It's true that we do have more latitude. We do have more discretionary authority. We have the authority to simply not even entertain a complaint. We can dismiss it right away, but we don't. We provide a response to every complaint.
We do receive a fair amount of these types of grievances from a few multiple grievers, but for us they are very easily dealt with. It's not that difficult to entertain If it's frivolous and vexatious and it's made in bad faith, we provide the answers right away. The only difference the service has is that under the regulation if the offender is not happy with whatever response they get, they can then raise it to the next level, and then raise it all the way up to the commissioner's level.
In terms of actual work for the service, it's the same. They simply have to rubber stamp the decision made initially that the complaint is groundless. That doesn't take much work. They have to get the paper up the chain, but it's not very administratively cumbersome. I would say that's the only difference.
For us what is more important is to make sure that, at the institutional level, everything is in place to deal with those legitimate grievances in a fair and appropriate and timely way. All your energy, just like Professor Mullan said, should be focused at the institution. With the assistance of mediators, grievance coordinators, and grievance clerks, as well as inmate committees and outside review boards, the service has everything it needs to achieve a much higher level of resolution at the institutional level.