I would urge those involved in this effort to refrain from using terms such as "illegal" or similar variations. Instead, you would likely be better served by sticking with phrases such as, "failure to follow written PTO procedures", "not in accord with PTO guidelines", or to substitute similar key words such as "protocols" or "practices"

Couldn't "failure to follow" be considered an "infraction" ?

If you agree, then where is the problem with using the term "illegal" in the full context of the statement? (note bolded):

When no new SNQs exist and the examiner has been properly advised of same (16 weeks ago), then the examiner's continuing inaction to correct the situation only creates suspicions of inappropriate and possibly illegal behavior

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Be well