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View Full Version : Missing Information in Training Records - Is it a Major Nonconformance?


KWalls
15th January 2008, 07:38 PM
Just wanted to report in real quick... the "official" results are not in yet, but unofficially we only recieved 1 major - for missing some info in the training records of our employees. And the good new is, we get to fix it before he comes back in a few weeks!! Other than that, our non-robot auditor is very pleased with our system. And I have to say, I did ask questions which he answered in a general manner or broadly speaking. Nice to know that I don't have to be afraid to ask questions. And after all the worrying I did about internal auditing (or my lack of knowledge of internal auditing) turned out to be complete OVERKILL because I audited EVERYTHING under the sun here. He said that it was almost "too thorough". Guess that's a good thing? THANK YOU to all of you who have helped me through this process. I seriously couldn't have done it without YOU or the Cove.

Doug Tropf
16th January 2008, 09:19 AM
Nice job Kyle, I imagine most of us get a case of the nerves prior to major audits. Hope the audit results lead to a raise for you.

Paul Simpson
16th January 2008, 09:32 AM
Just wanted to report in real quick... the "official" results are not in yet, but unofficially we only recieved 1 major - for missing some info in the training records of our employees. And the good new is, we get to fix it before he comes back in a few weeks!! :confused: Sorry, I am sure it is just general stupidity on my part but I thought you posted:
The auditor raised a major because a few training records weren't complete - doesn't sound like a major to me! Perhaps there is something else you can post here so we can give our cove "verdict"
You get another visit to clear the "Major." I presume you are paying extra for this?

CliffK
16th January 2008, 09:56 AM
Just wanted to report in real quick... the "official" results are not in yet, but unofficially we only recieved 1 major - for missing some info in the training records of our employees. And the good new is, we get to fix it before he comes back in a few weeks!! Other than that, our non-robot auditor is very pleased with our system.
Congratulations. Glad you had a good experience.

Getting a major for missing information in training records seems a bit much. Can you provide more information (maybe start a new thread) about the finding?

There's nothing wrong with suggesting that the auditor or CB reconsider the severity of a finding. I think your fellow Covers might be able to give you some advice, if you are interested.

Stijloor
16th January 2008, 10:03 AM
Just wanted to report in real quick... the "official" results are not in yet, but unofficially we only recieved 1 major - for missing some info in the training records of our employees. And the good new is, we get to fix it before he comes back in a few weeks!! Other than that, our non-robot auditor is very pleased with our system. And I have to say, I did ask questions which he answered in a general manner or broadly speaking. Nice to know that I don't have to be afraid to ask questions. And after all the worrying I did about internal auditing (or my lack of knowledge of internal auditing) turned out to be complete OVERKILL because I audited EVERYTHING under the sun here. He said that it was almost "too thorough". Guess that's a good thing? THANK YOU to all of you who have helped me through this process. I seriously couldn't have done it without YOU or the Cove.

KWalls,

For a nonconformity to be major, it has to be a failure of (in this case) the training process. Are you sure it is a major? Was this issue discussed during the closing meeting? Just curious. Some information missing in training records would be a minor, if at all....

Stijloor.

BradM
16th January 2008, 11:27 AM
All, this thread has been moved from the tips/ideas for auditors. I think it is a very worthwhile discussion for the OP (and all of us). I hope no one objects.

KWalls
16th January 2008, 11:53 AM
Just to clarify for you guys... yesterday was Readiness Review for us. So it wasn't the "real deal" but gave us a good idea at where we stood. But here is the reason behind the "finding"... He said that the training grandfathering statement had to show which departments they were grandfathered in for... ex: Our shop foreman would be grandfathered in for Manufacturing and Quality Control. Whereas right now is just states on their record that they are free from any type of training because they have helped create the system. Does that make sense?

Other than that he said there is no reason we shouldn't pass our certification audit on the 4th and 5th of February (1 & 1/2 days) and that he's been to a lot of small businesses to audit/register them and we are the most ready he's ever seen.

michellemmm
16th January 2008, 11:53 AM
:confused: Sorry, I am sure it is just general stupidity on my part but I thought you posted:

The auditor raised a major because a few training records weren't complete - doesn't sound like a major to me! Perhaps there is something else you can post here so we can give our cove "verdict"
You get another visit to clear the "Major." I presume you are paying extra for this?

I had the same reaction when I read her post... Not Fair!!! :nope:

I guess it all depends on the auditor...Is s/he going to audit the letter of quality or the spirit of quality...If an auditor wants to find fault or nonconformity, s/he can!!! No system is perfect...

S/he starts with a minor and follows the process through (audit trail) and shows the breakdown in the system from management commitment to customer satisfaction and build a case....

During my last audit, my client manager asked one of my SMT operator (new hire):
What problems do you have with the machine?
What have you done to improve the equipment?
Have you worked with better equipment?
Have you proposed getting better equipment?
etc...

My heart stopped....I could not breathe...
My client manager could have given several majors...But...He was not on a fault finding mission....He was looking for effective implementation.

Jim Wynne
16th January 2008, 12:07 PM
There are two ways to look at this. The first way is to say, whatever it's called in this situation--major or minor--it'll get fixed and people will move on with their lives. On the other hand, it's important to establish the ground rules early on and make sure that the auditor understands what it takes to characterize a given finding as "major." Unless there's evidence of a systemic failure--a required process either doesn't exist or is demonstrably ineffective--there is no major nonconformance, and it shouldn't be accepted as such.

AndyN
16th January 2008, 12:27 PM
He said that it was almost "too thorough".

Kyle:

Good job on being prepared! But this kind of comment from a CB auditor is really too much. Not his call............:rolleyes:

And, there's no way what you described is a major! I'm not an advocate of Grandfathering anyone into a job, don't care how long they've been doing it. As a manager I want to know they're competent, and grey hair doesn't do that for anyone...........
That said, his idea of what is required is off.

Paul Simpson
16th January 2008, 01:11 PM
Just to clarify for you guys... yesterday was Readiness Review for us. So it wasn't the "real deal" but gave us a good idea at where we stood. But here is the reason behind the "finding"... He said that the training grandfathering statement had to show which departments they were grandfathered in for... ex: Our shop foreman would be grandfathered in for Manufacturing and Quality Control. Whereas right now is just states on their record that they are free from any type of training because they have helped create the system. Does that make sense?Makes a lot of sense now! Operating within a QMS an individual can only be "grandfathered" in an area they've worked in - logically. If I were fixing this I would also record who had decided they are competent - ideally their boss!

Other than that he said there is no reason we shouldn't pass our certification audit on the 4th and 5th of February (1 & 1/2 days) and that he's been to a lot of small businesses to audit/register them and we are the most ready he's ever seen.Good for you! As the 1st audit was a stage 1 I won't quibble about the definition of "major" but, as Jim said, it is important to know where everyone stands.

Otherwise you find Majors slipping under the wire and opinions being recorded as fact! :bonk:

KWalls
16th January 2008, 01:17 PM
The draft report was just emailed to me... so here's an update. He didn't log any as majors/minors. Just verbals - a "fix it" ticket, if you will. And the items that he would like fixed are simple.

1. Complete Training Records (like I was saying... the "Grandfathering" thing.)
2. Missing step for procedure accepting purchase orders and contract review. (stamping and date PO indicating review.)

So we are on a mission this week to get them completed.

Your feedback is appreciated!!

KWalls
16th January 2008, 01:20 PM
Makes a lot of sense now! Operating within a QMS an individual can only be "grandfathered" in an area they've worked in - logically. If I were fixing this I would also record who had decided they are competent - ideally their boss!


YES! That's exactly the point he was trying to make. Thanks for the tip, Paul! I will make certain this happens. Just more evidence that proves their competency. :bonk:

CliffK
16th January 2008, 01:31 PM
Just to clarify for you guys... yesterday was Readiness Review for us. So it wasn't the "real deal" but gave us a good idea at where we stood. But here is the reason behind the "finding"... He said that the training grandfathering statement had to show which departments they were grandfathered in for... ex: Our shop foreman would be grandfathered in for Manufacturing and Quality Control. Whereas right now is just states on their record that they are free from any type of training because they have helped create the system. Does that make sense?


Ah, this was a pre-certification. That makes the major/minor thing a little less important. Still, Jim makes a very good point about needing a clear definition of a major nonconformity. The definition he cites is the common one.

There is a monetary difference between a major and minor, though. For a major, the auditor makes a return trip to verify implementation and effectiveness of the corrective action. Guess who pays for the trip.:(

Caster
16th January 2008, 10:30 PM
Re: Grand daddy

A little off topic but the good old grandddy clause alwys gets a quick stink test from me.

If the person wrote their procedures, has been in the job for a while, and can generally explain what they are doing, I'm OK with it. It doesn't take long to find out.

If everyone is grandfathered to avoid having to do any training, the audit heads down a different path. Also doesn't take very long to find out.

Have you thought about 3 years from now? Does your grandpappy clause expire? Will you re assess competence as time moves on?

Five years from now if you have people with no training re assessment because they were grand fathered back in the day, I would really question it.

Good luck on the assessment.

Helmut Jilling
17th January 2008, 12:24 AM
Congratulations. Glad you had a good experience.

Getting a major for missing information in training records seems a bit much. Can you provide more information (maybe start a new thread) about the finding?

There's nothing wrong with suggesting that the auditor or CB reconsider the severity of a finding. I think your fellow Covers might be able to give you some advice, if you are interested.


There are several things to consider:

1. Missing a "few records" probably would not be a major. However, not having records of training because everyone is "grandfathered" would not be a "few missing records." So, we would have to see the extent of what is missing. A lot cold be a major in an audit.

2. Can someone show me where the standard or the related supporting documents discusses the "rules" for grandfathering? I read a lot of comments and rules in this thread for what is allowed, or not allowed, when grandfathering, when it is not even mentioned in the standard. :confused:

3. However, I do agree that the grandfathering concept makes sense, but we have to look at the actual requirements. Training records are not required except when there was training given. If someone has had the job for a long while, and does not need training, then obviously there may not be any "training records." However, it is required to evaluate competence and maintain records of the evaluation. That part can't be "grandfathered" away. It is key to the whole clause 6.2.

Paul Simpson
17th January 2008, 05:24 AM
2. Can someone show me where the standard or the related supporting documents discusses the "rules" for grandfathering? I read a lot of comments and rules in this thread for what is allowed, or not allowed, when grandfathering, when it is not even mentioned in the standard. :confused:The standard doesn't even require training! The purpose of the whole clause is that people are competent in their jobs.

Grandfathering is one way for organizations to demonstrate that personnel have been assessed as being competent in their jobs (and therefore not needing training).

As Caster said it needs a check to make sure it is not an excuse for not training!

Helmut Jilling
17th January 2008, 06:06 AM
The standard doesn't even require training! The purpose of the whole clause is that people are competent in their jobs.

Grandfathering is one way for organizations to demonstrate that personnel have been assessed as being competent in their jobs (and therefore not needing training).

As Caster said it needs a check to make sure it is not an excuse for not training!


I assume you noticed my intended humor on point #2...

My point was grandfathering is superimposed on the standard. It is not a part of it. It is not a way to demonstrate assessment of competence. It is a way to avoid unnecessary training, because someone supposedly already knows the job, based on their doing it a long time. But it based on an assumption of competence, and in fact that has to be evaluated. I agree the standard would allow no additional training (grandfathering), but only because an evaluation has been made and verified competence.

I ran into that just last night, where the offshift QA technicians were presumed to be competent, and in fact, we found some fundamental gaps in their skills.

The best way to make that evaluation of competence is against the skills list that the organization has identified.

Paul Simpson
17th January 2008, 07:14 AM
I assume you noticed my intended humor on point #2... Nope, went straight by. You might find you need to be a bit less subtle with me!

:lol: always works!

:lol:

My point was grandfathering is superimposed on the standard. It is not a part of it. It is not a way to demonstrate assessment of competence. No, this is precisely the point. The standard doesn't say anything about how an organization must meet any of its requirements - that is what the cove is for! :D

Grandfathering is a statement of having assessed the individual's competence.

If s / he had not been doing the job right over the last 300 years we would have fired them!
It is a way to avoid unnecessary training, because someone supposedly already knows the job, based on their doing it a long time. But it based on an assumption of competence, and in fact that has to be evaluated. I agree the standard would allow no additional training (grandfathering), but only because an evaluation has been made and verified competence.Thanks for the emphasis. :sarcasm:

By "grandfathering" an employee as competent their boss (as per my original post) is saying they have evaluated an employee's performance in the job over time and finds it to be satisfactory.

The boss might be lying to get over having to do some training but that is what the audits (both internal and external) are there to discover.

I ran into that just last night, where the offshift QA technicians were presumed to be competent, and in fact, we found some fundamental gaps in their skills.The best way to make that evaluation of competence is against the skills list that the organization has identified. Assuming the organization has a "skills list." There are many ways of demonstrating competence and that is just one of them.

JaneB
18th January 2008, 10:31 PM
The standard doesn't say anything about how an organization must meet any of its requirements - that is what the cove is for! :D

Well said. :applause: :lol:



PS - dunno why the posting subject line has gone astray... probably them cyber gremlines in the works again :-)

Stijloor
19th January 2008, 02:17 PM
Well said. :applause: :lol:

PS - dunno why the posting subject line has gone astray... probably them cyber gremlines in the works again :-)

Great observation Jane!

Can the Moderators fix this? Because our Fellow Covers and Visitors may become confused....:confused:

Stijloor.

BradM
19th January 2008, 02:35 PM
Great observation Jane!

Can the Moderators fix this? Because our Fellow Covers and Visitors may become confused....:confused:

Stijloor.


The thread title has not changed (how it appears at the top). Along the line, one of the posters changed the response title, which is entirely OK to do.:yes:

See this when you reply:

Thread or Post Title - Change if appropriate
within a thread to help continuity and branches:

Marc has encouraged us to experiment and be a little more creative when re-labeling our responses.

So, let's step outside the boundaries:lol: and be creative!:tg:

Stijloor
19th January 2008, 03:21 PM
The thread title has not changed (how it appears at the top). Along the line, one of the posters changed the response title, which is entirely OK to do.:yes:

See this when you reply:

Thread or Post Title - Change if appropriate
within a thread to help continuity and branches:

Marc has encouraged us to experiment and be a little more creative when re-labeling our responses.

So, let's step outside the boundaries:lol: and be creative!:tg:

Hi Brad,

I stepped outside the (Box) boundaries...and found myself in The Twilight Zone (http://en.wikipedia.org/wiki/The_Twilight_Zone)....:mg:

Stijloor.

fuzzy
25th January 2008, 06:54 PM
The draft report was just emailed to me... so here's an update. He didn't log any as majors/minors. Just verbals - a "fix it" ticket, if you will. And the items that he would like fixed are simple.

1. Complete Training Records (like I was saying... the "Grandfathering" thing.)
2. Missing step for procedure accepting purchase orders and contract review. (stamping and date PO indicating review.)

So we are on a mission this week to get them completed.

Your feedback is appreciated!!

Kyle - Good to hear of your progress...hard work has it's reward:yes:. I like the advice you've gotten; most likely this was not a "true" major, but I am troubled that the terms or "rules" were not clear before the audit began. I like the definitions that my last CB used, and I like to repeat them in my training sessions: 1.)system failure or collapse 2.)failure that resulted in or could have resulted in, the shipment of NC product to a customer. We got a major:notme: for failure to follow the requirements of our C=0 sampling plan, when an operator replaced:mad: a NC unit they found in the sample from the lot. The material never got shipped, but it would have without the audit interveening that day. Make sure that you understand the "rules" at the next audit opening.:cool: