being recorded.

D. Evaluating Whether a Prima Facie Allegation Exists and Other Threshold Issues

As noted above, the primary purpose of the screening interview is to ensure that (a) the complaint is timely, (b) the coverage requirements have been met, and (c) a prima facie allegation of unlawful retaliation exists. During the complaint screening process, it is important to confirm that the complaint was timely filed and that a prima facie allegation has been made under HRS § 396-8(e). Other threshold issues may also need to be verified depending on the circumstances. The following is a list of the threshold issues that most commonly arise when evaluating the sufficiency of a whistleblower complaint.

1. Coverage by HRS § 396-8(e)
   The investigator must ensure that Complainant and Respondent(s) are covered under HRS § 396-8(e). It may be necessary for the investigator to consult with the supervisor in order to identify and resolve issues pertaining to coverage. Occasionally, HIOSH needs further information from Respondent to verify coverage under HRS § 396-8(e). In these circumstances, HIOSH may docket a complaint based on Complainant’s allegation of coverage in order to obtain further information from Respondent.
2. Employment
   HRS § 396-8(e) requires that the entity employing Complainant be engaged in any trade, business, occupation, or work, including excavation, demolition, and construction work, or any process or operation in any way related, in which any person is engaged to work for hire except domestic services in or about a private home.
3. Timeliness of Filing
   Whistleblower complaints must be filed within the statutory timeframe of 60 days, which generally begins when the adverse action takes place. The first day of the time period is the day after the alleged retaliatory decision is both made and communicated to Complainant. Generally, the date of the postmark, facsimile transmittal, email communication, online complaint, telephone call, hand-delivery, delivery to a third-party commercial carrier, or in-person filing at the HIOSH office will be considered the date of filing. If the postmark is absent or illegible, the date filed is the date the complaint is received. If the last day of the statutory filing period falls on a weekend or a state or federal holiday, or if the HIOSH office is closed, then the next business day will count as the final day.
4. Tolling (Extending) the Complaint Filing Deadline
   The following is a non-exclusive list of reasons that may justify the tolling (extending) of the complaint filing deadline, and an investigation must ordinarily be conducted if evidence establishes that a late filing was due to any of them. Tolling suspends the running of the filing period and allows days during which Complainant was unable to file a complaint to be added to the regular filing period. If in doubt, the investigator should consult with the SI, OH Branch Manager, or the Administrator. Refer to HAR §12-57-8(d)(2) for circumstances which would justify tolling.
   1. The employer has actively concealed or misled the employee regarding the existence of the adverse action or the retaliatory grounds for the adverse action. Examples of concealed adverse actions would be:
      • After the employee engaged in protected activity, the employer placed a note in the personnel file that will negate the employee’s eligibility for promotion but never informed the employee of the notation; and
      • The employer purports to lay off a group of employees, but immediately rehires all of the employees who did not engage in protected activity.
        Mere misrepresentation about the reason for the adverse action is insufficient for tolling.
   2. The employee is unable to file due to a debilitating illness or injury which occurred within the filing period.
   3. The employee is unable to file due to a natural or man-made disaster such as a major storm or flood, which occurred during the filing period. Conditions should be such that a reasonable person, under the same circumstances, would not have been able to communicate with HIOSH within the filing period.
   4. The employee mistakenly filed a timely retaliation complaint with another agency that does not have the authority to grant individual relief (e.g., filing a HIOSH retaliation complaint with the Department of Health).
   5. The employer’s own acts or omissions have lulled the employee into foregoing prompt attempts to vindicate their rights. For example, tolling may be appropriate when an employer repeatedly assured the Complainant that they would be reinstated so that the Complainant reasonably believed they would be restored to their former position. However, the mere fact that settlement negotiations were ongoing between the Complainant and the respondent is not sufficient. Hyman v. KD Resources, ARB No. 09-076, ALJ No. 2009-SOX-20 (ARB Mar. 31, 2010).
   6. HIOSH will recognize private agreements between the employer and employee that expressly toll (extend) the filing deadline. The agreement must be (a) in writing, (b) operate to actually extend the deadline to file a whistleblower complaint, and (c) reflect the mutual assent of both parties. The agreement will only toll the limitations period with respect to the parties that are actually covered by the agreement.
   7. Conditions which do not justify extension of the filing period include:
      1. Ignorance of the statutory filing period.
      2. Filing of unemployment compensation claims.
      3. Filing a workers’ compensation claim.
      4. Filing a private lawsuit.
      5. Filing a grievance or arbitration action.
      6. Filing a retaliation complaint with another agency that has the authority to grant the requested relief.

IV. Initial Complaint Results

Following the screening interview (or reasonable attempts to conduct one), complaints that do not meet threshold requirements (i.e., do not contain a prima facie allegation or fail for some other threshold reason such as untimeliness or lack of coverage) will be either administratively closed (if the Complainant agrees) or docketed and dismissed. Other potential results after initial intake and screening are also discussed further below.

A. Administrative Closures (AC)

1. Administrative Closures with Complainant’s Agreement
   Complaints that do not meet the threshold requirements following a screening interview will be administratively closed provided that Complainant agrees. The supervisor must also agree, and that agreement must be documented in the case file. If a supervisor has conducted the screening, no further supervisory review is necessary. When a complaint is administratively closed in these circumstances, the following must be completed by the investigator:
   1. Obtain Complainant’s agreement: The investigator will notify Complainant, verbally or in writing, that the complaint does not meet threshold requirements for investigation and that, if Complainant agrees, HIOSH will administratively close the case. The notification can be done as part of a screening interview and should include:
      1. A brief explanation of the reason(s) the complaint cannot be investigated and the opportunity for the Complainant to provide any pertinent information that might lead HIOSH to docket the case;
      2. An explanation that if the case is administratively closed, the complaint will not be forwarded to Respondent and Complainant will not have the opportunity to object to or request review of HIOSH’s decision; and
      3. An explanation that if Complainant does not agree to allow HIOSH to administratively close the case, HIOSH will inform the Complainant of their rights to object or request an informal review of HIOSH’s decision. Complainant will also be informed that Respondent will be notified of the complaint if it is docketed and dismissed.
   2. Send Complainant confirmation of the administrative closure or dismissal of the complaint and document the administrative closure in the case file:
      1. If Complainant agrees, HIOSH will send (email or mail, delivery confirmation required) an administrative closure letter to Complainant, stating that Complainant has agreed to the administrative closure.
      2. If Complainant disagrees with the administrative closure, HIOSH will proceed with its informal review process described below.
      3. If Complainant changes their mind after initially agreeing to the administrative closure of the case and contacts HIOSH within a reasonable amount of time (usually 10 days), HIOSH should reopen the case and forward the complaint to the Administrator for an informal review unless Complainant provides information that would allow HIOSH to docket the case for investigation.
   3. Administratively closed complaints will not be forwarded to the named respondent.

B. Informal Review

If the Complainant objects to HIOSH’s determination to administratively close the whistleblower complaint, the case may be referred to the Administrator for an informal review in accordance with HAR §12-51-12. The Complainant may request such a review by submitting a written statement of position to the Administrator. Upon the Complainant’s request, the Administrator may convene a redetermination hearing or meeting, during which the Complainant may present their views orally. After evaluating all written and oral submissions, the Administrator will decide whether to affirm or reverse the initial determination not to proceed with an investigation and will notify the Complainant of the decision and the reasons therefor

Should the Administrator conclude that an investigation is warranted, the case will be formally docketed and investigated. Conversely, if the Administrator determines that an investigation is not appropriate and the Complainant continues to contest this decision, the case will be docketed and subsequently dismissed.

Notification letters will be sent to the Respondent, informing them that a determination has been made not to conduct an investigation. The letter will also notify the Respondent that the Complainant intends to appeal this determination to the HLRB.

The authority for such a review is provided under HAR §12-51-11.

“The complaining party may obtain review of the determination by submitting a written statement of position with the Director. Upon the request of the complaining party, the Director may hold a redetermining hearing in which the complaining party may orally present his views. After considering all written and oral views presented, the Director shall affirm or reverse the prior determination not to conduct an inspection or investigation and inform the complaining party of the decision and reasons.”

C. Unavailable/Unresponsive Complainant

If Complainant does not respond to HIOSH’s reasonable attempts to conduct a screening interview or obtain information needed to docket the complaint, HIOSH may administratively close the complaint.

1. Reasonable Attempts to Contact Complainant
   HIOSH will attempt to contact Complainant through more than one method of communication (e.g., telephone and email), if Complainant has provided more than one form of contact information and allowing Complainant 48 hours to respond. In the case of phone calls, at least two attempts should be made at different hours of the day during allowed work-band hours. HIOSH’s attempts to contact Complainant must be documented in the case file.
2. Notification to Complainant After HIOSH attempts
   HIOSH will inform the Complainant that it has administratively closed the complaint and that if Complainant wishes to pursue the complaint, Complainant should contact HIOSH within 10 days or before the filing period ends, whichever is later. Where possible, this notification should be done in writing and sent by methods that allow HIOSH to confirm delivery. The notification will specify direct contact information for the HIOSH Office or the investigator including: mailing address, telephone number, and email.
3. Response From Complainant
   If Complainant contacts HIOSH and indicates a desire to pursue the complaint, HIOSH will reopen the case, complete the screening interview, and either docket the case or seek Complainant’s concurrence with administratively closing the case if it does not meet the necessary threshold requirements.
   1. If Complainant contacts the investigator within 10 days, the original filing date will normally be used.
   2. If Complainant contacts the investigator after 10 days, but still within the statutory filing period, the date of Complainant’s new response may be used as the filing date.
   3. If Complainant contacts the investigator after 10 days and the statutory filing period has ended, the investigator will, in the screening interview, determine if (1) Complainant received the letter, and (2) if circumstances exist that could excuse the Complainant’s failure to pursue their case in a timely manner. The investigator shall then consult with the SI, the OH Branch Manager, and DAG, as appropriate, to determine whether the complaint should be reopened or if the complaint should remain closed due to Complainant’s failure to pursue their case in a timely manner. This determination is fact-specific to each complaint. The original filing date must be used.

D. Documenting Administrative Closures in OIS-Whistleblower

As noted above, the decision to administratively close a complaint and communications with Complainant related to administratively closing a complaint must be appropriately documented on the case activity log. The investigator must:

1. Appropriately enter the administrative closure in OIS-Whistleblower.
2. Preserve, in the same manner as investigation case files and in accordance with the current agency records retention schedule, a copy of the administrative closure letter and the complaint, along with any other related documents such as emails and interview statements/recordings. Typical documents to be included in the screening file record are:
   1. The complaint;
   2. Complaint assignment memo or email;
   3. All internal and external emails and other correspondence;
   4. Documentation of contacts/attempted contacts with Complainant (e.g., case activity log) and supervisor’s approval of actions taken;
   5. Complainant interview (e.g., recording, statement, or memo to file);
   6. Administrative closure letter to Complainant; and
   7. OIS -Whistleblower Summary page.

E. Withdrawal Before Docketing or before Notification Letters are Issued

When Complainant elects not to pursue their complaint before docketing or before HIOSH issues notification letters, the investigator will document Complainant’s withdrawal request in the case file and administratively close the complaint. Follow administrative closure procedures beginning at Chapter 3.IV.A.1.a above. The administrative closure letter will indicate Complainant did not wish to pursue the case.

V. Docketing

The term “to docket” means to open a case for an investigation, document the case as an open investigation in OIS Whistleblower, assign a local case number, and formally notify both parties in writing of HIOSH’s receipt of the complaint and intent to investigate.

The appropriate case file identification format for electronic case files is “Local Case Number[space]Respondent[space]-[space]Complainant.”³ The appropriate case identification in correspondence is “Respondent/Complainant/Local Case Number.”

OIS -Whistleblower automatically designates the case number when a new complaint is entered into the system. However, cases that are docketed and assigned for investigation must be given a local case number, which uniquely identifies the case. Local case numbers shall follow the format 11-222, where each series of numbers designates the following:

• The fiscal year and
• The serial number of the complaint for the fiscal year

Cases involving multiple Complainants will be docketed under separate case numbers.

Cases involving multiple respondents will ordinarily be docketed under one case number, unless the allegations are so different that they must be investigated separately.

VI. Named Respondents

All relevant employers should be named as Respondents in all docketed cases unless Complainant refuses. This includes contractors, subcontractors, host employers, and relevant staffing agencies, as well as individual company officials as discussed below. Failing to name a Respondent may create confusion regarding whether Complainant has properly exhausted administrative remedies which could impede future settlement of the case, impede relevant interviews, or unnecessarily delay or prevent Complainant from obtaining reinstatement and other remedies. For more information on temporary workers and host employers, see Memorandum, Clarification of Guidance for Section 11(c) Cases Involving Temporary Workers, issued May 11, 2016 and OSHA’s Protecting Temporary Workers webpage for further information.

An individual company official who carries out the retaliatory adverse action may be liable if they have the authority to hire, transfer, promote, reprimand, or discharge Complainant. Anderson v. Timex Logistics, 2014 WL 1758319 (ARB 2014).

VII. Notification Letters

A. Complainant

As part of the requisite docketing procedures when a case is opened for investigation, a notification letter will be sent to inform the Complainant of the case number and the assigned investigator. The contact information of the investigator will be included in the docketing letter. The letter will also request that the parties provide each other with a copy of all submissions they make to HIOSH related to the complaint. The letter packet will include at minimum:

• A copy of the whistleblower complaint supplemented as appropriate by a summary of allegations added during the screening interview.
• A Designation of Representative Form to allow the Complainant the option of designating an attorney or other official representative.

B. Respondent

At the time of docketing, or as soon as appropriate if an inspection is pending, a notification letter will be sent notifying the Respondent(s) that a complaint alleging unlawful retaliation (discrimination) has been filed by Complainant and requesting that Respondent submit a written position statement. Failure to promptly forward the respondent letter could adversely impact the respondent’s due process rights and the timely completion of the investigation
The letter will notify the Respondent(s) to retain and maintain all records, documents, email, correspondence, memoranda, reports, notes, video, and all other evidence relating to the case.
The letter will also request that the parties provide each other with a copy of all submissions they make to HIOSH related to the complaint. The letter packet will include at minimum:

• A copy of the whistleblower complaint redacted as appropriate and supplemented as appropriate by a summary of allegations added during the screening interview.
• A Designation of Representative Form to allow the Respondent the option of designating an attorney or other official representative.

Respondent will be notified using a method that permits HIOSH to confirm receipt. This includes but is not limited to: email or certified U.S. mail, delivery confirmation required, or hand delivery. Proof of receipt must be preserved in the file with copies of the letters to maintain accountability.

Prior to sending the notification letter, the supervisor should determine whether it appears from the complaint and/or the initial contact with Complainant that an inspection may be pending with the OH or OS Branches. If it appears that an inspection may be pending, the supervisor or investigator should contact the appropriate branch to inquire about the status of the inspection. If a delay is requested, then the notification letter should not be issued until such inspection has commenced in order to avoid giving advance notice of a potential inspection.

VIII. Early Resolution

HIOSH will work to accommodate an early resolution of complaints in which both parties seek resolution prior to the completion of the investigation. Consequently, the investigator is encouraged to contact Respondent soon after completing the intake interview and docketing the complaint if they believe an early resolution may be possible. However, the investigator must first determine whether a safety/health inspection is pending. The investigator must wait until the commencement of the safety and health inspection before contacting Respondent.

IX. Case Transfer

Careful planning must be exercised in the docketing of cases to avoid the need to transfer case responsibility from one investigator to another. However, if caseload or case priority considerations warrant the transfer of a case, any such transfer must be documented in the case file and OIS -Whistleblower.

The SI may consult with the OH Branch Manager when it is necessary to reassign cases among investigators under their supervision due to staffing issues.

---

1. HAR § 12-57-8(d)(3) states that filing with another agency is a circumstance that “do[es] not justify tolling the 60-day period.” Nowhere in HAR § 12-57-8(d)(3), or any other subsection of HAR § 12-57-8, is HIOSH prohibited from tolling the 60-day deadline if it deems it justified. See Henkels & McCoy, Inc. v. DLIR and W. Olive, Case No. OSH 2019-05, Decision No. 40 (DLIR). ↩︎
2. In some circumstances, a reasonable period of time may be more than 10 days; for instance, if medical issues prevented Complainant from responding to HIOSH’s inquiry within 10 days ↩︎
3. See OSHA Instruction CPL 02-03-009, Electronic Case File System Procedures for the Whistleblower Protection Program, June 18, 2020, for more information. ↩︎