Good afternoon,
Our organization has a job description for every position with minimum education and experience background required. Besides, we provide job-related training and keep records of it. Our Human resources procedure says that managers can consider other criteria or referrals and might hire someone without minimum requirements described in the job description. Each year we discuss with our ISO external auditor, and he says that we can not do that. What is the best way to address this issue? As per my understanding, we are complying with clause 7.2 competence by proving job-related training and addressing in our procedure that managers might consider other criteria. Please suggest the best way to address this issue.
Your auditor is likely correct. The standard is VERY clear on the topic.
7.2 "The organization shall: a) determine the necessary competence of person(s) doing work under its control that effects the performance and effectiveness of the quality management system . . . "
It is a requirement that the organization "determine the necessary competence".
Further it states "d) retain appropriate documented information as evidence of competence".
Let's look at what the OP actually stated. The HR procedure offers an "out" if an otherwise desirable candidate doesn't fit all of the "requirements" stated in the job description. This is only tangentially related to competence. It doesn't mean that the job description is evidence of having determined the "
necessary competence."
This is from the 2008 version of 9001, but the changes in the 2015 version are mostly superficial:
The organization must:
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)
Given "a" and "b" we can see that it's acceptable, after determining the necessary competence, to provide training (or take other actions) to achieve it. This means, at least by implication, that it's acceptable to hire people who might not have the necessary
competence and then give them an opportunity to achieve it. The idea of allowing for a rational decision to forego certain "requirements" (not
competencies, mind you) makes perfect sense and is done all the time. Furthermore, the listing of attributes given in job descriptions and solicitations is often ambiguous. Just for fun, I pulled up a solicitation for a quality engineer position on LinkedIn and found this:
Quality Engineer I Job Requirements:
Bachelors of Science in Engineering or related STEM field(s)
3+ years within a Manufacturing Environment
Experience operating and manipulating a QMS (Quality Management System)
Experience with Statistical Process control
Minimum six sigma green belt preferred
Experience in implementing a quality management system is a plus
Ability to work well with all levels of personnel throughout the facility.
On-call for Quality related production issues.
(My emphasis)
What does "operating and manipulating a QMS" mean? What extent of experience with SPC is necessary in order to be considered
competent? Why are attributes identified as "preferred" and "a plus" listed as
requirements?
There is no valid reason that (a) the qualifications of any candidate shouldn't be fluid except in cases where a minimum level of education and training is legally necessary and (b) candidates lacking one or more of the stated "requirements" shouldn't be hired and then trained to achieve the necessary competence.