Auditor demanding that we retrospectively populate training records.

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Baldrick

We've just gone through our TS Stage 2 with a few minors, one of which stemmed from HR having no record on file to demonstrate that one of our Logistics people had received any on the job training relating to the bespoke software package that he uses in his job (which is quality critical).

There was no problem with any aspect of our annual appraisal system, and the auditor is happy that we assess our people every year, including confirmation of competency.

We submitted a response that (we thought) covered all the bases - we reissued our training procedure and created a new form for logging future OTJ training. This was accepted by the auditor.

The MAJOR problem is that he is saying that we have to "address the gaps in our records", which I assume means that we have to somehow retrospectively create OTJ training records for everyone on site. :mg:

Apart from the work involved, surely this is problematic from a number of other standpoints? Since nothing was recorded at the time the training was given (remember we are talking only about OTJ training, which was not required in QS9000 or ISO9001:1994), can we realistically expect every employee on site to recall what training they have received? And when? And who delivered it? And what specific elements were covered and what wasn't? We could be talking about a 30 minute chat 10 years ago.

Even if we created these records based upon what people could remember, wouldn't both trainers and trainees be perfectly entitled to refuse to sign them?

Under TS and the new version of ISO we have to assess everyone annually for competency - which we do to or auditor's satisfaction. Doesn't this make it a moot point whether they received any OTJ training or not? Surely the only important thing is that they are now competent, and that we review this regularly?

I agree that recording OTJ training is a useful thing to do from now on, and we have happily agreed to do this. But creating retrospective records? To me that's not required by the standard and adding no value. :nope:

I'd appreciate all opinions?
 
D

Don Palmer

Baldrick said:
The MAJOR problem is that he is saying that we have to "address the gaps in our records", which I assume means that we have to somehow retrospectively create OTJ training records for everyone on site. :mg:
Is it possible that what the auditor really wants is a statement of fact as to WHY there is a gap in your records. I can not imagine an auditor suggesting someone 'pencil whip' records to fill in the gaps.
 
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ralphsulser

I doubt that suggesting you pencil whip records is the auditors intent. I think that creating skill level maps for each employee with training categories and competentcy will provide current and future resolution and tracking to satisfy this TS requriement. We have skill maps for each dept and they are updated quarterly and posted in the areas in the plant. I posted examples here on the Cove sometime ago, a search may help you find and evaluate if this would be beneficial for your operation. If you are in doubt, call your auditor and discuss it further.
 
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dbzman

Documentation

Is it possible that all the auditor really is looking for is a statement that you have evaluated the employee(s) and that they are competent?

Couldn’t you do this through observation for a short period of time and then document it?

How many employees are we talking about?

;)
 
B

Baldrick

Thanks - but I think he wants the records backdated.

Thanks for your input so far ralphsulser dbzman and Muleskinner. :thanx:

I should point out that we have an excellent system for recording training and competency, including skills matrices, job descriptions and records of all formal training (internal and external), supplemented by annual appraisal and other robust systems, all of which have been audited and deemed satisfactory.

We DON'T have any records of on-the-job training, because most of it is given informally and the sheer amount given, combined with the fact there was no requirement for it in QS, meant that this was impractical and unnecessary.

I think it's pretty clear that he wants us to backdate the records. We will ask of course, but assuming he DOES want this, does anyone have an opinion on whether it meets either the letter or intent of the standard?

Thanks again.
 
We are a small company, operating with a team based structure. While each team is well aware of the competence of their team mates in a given skill, and the team above them is also aware, these competencies were never documented (tribal knowledge). The vast majority of these competencies are achieved via OJT as we don't have a big training staff and/or facilities.:D

We created a spreadsheet for each team: A cross-training matrix, if you will. Team members across the top, skills necessary on the team down the side. Team leaders documented the competency of each team member on a 1 (no skill) to 4 (competent without supervision), signed the matrix, which was approved by the team leader of the next team up the chain.

In addition, each skill in the matrix is listed on a second page of the spreadsheet with the training requirements to acheive competency. For example, TS Awareness requires classroom training to achieve a 4, while ability to build product X to print Y is OJT. This document is also signed by two team leaders, completer and approver.

It's not a lot of work and gives you a kickin' cross-training matrix for each team member. You are also covered when you have employees moving from team to team to adjust workloads and throughputs (TOC).

What's wrong with a team leader documenting the fact that they know that I am competent to run a press because they taught me how to do it 10 years ago?
-ICY
P.S. During registration, the whole training and evaluation of its effectiveness was one of our "atta-boys".
 
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dbzman

Simplify

Wouldn’t it be sufficient if you had it stated in your documentation that all training of these employees includes on the job training?

Your program includes on-the-job training and when the employee is signed off that he is trained then all conditions (including on-the-job training) are met.

When it comes right down to it the only evidence is the signature of the trainer and the employee’s ability to demonstrate at any time his competency.


:bonk:
 
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ralphsulser

I agree, just add OJT to your training and competence matrix categories
 
B

Baldrick

What about the retrospective records question?

Guys - thanks again for your swift responses. All good stuff. :agree1:

But I re-emphasise - we ALREADY DO ALL OF THE STUFF YOU RECOMMEND. Our system is very similar to the one described by Icy.

The issue is not about demonstration of competency or even training records in general. Our problem is that we have been doing, but not recording, On-The-Job training.

We have amended our training procedure and created a new form to record OTJ training FROM THIS POINT ONWARDS - but we have now been told by our auditor that we also need to populate our training records RETROSPECTIVELY to "fill in the gaps" (the auditor's own words).

I think this is unethical, impractical and non-value added.

Can anyone offer a solution to this one?
 

Jim Wynne

Leader
Admin
If you don't understand the auditor's finding, and especially if you don't see the "shall," you need to discuss it with the auditor. It might also help if you were to post the exact text of the auditor's written finding which, I assume, includes a citation of the clause you're alleged to have violated.

If the auditor is indeed trying to invoke ex post facto requirements, you should be able to easily show the absurdity of the expectation. An audit is a "snapshot" of the state of the quality system at the time of the audit, not what the quality system looked like two years ago.
 
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