Audit Finding on 6.2.2 - Education Requirements not Verified

[ACIQualityGuy]

We recently went through our stage two audit and passed!

Of course the auditors had a minor finding, and I'm having a hard time understanding how we can meet the requirement while still adding value, can you help?

The job description for my position indicated that I have 3-5 years experience and a technical degree. We didn't have a copy of my diploma on file and don't have one for any of our employees for that matter. It was on this basis that he wrote us up, see below:

Details:
Appropriate records of education, training, skills and experience are not effective.

Requirements:

6.2.2 Competence, training and awareness
The organization shall
a) determine the necessary competence for personnel performing work affecting conformity to product requirements,
b) where applicable, provide training or take other actions to achieve the necessary competence,
c) evaluate the effectiveness of the actions taken,
d) ensure that its personnel are aware of the relevance and importance of their activities and how they contribute to the achievement of the quality objectives, and​

e) maintain appropriate records of education, training, skills and experience (see 4.2.4).

Objective Evidence:
Reviewed the job description for the Quality Control manager and the education section requires a degree in a technical field, but they don't have any evidence of the document in their files.​

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We've gone through our job descriptions and added "preferred" to the education and skills requirements so that we can have some flexability in who we hire.

We're also adding a note in all current employee files indicating that they've been grandfathered in (we aren't going to ask all current employees for a copy of their diploma/call their previous employers to verify their experience).

Moving forward I'm wondering if we really need to call and verify past employer history and ask that they give a copy of their diploma. For us it's most important that the employee works for us and not that they meet a specific requirement (hence the "preferred" added to our job descriptions), and we perform 90 day reviews to document they are working out.

We want to keep the ideal candidate information (that they have experiance / education) so that we can use the job descriptions when posting an opening.

What do you guys do / how do you satisfy this requirement?

Thanks in advance!

 

[AndyN]

Re: Audit Finding on 6.2.2, Education Requirements not Verified

This is part of the reason why competency was introduced - because records of training and education don't provide for competency. Perhaps, if instead of specifying jobs in traditional terms, it should be slanted more towards competencies. Then "hiring" criteria which are likely to provide for the background to competency would be less important. The auditor, possibly more by luck, might have done you a favor!

 

[Marc]

Proof of Education

This is kinda off the wall, but some one I know worked in a company which was bought by anther company. The new owner put every employee (several hundred) through a totally new employee hire procedure (as if they were applying for their job to begin with). The only people exempt were people who had been with the acquired company more than 8 years.

So - They had to provide copies of their high school (or other required) diploma(s) (or proof there of), evidence of training they had taken, vaccination certificates, etc., etc. There were a few people who had problems because their high school had been closed (and they didn't keep their diploma, it was lost or whatever) and things like that. Not to mention - Do you have evidence of your vaccinations? I sure don't and showing them "the spot" didn't count. A lot of people had to be re-vaccinated.

Plus - They had "additional" requirements such as each employee will be drug and nicotine tested. Drug failure was auto-you-are-fired (as one would expect). Tobacco you had 6 months to get off nicotine (including nicotine substitutes such as patches and gum). Proof by blood test.

My only point in this is to say I think this level of "detail" may be the future. I'd bet even proof of a background check will become relatively standard in the not to far future.

 

[somashekar]

An element of competency comes from education. When you recruit going further, your determined education as one of the basis for consideration must be supported by the candidates true credentials, and get into the personnel record.

 

[ACIQualityGuy]

Since we no longer have education / skill "requirements" (because we indicate they are preferred but not required in the job description), do we still need to verify the employee graduated / has the skills they indicated on their resume? I would argue that we verify the employee has the needed skills to perform their job with our 90 day and annual employee review.

Thanks for all the responses!

 

[JaneB]

Since we no longer have education / skill "requirements" (because we indicate they are preferred but not required in the job description), do we still need to verify the employee graduated / has the skills they indicated on their resume? I would argue that we verify the employee has the needed skills to perform their job with our 90 day and annual employee review.

Thanks for all the responses!

No you don't need to verify everyone who said they graduated did actually do so, if you have now changed the rules of your system. You should consider whether just accepting a person's resume on face value alone is good practice in future. I would suggest it's an unwise practice, but if you have good 90- day and annual reviews, that should compensate.

In saying the above, I assume that you are not in a field where your personnel must have certain qualifications and that you are not making claims to your customers which are either untrue or you haven't substantiated (eg, our staff are graduates).

Did you drop ALL requirements for all your employees, or just those relating to qualifications?

If you decided to ditch all of them, think again. You see, you do need to specify what competencies are required for your various roles. Now, if a particular role doesn't have any requirements at all and anyone with a pulse who is vertical & breathing will do, then fine. But usually most roles need at least a few competencies, so just list them.

Saying something is preferred is fine, if that's the case.

Grandfathering is fine - going forward you'll want to have a system of reviews in place to ensure people remain competent, which it sounds as though you do.

If the write-up pushed you to get a bit clearer about what was actually required versus what was simply preferred, that's good.

One of my clients had everyone write their own job descriptions. One guy listed 'qualified hairdresser' as a required criteria. He was a Sales role. I asked the business owner if in future he only wanted to hire sales people who had hairdressing qualifications - for a company that sold and serviced wide format printers!

 

[insect warfare]

Since we no longer have education / skill "requirements" (because we indicate they are preferred but not required in the job description), do we still need to verify the employee graduated / has the skills they indicated on their resume? I would argue that we verify the employee has the needed skills to perform their job with our 90 day and annual employee review.

Thanks for all the responses!

This should already be taking place via background checking through your HR or staffing agency. If the job description documents do not reflect what you (as a company) are looking for in certain people, then by all means update them so they are more effective in that regard, and try not to be too prescriptive where you can help it.

Another thing to think about: 6.2.1 also states "Personnel.....shall be competent on the basis of appropriate education, training, skills and experience". What value is there in verifying someone's diploma or credentials if they are already competent overall in their assigned duties? What makes not having a diploma "inappropriate" in the first place? The sum of one's competence is comprised of a suitable combination of these four elements, and the evaluation of that competence (by what your organization feels is appropriate) is by far the most important aspect of determining the true value of their performance.

I have no formal education as an internal auditor, but I sure have the experience to make up for it (not a nonconformity, i hope). And the requirements for my position do not state anything requiring that I be "certified" in that field, either.

Brian