We are implementing ISO9001:2000 system, and were audited the day before yesterday, and we received a corrective action request. It says:
Statement of Non-conformance: The training process was not implemented effectively.
Requirement:6.2.2
Objective Evidence:
1. The competence of Industrial Engineer was not addressed.
2. The training needs were not identified for the engineer level except competence requirements in the job description, e.g. equipment engineer.

In my company, the Industrial Engineer manages the operators, but he doesn’t teach the operators how to operate a machine, or how to get work done, nor is he responsible for the product quality.
We identify the competences needed for a job, and add it onto the competence list. If the personal regulated by the competence list doesn’t meet the competence requirements, we, by corporate procedure, take measures to make them meet the requirements by training or offering them training materials. However, we indeed don’t have a definite training plan like when, where or how to train who or what per month or year.

My questions:
Do you think the Corrective action request is righteous? Why?
Can self learning be counted as training?
When I designed the system for the company, I thought the classroom type of training was unnecessary. So I just wrote “the managers should use suitable means to make the personal meet these competence requirements”.

Thanks in advance.

We are implementing ISO9001:2000 system, and were audited the day before yesterday, and we received a corrective action request. It says:
Statement of Non-conformance: The training process was not implemented effectively.
Requirement:6.2.2
Objective Evidence:
1. The competence of Industrial Engineer was not addressed.
2. The training needs were not identified for the engineer level except competence requirements in the job description, e.g. equipment engineer.

In my company, the Industrial Engineer manages the operators, but he doesn’t teach the operators how to operate a machine, or how to get work done, nor is he responsible for the product quality.
We identify the competences needed for a job, and add it onto the competence list. If the personal regulated by the competence list doesn’t meet the competence requirements, we, by corporate procedure, take measures to make them meet the requirements by training or offering them training materials. However, we indeed don’t have a definite training plan like when, where or how to train who or what per month or year.

My questions:
Do you think the Corrective action request is righteous? Why?
Can self learning be counted as training?
When I designed the system for the company, I thought the classroom type of training was unnecessary. So I just wrote “the managers should use suitable means to make the personal meet these competence requirements”.

Thanks in advance.I think the CAR is correct. You should identify what the Industrial Engineer is responsible for and how you determine the IE's competence. For example, the IE's supervisor might evaluate the IE's performance periodically. BTW, everybody is responsible for Quality. What responsibilites does the IE have? Does he design or set-up production processes? If so, your IE would certainly have an effect on quality.

I think the CAR is correct. You should identify what the Industrial Engineer is responsible for and how you determine the IE's competence. For example, the IE's supervisor might evaluate the IE's performance periodically. BTW, everybody is responsible for Quality. What responsibilites does the IE have? Does he design or set-up production processes? If so, your IE would certainly have an effect on quality.
In a wider sense, you are right, everybody is responsible for quality. But I take it that the standard’s statement work affecting product quality only means the works directly affecting product quality, like the operator’s. So I didn’t reckon other types of job, like purchaser’s, as work affecting product quality.
Limited to the Standard ISO9001:2000, did I take it wrong?
I know the job title IE sounds confusing, but IE in my company doesn’t design process. He is like a team leader, disciplining the operators, and telling them whose orders to follow. So by my previous understanding, IE’s could not be counted as work affecting product quality. Of course, in the wider sense, it could.
So what do the words “work affecting product quality” exactly mean?

In a wider sense, you are right, everybody is responsible for quality. But I take it that the standard’s statement work affecting product quality only means the works directly affecting product quality, like the operator’s. So I didn’t reckon other types of job, like purchaser’s, as work affecting product quality.
Limited to the Standard ISO9001:2000, did I take it wrong?
I know the job title IE sounds confusing, but IE in my company doesn’t design process. He is like a team leader, disciplining the operators, and telling them whose orders to follow. So by my previous understanding, IE’s could not be counted as work affecting product quality. Of course, in the wider sense, it could.
So what do the words “work affecting product quality” exactly mean?

It's not at all clear to me what the IE does for a living with regard to the operators. There are some ambiguities in the standard, but "work affecting product quality" doesn't seem to be one of them. Offhand, I would say that accounting clerks, janitors and receptionists, to name a few, don't do work that affects product quality, but it seems to me that the operators' supervisor certainly has that potential. Have you discussed this with the auditor? If you haven't, you should.

So I didn’t reckon other types of job, like purchaser’s, as work affecting product quality. If a purchasing agent mis-specifies the raw material being purchased, don't you think s/he is affecting product quality? In my estimation, your understanding of "work affecting product quality" is too narrow. Quality does not happen in the shop floor only.

If a purchasing agent mis-specifies the raw material being purchased, don't you think s/he is affecting product quality? In my estimation, your understanding of "work affecting product quality" is too narrow. Quality does not happen in the shop floor only.

I agree--the thing is supposed to be seen as a chain, not a series of disconnected events. That's what the process approach is all about. On the other hand, I think it is possible to extend it too far. The OP really needs to talk to his auditor and find out what it was about the IE that concerned him. I have a feeling that the auditor came across a disconnect, and it had to do with the fact that the IE's responsibilities were too ambiguously defined.

the thing is supposed to be seen as a chain, not a series of disconnected events. That's what the process approach is all about.

Thank you two. The above sentences are the most valuable.

Another issue that you should review is that the competencies listed in the job description are typically a set of minimum requirements that must be met at the point of hire. If you cannot identify a candidate that meets all of them, you identify the gap as training needs.

However, once all of these are met, you still have a requirement to identify training needs. This can be seen as continual improvement, or the job may be changing over time and the person must grow to keep up. Many times this training needs assessment is done as part of an annual performance review (though this is NOT a requirement). It might even be an informal process. However, if it is informal, you must be able to provide evidence that it is done in a consistent manner for all employees performing work that affects quality.

From a merely practical standpoint, I think the job title is immaterial to the listing of minimum competencies to perform the job and then establishing a periodic review to determine the job holder still has those competencies.

In my opinion, the training program for either a new candidate or an incumbent found to be lacking in the minimum competencies can be vague and certainly individualized, making the primary criterion for effectiveness of the training to be a "practical exam" demonstrating those competencies.

In other words, it is immaterial where and how the competencies are gained as long as the individual can demonstrate he/she possesses them!

...My questions:
Do you think the Corrective action request is righteous? Why?
Can self learning be counted as training?
When I designed the system for the company, I thought the classroom type of training was unnecessary. So I just wrote “the managers should use suitable means to make the personal meet these competence requirements”.

Thanks in advance.


1. Yes, I think the CAR is justified. The intent is that everyone in the company that matters should competent to perform their jobs. Competent would be that they have the needed skills as defined in your system for each position. The intent clearly is not limited to operators. Deming said that 85% of the failures are casued by the system (management). My audit experiences bears that out. We need to define and manage skills all the way up the org chart. Everyone needs to be competent.

2. Self-learning, outside study, mentoring, OJT, classroom...there are many ways to learn, and they all count. The end result is the focus - competent skills- not the method used to get there.

PS: I write this nonconformance very often.

The end result is the focus - competent skills

I agree.
I plan to add the IE competence on the list. Except the competence performing the job, the auditor also said something else, like management skills. He said that many engineers spent many years on a job and couldn’t figure out a whole picture of how the system is running, and was not adaptable. Do you think he meant something else beside competence?

Competence is a status of capability in more than a technical sense.

Many brilliant engineers, doctors, and other subject matter experts can still render their responsible processes ineffective through a less than optimum allocation of resources--both material and human.

If your engineer is not able to apply management methods such as the Theory of Constraints (see here http://www.nysscpa.org/cpajournal/1999/0499/Departments/D530499.HTM ) then arguably an inability to harness technical prowess into the output of his responsible processes is a practical meaning of incompetency.

This is a very common event. While line operators will have elegant training programs designed to manage their output through skill development, very often this is not done for engineers. Engineers who are very skilled in theory may bumble when performing their work according to the plan because the theory naturally varies among learners and the education sources.

So I encourage you to now only categorize the education and experience in all persons operating in your processes, but identify gaps they may have in being effective at applying their learning. Teamwork, problem solving using cause-and-effect, project planning and assessing results are, IMHO, essential elements of most any competency set and may help your engineer to better articulate his understanding of the system and appear more adaptable. I say articulate and appear because the auditor may have based remarks on what is seen. If your engineer possesses capability he didn't display to the auditor--perhaps by just not providing the answers or evidence needed to convince the auditor of competence--the verdict was delivered as a CA. I do not know your engineer but I do know that sometimes the problem is not incompetence, but underperformance.

I hope this helps!

I say articulate and appear because the auditor may have based remarks on what is seen. If your engineer possesses capability he didn't display to the auditor--perhaps by just not providing the answers or evidence needed to convince the auditor of competence--the verdict was delivered as a CA. I do not know your engineer but I do know that sometimes the problem is not incompetence, but underperformance.I wouldn't think a competent auditor would or should issue a finding based on one individual failing to show competence. It's not for the auditor to judge that. It's the auditors responsibility to evaluate the system, not the individual. There would have had to be more evidence.

I wouldn't think a competent auditor would or should issue a finding based on one individual failing to show competence. It's not for the auditor to judge that. It's the auditors responsibility to evaluate the system, not the individual. There would have had to be more evidence.Fair enough. I have only the IE story to go on, but I agree a good auditor would be able to discern a system gap given the evidence.

I wouldn't think a competent auditor would or should issue a finding based on one individual failing to show competence. It's not for the auditor to judge that. It's the auditors responsibility to evaluate the system, not the individual. There would have had to be more evidence.My guess is a COMPETENT auditor would not mark the individual, but would point out the SYSTEM has no way to evaluate the competence of the individual! If the system has a process in place, but it fails to catch the incompetent employee, I think that is beyond the scope of an auditor who would have to be judge and jury over the competence of every employee.

To Jennifer:
I think you did a pretty good job of explaining "how" an otherwise competent individual could fall short of the competence required for a particular position.

I think it is important to note the organization and its management have a duty

to create a process to identify the competencies needed for a particular position and then
to determine whether a candidate or incumbent possess those competencies necessary for the position and,
finally, to implement a process for helping the individuals get the competency (on or off site) or replace them with folks who CAN demonstrate such competency.These processes are what an auditor should be looking for.

The PETER PRINCIPLE is alive and well in many organizations only because there is no evaluation method to determine competency!

The PETER PRINCIPLE is alive and well in many organizations only because there is no evaluation method to determine competency!

I think there are as many cases where competency is not evaluated because it's not considered as relevant as experience (or is considered the equivalent of experience). Then there are the cases where incompetence is recognized, but nothing is done about it.

He stated that the company did not have a training plan stating the when, where or hows they train to meet competency. Even if the training is OJT, that needs to be stated somewhere and that training needs to documented.
Also, how can a person be responsible for operators and not have some knowledge of their processes, how can he point them in the right direction for guidance?
Just my 2 cents.

He stated that the company did not have a training plan stating the when, where or hows they train to meet competency. Even if the training is OJT, that needs to be stated somewhere and that training needs to documented.
Also, how can a person be responsible for operators and not have some knowledge of their processes, how can he point them in the right direction for guidance?
Just my 2 cents.Your :2cents: is worth a lot more.:agree1: