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Date of Quality Management System - Training Records

ISO_Man

Involved In Discussions
#1
I have some very long-term employees (like 20+ years) and it's a challenge to provide training records for them - a number of their training folders just have the note "grandfathered in" written on the record. I'm thinking of drafting a statement for signature by upper management that these people were employees long before our current QMS was in place and their work has been validated by qualified personnel. The practice of maintaining training records was implemented officially when this QMS was adopted and training records are up to date since then.

Any thoughts?
 

Al Rosen

Staff member
Super Moderator
#2
I have some very long-term employees (like 20+ years) and it's a challenge to provide training records for them - a number of their training folders just have the note "grandfathered in" written on the record. I'm thinking of drafting a statement for signature by upper management that these people were employees long before our current QMS was in place and their work has been validated by qualified personnel. The practice of maintaining training records was implemented officially when this QMS was adopted and training records are up to date since then.

Any thoughts?
I would just add this statement to your training SOP and not necessarily involve upper management.
 
#4
Hi. My company have been certified for 3 systems (ISO9001, 14001 & 45001). On my recent audit, the auditor had raise an NC on clause 7.2, which we have to identify non-legislated training as well and who should attend the training. We have already identified the legislated training and records are available.
Appreciate to have some examples of non-legislated training, other than root cause analysis which i can think of.. seem like this non-legislated training is very subjective
 

ISO_Man

Involved In Discussions
#5
Hi. My company have been certified for 3 systems (ISO9001, 14001 & 45001). On my recent audit, the auditor had raise an NC on clause 7.2, which we have to identify non-legislated training as well and who should attend the training. We have already identified the legislated training and records are available.
Appreciate to have some examples of non-legislated training, other than root cause analysis which i can think of.. seem like this non-legislated training is very subjective
I'm not sure what you mean by "legislated training." Where is your company located?
 

atitheya

Involved In Discussions
#7
Hi. My company have been certified for 3 systems (ISO9001, 14001 & 45001). On my recent audit, the auditor had raise an NC on clause 7.2, which we have to identify non-legislated training as well and who should attend the training. We have already identified the legislated training and records are available.
Appreciate to have some examples of non-legislated training, other than root cause analysis which i can think of.. seem like this non-legislated training is very subjective
You must understand the intent of the standard.

You must demonstrate that the employees are competent, whether by virtue of legislative training or otherwise, to execute their job effectively. If you can assure, no further training is required, auditor cannot raise an NC. ISO9001:2015 7.2 b) states 'ensure that these persons are competent on the basis of appropriate education, training, or experience'. Note the word 'experience', as also the effectiveness of the work done.

Where there is a legislation for a particular training or education, that must be followed, and records retained.
 

Mike S.

An Early 'Cover'
Trusted
#8
As far as training records....a few questions come to mind:

If I am training someone to do something new, say, a 60 minute training session for a new employee on how to maintain the calibration database, or perform acceptance test ABC-123, I always do a training record.

But where do we draw the line between training and ongoing coaching, or answering questions, or awareness? What does ISO9001/AS9100 7.2 really require?

Let's say a procedure is revised and it is important to make the people who use that procedure aware of the change. It takes a 5 minute review with them -- as much awareness ("hey, be aware that we changed the requirements here....") as it is actual "training". Do you require that a training record be generated?

What if they have questions about performing a task that they are already basically qualified to do, but they encounter some unusual situations and I spend 15 minutes going over some examples. Training record?

I'd be interested to hear some perspectives.
 

atitheya

Involved In Discussions
#9
What does ISO9001/AS9100 7.2 really require?
"ISO 9001:2015 clause 7.2 d) retain appropriate documented information as evidence of competence"

The training, coaching, mentoring, briefing, or any other actions may be recorded (or not recorded) as determined necessary by your organization. The standard does not have a requirement for any such record.
 

tony s

Information Seeker
Trusted
#10
If I'm the internal auditor of an organization, what records should I present to the CB auditor "as evidence of competence"? Training certificate? I don't think so. IAF Auditing Practices Guidance on Competence clarified that "training records could be viewed to verify that a training course had been successfully completed (but note, this alone would not provide evidence that the trainee is competent)". See this link.
 
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