Competency evaluation records - Direct correlation to EMS-related topics

SteelMaiden

Super Moderator
Trusted Information Resource
Guys and Gals, we just finished up with our first surveillance audit for 14001. Had a great audit, and wowed our auditor. All except the following nonconformance: Records of competency were not evidenced that showed direct correlation to EMS-related topics presented in the annual refresher training. Competency records for contractors were also not evidenced.

We, internally, had written up a nonconformance about contractors - we had not done a good job on identifying competency requirements for contractors, therefore making it impossible for our contractors to acheive competency on a consistent basis.

As for our own employees, we maintain a matrix of "competencies" for each job function, and annually we review (supervisors review hourly, managers review supervisors, and up the line) each employee for competency and document it at the same time we document our cost of living increase. In addition, trainees are reviewed using the same criteria during each of their reviews (6, 9, 12 and 18 months to get to full grade).

The auditor could not find an instance of incompetent behaviour, and actually commended us on the knowledge of our people. I am having a hard time with this. (I was kind of the official stand in for this audit as the MR we had left us for another company and his replacement just started) If we have a matrix, and we train to it, and have training records, and managerial/supervisory staff feels that their employees are competent and document that "employee x has shown appropriate competency to perform all functions of his job" why isn't this enough? The auditor stated that we "could" back this up with tests given after all training, and then maybe follow up after 3 or 6 months to see if the employee has retained the knowledge. That is why we have supervisors, to monitor employees progress and develop or reinforce competency.

What do you do in your organization to document assessment of competency? Do you have a competency evaluation on each and every aspect that an employee is affected by? Do you have a record for each employee showing that they "competently" recycle toner cartridges? I want to use this information for some benchmarking. Thanks in advance.
 

harry

Trusted Information Resource
Hi Steel,

1. Would having an evaluation column in the training records for the trainer or supervisor to carry out evaluation be good enough for your case?. Such evaluation need to be done within say 3 months after training and those with unsatisfactory results need to undergo further training.
2. For critical processes (those that may have an impact on the environment), have a mandatory emergency response and preparedness drill at least once a year. Such drills also enable us to carry out an audit of response and preparedness, procedures, resources and in a way is a validation of the effectiveness of trainings carried out.
3. Toner cartridges? I hope the auditor is not carrying a magnifying glass but as long as training is carried out and evaluation done, shouldn't be a problem isn't it?
 

Randy

Super Moderator
Anything related with competency should fall in line with this definition (which BTW will be in the next 14001 and other associated documents and is in 9000:2005)

competence
demonstrated personal attributes and demonstrated ability to apply knowledge and skills


1. Identify what the personal attributes are that are necessary for the specific task.

2. Identify the necessary knowledge required for the specific task.

3. Identify the necessary skills for the specific task.

4. Identify the methods needed to evaluate achieving 1-2-3

5. Identify the format to verify achievement of 1-2-3

That's it in a nutshell


Oh yeah, document it.

B]4.4.2 Competence, training and awareness[/B]
The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records.
 

SteelMaiden

Super Moderator
Trusted Information Resource
Hi Steel,

1. Would having an evaluation column in the training records for the trainer or supervisor to carry out evaluation be good enough for your case?. Such evaluation need to be done within say 3 months after training and those with unsatisfactory results need to undergo further training.
2. For critical processes (those that may have an impact on the environment), have a mandatory emergency response and preparedness drill at least once a year. Such drills also enable us to carry out an audit of response and preparedness, procedures, resources and in a way is a validation of the effectiveness of trainings carried out.
3. Toner cartridges? I hope the auditor is not carrying a magnifying glass but as long as training is carried out and evaluation done, shouldn't be a problem isn't it?

1 Well, right now it is evaluated through supervisors and documented on a change of status 6 mos after.
2 We do drills on evacs, spills, etc., and they are documented along with a follow up "what went wrong, what went right" meeting with minutes and action items.
3 Yep, she said stuff like aerosol can disposal, toner cartridges and out other recycling efforts, and we do an inspection every month that documents problems....finding unrecycled material has never been a problem:rolleyes:

You kind of have to imagine that our plant is very, very clean for what we are doing. perfect? no, but better than most.

Anything related with competency should fall in line with this definition (which BTW will be in the next 14001 and other associated documents and is in 9000:2005)

competence
demonstrated personal attributes and demonstrated ability to apply knowledge and skills

1. Identify what the personal attributes are that are necessary for the specific task.

2. Identify the necessary knowledge required for the specific task.

3. Identify the necessary skills for the specific task.

4. Identify the methods needed to evaluate achieving 1-2-3

5. Identify the format to verify achievement of 1-2-3

That's it in a nutshell


Oh yeah, document it.

B]4.4.2 Competence, training and awareness[/b]
The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records.

1 done..listed in HR by job titles
2 done..listed in HR by job titles
3 done..listed in matrix by job titles
4 done..documented by our procedure
5 done..documented that personnel were assessed and found competent as noted in the original post.

So, it looks like we have met the letter of the standard, any thoughts as to whether we are meeting the intent? (that is what she "said" but did not document in her finding)

BTW, I don't want anyone to think that our auditor is not good, she is, and I really like her. I just think that what she wrote kind of misses the problem...I see a real disconnect when it comes to defining competencies, we are really just too broad in our documentation (we don't list individual impact possibilities that are governed by permits, etc.) The manager of the department wants to list OA or overall knowledge of the EMS, I want to know if the person can affect our Title V permit. Does this make sense to anyone else? thanks, once again the Cove pulls my :ca: out of the fire. :thanks:
 

Randy

Super Moderator
The competency thing is one of the most misunderstood and poorly accomplished and audited processes in nearly every system I see. More often than not training has been done but that's it.

I think what you indicate is being done hits the mark and hits it very good. The aduitor herself may be a little off, lord knows my bubble misses middle occasionally.
 
Hi,

The main issue appears to be the link between "activities that result in significant environmental impacts" and "competence of those personnel who carry out those activities". Many times the HR competency matrix is insufficient to address the issue of "singificant environmental impact" ; we faced a similar observation in our surveillance audit. For example, how many organizations with ISO-14001 will show "knowledge of environmental impacts and the socio-legal implications of the processes" as one of the competency criteria (or in the job description) for say, Vice-President, Operations. Many significant impacts of the operation are/may be linked to the activities of this Vice-President; has this criterion been captured in his job-description ? In my opinion the surveillance auditor is trying to help you to fine tune your system to be more effective by pointing out this gap. If you start linking the significant aspects to those whose activities can cause the related significant impacts and then check if competencies required for reducing/eliminating these risks have been captured in their competency matrix, you will definitely see the point made by your auditor. In my opinion, your auditor is adding value to your system.

With best regards,

Ramakrishnan
 

harry

Trusted Information Resource
BTW, I don't want anyone to think that our auditor is not good, she is, and I really like her. I just think that what she wrote kind of misses the problem...I see a real disconnect when it comes to defining competencies, we are really just too broad in our documentation (we don't list individual impact possibilities that are governed by permits, etc.) The manager of the department wants to list OA or overall knowledge of the EMS, I want to know if the person can affect our Title V permit. Does this make sense to anyone else? thanks, once again the Cove pulls my :ca: out of the fire. :thanks:

Hi,

The main issue appears to be the link between "activities that result in significant environmental impacts" and "competence of those personnel who carry out those activities". Many times the HR competency matrix is insufficient to address the issue of "singificant environmental impact" ; we faced a similar observation in our surveillance audit. For example, how many organizations with ISO-14001 will show "knowledge of environmental impacts and the socio-legal implications of the processes" as one of the competency criteria (or in the job description) for say, Vice-President, Operations. Many significant impacts of the operation are/may be linked to the activities of this Vice-President; has this criterion been captured in his job-description ? In my opinion the surveillance auditor is trying to help you to fine tune your system to be more effective by pointing out this gap. If you start linking the significant aspects to those whose activities can cause the related significant impacts and then check if competencies required for reducing/eliminating these risks have been captured in their competency matrix, you will definitely see the point made by your auditor. In my opinion, your auditor is adding value to your system.

With best regards,

Ramakrishnan

I agree that you have a good auditor and you also have a good system running. I think she's trying to help you make it better. I also concur with Dr. Ramakrishnan's view.

Setting up a system and get it running is easy but the ability to fine tune it further is a challenge. I hope to learn from your experience (and others also).

Regards.
 

SteelMaiden

Super Moderator
Trusted Information Resource
Thanks Dr. R, you are definitely on track, but in our case, we not only have the HR competencies but an additional matrix for competence (that is also assessed) that was created using those aspects along with the other requirements, both legal and other, by a team of environmental and system management personnel. I think she just didn't like the fact that our records do not list individually all competency requirements. We take the checklist and then make a general competency statement and track the individual's "action items" for improvement. I think she wants to see a checklist for each employee with a yes/no/na.

I think that she looked at this last before the closing meeting and just was not quite putting two and two together. As I said earlier, she could not find any instance where an employee did not show absolute competence and praised us for having such knowledgeable personnel. Are there ways to improve, sure, but I cannot see where we were in nonconformance to the standard.

Thanks everyone, I have to go write up an investigation on this nonconformance:biglaugh:
 
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