The quality of grievance procedures is potentially a major indicator for the degree of compliance with labor standards. If a grievance system is designed well in theory and works well in practice, it should catch significant abuse in every subject area of code standards.Measuring how close grievance procedures come to theoretical and practical success can therefore be extremely valuable.

Measurability issues 

Grievance procedures are relatively easy to measure in form. What is difficult is gauging how well they work in practice.Fear, distrust, or other factors that make workers unwilling to come forward are critically important, and they are as elusive to measure in the grievance context as they are for monitoring in general (see Monitoring discussion).Success is also easier to measure than failure, since the failure of workers to use a grievance procedure leaves no paper trail. 

Of course, the reality of grievance procedures in low-wage factories is much likelier to lie at the failure end of the spectrum, with measurement results showing the absence of key attributes rather than their presence.Measurement results showing ineffective (or non-existent) grievance procedures are much less useful as indicators of abuse than results showing effective grievance procedures are as indicators of compliance. 

Interpreting measurements of the frequency of use of grievance procedures is also difficult. Does a lack of grievances indicate a lack of abuses, or difficulties with using the grievance mechanism? Is a high volume of grievances a sign of health, or crisis? 

Current measurement practice is almost entirely in the form of yes/no determinations, reflecting a checklist approach to identifying key grievance procedure elements such as suggestion boxes and written records. 

Current strengths

Some key structural elements of grievance systems are well identified in current measurement practice, including the existence of written procedures for bringing grievances; ^[1] procedures for workers to monitor complaints; ^[2] the existence of an appeal mechanism for unfavorably resolved complaints ^[3] or disciplinary actions; ^[4] suggestion boxes ^[5] in private and secure locations; ^[6] telephone hotlines or post office boxes; ^[7] even the existence of outside legal help ^[8] or neutral assistance ^[9] for workers trying to use a grievance procedure.  

Whether thorough records are kept is also well-measured, ^[10] as is their transparency to the company placing orders in the factory. ^[11] Complete records are an essential predicate to any statistical analysis of grievances ^[12] and their disposition. ^[13]  

Whether workers have been trained to use grievance procedures is also measured, ^[14] although not in any depth except for suggestion boxes. ^[15]

Current weaknesses 

Confidentiality is a central concern, but measurement of the confidentiality of suggestion boxes, hotlines, appeals and the like is limited to question-begging inquiries ^[16] about whether such avenues are "confidential," ^[17] without any cross-check or indirect measurement unit (such as asking workers about instances where confidentiality was violated). 

Surprisingly, the coverage of grievance procedures is not well measured, except for the specific areas of abuse and harassment ^[18] and discrimination. ^[19] Making sure grievance procedures cover all potential areas of code violation would seem to be basic.But code-wide coverage is referred to only in the context of future improvement to code provisions. ^[20] Whether grievances can be raised for violations of every element of existing codes is a question that current practice does not explore. 

When it comes to actual worker use of grievance procedures, current measurement practice is strikingly weak, with only two measurement units even attempting to address use in practice on anything other than a statistical basis, and only one of them directly soliciting input from workers. ^[21]  

Best current practices (selected) 

·        Identifying whether grievance procedures are in place, and whether they include key confidentiality and appeal features (see Strengths above)

·        Checking whether workers have been sufficiently trained to use the procedures, ^[22] and whether suggestion boxes have clear, permanent instructions as reminders ^[23]

·        Undertaking statistical analysis of grievances where possible

·        Emphasizing the importance of complete record-keeping and making it available for inspection and analysis. ^[24]  

Possible improvements suggested by analysis  

1.      Attempt to correlate factory records of individual grievances with the first-hand account of the worker bringing the grievance, to check if records accurately reflect the actual handling and disposition of the grievance.

2.      Ask management to provide examples of successful resolution of legitimate grievances (i.e., where management admits the worker was in the right and the situation required correction). Then, if possible, interview both the worker who brought the grievance and the management personnel who processed it.

3.      Collect fuller qualitative information from workers about actual experience with and attitudes toward grievance procedures (including the confidentiality of the procedures, their workability, their likelihood of producing a successful outcome, any experience with successful outcomes obtained by others in the same workplace, etc.).

4.      Test workers in interviews to see if training in the use of grievance procedures has actually been absorbed.

5.      Establish whether grievance procedures cover all types of potential code violations, or only a subset.

6.      Attempt statistical evaluation of grievances where possible, looking for patterns that can lead to more refined measurements applicable in other locations (e.g., does a high volume of recorded grievances tend to reflect a responsive management; do patterns emerge of problem areas that are more and less susceptible to successful resolution via grievance, such as health and safety versus freedom of association; etc.).

7.      Apply automatic discounts to interview findings, and/or automatically add extra interview time and more stringent privacy and anti-retribution requirements to the monitoring process, whenever basic elements are lacking for a structurally adequate and functioning grievance system.