Top Management and Competence, Awareness, Training

[samsung]

There is a very important word in the clause 5 of the ISO 9001; TOP MANAGEMENT.
Who is your Top management ? One person say the MD or CEO ., Board of Directors., A Top Management Team., .... ?
How deep is their understanding about the ISO9001 standard, the 2008 release. Have they been trained about the standard, about the intents of the clause 5. Do you maintain their training records ? Are they mapped in the training plans going further ? Does your certification agency ask and look for this anytime in the audits ? Is the same done in your internal audits ??.

Since it is not a requirement, why would the certification agency look for the Top Management's training record to seek the evidences of his 'Competence' and/or 'awareness'. And what especially is new in clause 5.0 in the 2008 release for the Top Management which he was presumably not aware of at the time of establishing the QMS in the first instance ?

And what if he is found to be 'incompetent' ? Will the Auditor (external or internal) write it as a non conformance and ask for an appropriate Corrective Action?

IMO, only those people who are found to have any 'gaps' need to be not only mapped in the training plans but also in the programs designed to bridge such gaps. The auditor can look for many other evidences should he, at any time, develop an apprehension of the top managements' 'competence' or 'awareness' about his duties. Few of the documents that can provide an insight to this effect are - Policy, Business Plan, assignment of responsibilities and delegation of authorities and the likes.

It's often the MR or quality coordinator who makes the TM aware of the changes/ revisions in the standard and the possible impacts on the certification status and that should be enough for this matter.

 

[somashekar]

Does that not constitute to the training of the top management ? and an audit to check if this activity does happen and is effective ? IMO the competence awareness and training covers all the elements of the QMS and Top management is one vital element.
Coming to actuals ... does the internal auditors and certification auditors shy away from this process of looking at it across the organization Top to bottom.
We had an auditor asking for the training records of plant GM and when the GM said that he has xx years experience and is the overall chief of the organization the auditor response was " So what " ...
I would like to know how various organizations view this ... ?

 

[samsung]

Does that not constitute to the training of the top management ? and an audit to check if this activity does happen and is effective ? IMO the competence awareness and training covers all the elements of the QMS and Top management is one vital element.
Coming to actuals ... does the internal auditors and certification auditors shy away from this process of looking at it across the organization Top to bottom.
We had an auditor asking for the training records of plant GM and when the GM said that he has xx years experience and is the overall chief of the organization the auditor response was " So what " ...
I would like to know how various organizations view this ... ?

During the 2008 revision, two changes were made to clause 6.2.2 :

(i) Change in title from 'Competence, Awareness, and Training' to 'Competence, Training and Awareness' to signify that awareness comes from some sort of training and hence the 3 elements were reordered.

(ii) "Determine the necessary competence for personnel performing work affecting conformity to product requirements, as against "work affecting product quality"

That says the standard still upheld the requirement of 'determination of competence' only of the persons whose work can affect conformity to product requirements. So no one in the organization ever needs to be provided any training if everyone is competent and Competence has to be determined against a defined set of requirements. If a 'GAP' exists, it needs to be fulfilled by means of 'training or other actions'.

So, upto this point the auditor should feel quite relaxed. Now, you can say that many of the decisions of top management can affect conformity to product requirements. Requirement can (& do) keep changing and the one who has to direct and control the organization is constantly made aware of those changes, & that's all. And I don't see any need for recording such 'awareness sessions'.

Auditor should only look for the processes, the role of enablers and the results. And, if, during the investigation, it is proved that the non-fulfillment of the requirement is attributable to 'incompetence' or 'unawareness' of the TM, he has a legitimate right to raise an NC but before doing so he shall have to be 200% sure of his decision/ finding.

Still I have to hear of the instances where an auditor could prove 'incompetence' of a CEO. Can an auditor ask for showing CEO's annual appraisal documents to verify what his own evaluator considered of his 'competence' and whether or not recommended a 'Training' to fulfill the 'gap'?

 

[Randy]

As stated Top Management is defined in ISO 9000:2005 and it's up to the organization itself to figure it out.

In very simple laymen's terms Top Management will be whoever has the organizational authority to authorize/mandate/order the establishment of a Quality Policy for the entire organization and who also has authority over the highest level of organization resource decisions and allocation....Oh yeah...ORGANIZATION is defined in ISO 9000:2005 as well. Top Management hasn't got anything to do with job titles, it's an authority & responsibilty thing.

Use the standards and their associated references and it'll make life a whole lot easier and less complicated.

 

[samsung]

We had an auditor asking for the training records of plant GM and when the GM said that he has xx years experience and is the overall chief of the organization the auditor response was " So what " ...

Training records of what ? Did the auditor find anything that had direct linkage with his 'competence' (or incompetence) and 'training' was the only cure ? I've never seen/ heard of an auditor auditing top Management and asking for his/her/their training records. I consider it undesirable and waste of time.

Our CEO is a very good safety manager and trainer and infact whenever he's free from his tight business schedule, he delivers long safety talks, takes interesting training classes, gathers people at plant site and guides them on hazard identification or site EHS inspection etc etc. Similarly, when in office, he never miss to attend any of the training sessions / tool box talks / lectures by other staff or external faculties, particularly on safety. We do make note of the persons who attended the 'session' but never make it a training record of the CEO or other members of the top management team. He does it with an intent of motivating and involving the people in achieving the organizational goals and not to get his hours counted as training mandays to become a record/ history of himself.

Infact, this CEO or any other member of our Top Management would never bother to entertain an auditor if asking for the 'Training Records'.

Let's see how others feel it like. Thanks.

 

[MajorBVNaik]

Dear Friends
I have read the discussion with lot of interest & must sya that I enjoyed it immnesely
I am of the opinion that the quality manual must define under clause 5.1 as to who is or who are top management.
Another important point is that identifying competence required for the top management, if top management is MD (person who writes the cheque) he/she should do the needful on his/her own. Having done the identification part he/she should identify the seminars or suitable training events which would help him/her improve competence help run the organization effectively & efficiently. He/she should hand over details of such seminars & also self evaluation to the MR who can maintain records.
Any person of such a stature should think that learning is an on going process & he/she should never think that they know every thing & stop learning & improving.

 

[Richard Pike]

Can an auditor ask for showing CEO's annual appraisal documents to verify what his own evaluator considered of his 'competence' and whether or not recommended a 'Training' to fulfill the 'gap'?

Only if he /she is particularly stupid!

However: if the incumbent has specific defined responsibilities in the organization, and those have been identified as requiring specific training and/or competence; then YES to verify same would be within the remit of the Auditor.

An example could be if the "top manager' formally conducts Internal Audits.

 

[somashekar]

Dear Friends
I have read the discussion with lot of interest & must sya that I enjoyed it immnesely
I am of the opinion that the quality manual must define under clause 5.1 as to who is or who are top management.
Another important point is that identifying competence required for the top management, if top management is MD (person who writes the cheque) he/she should do the needful on his/her own. Having done the identification part he/she should identify the seminars or suitable training events which would help him/her improve competence help run the organization effectively & efficiently. He/she should hand over details of such seminars & also self evaluation to the MR who can maintain records.
Any person of such a stature should think that learning is an on going process & he/she should never think that they know every thing & stop learning & improving.

Permit me to refer to the ISO 13485:2003 here which is based on the ISO 9001:2000. Though the ISO 9001:2008 is now applicable, this standard ISO 13485:2003 continues as is per my information. However with very minor changes made in the ISO9001:2008 about the clause 6.2.2 (Competence, training and awareness) the overall intent still remains very much same as I believe.
If you further dwell into 6.2.2 d) there is no change here in the new ISO 9001:2008.
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 ....
More so in the ISO13485:2003 scenerio, the Top management MUST be aware, trained and competent about the new and revised regulatory requirements, the need for the organization to comply with these requirements and the consequences of not meeting them. About the systems established for vigilance and product recalls, about responding to competent authorities on any reported problems and other vide gammet revolving around these subjects which have direct relationship to business , growth, risks, and the need to plan and budget towards meeting them. The Top management represents the organization and in connection with several regulatory and other agreements it is this Top which would have signed on the dotted line. Such training to them hence is very vital for the conformity to requirements.
These do mostly come from proper and timely training & awareness (or awareness & training) and records established about them goes to ensure that these "personnel" are aware of the relevance and importance of their activities and how they contribute to the achievement of the quality objectives.
Similar perhaps it will be in other various areas when we talk about global business scenario. Hence I tend to believe that Top management has to be abreast with the related global regulatory requirements and changes and in effect within the quality management system the established procedure of maintaining records per 6.2.2 e) is applicable to all personnel TOP to BOTTOM where applicable.

 

[JaneB]

We had an auditor asking for the training records of plant GM and when the GM said that he has xx years experience and is the overall chief of the organization the auditor response was " So what "

If any auditor of any of my clients responded so rudely and ignorantly, I'd quote them the relevant bits of the Standard (see below) while showing them out the door, lodge a complaint with the CB and insist that they send along an auditor who audits against the Standard, rather than their own personal interpretation of it.
Why don't people just read the Standard? Why do they ignore the italicised bits below from ISO 9001?

6.2.1 Personnel performing work affecting conformity to product requirements shall be competent on the basis of appropriate education, training, skills and experience....

and 6.2.2b. the organisation shall

where applicable, provide training or take other actions to achieve the necessary competence

Use the standards and their associated references and it'll make life a whole lot easier and less complicated.

Indeed yes.
As for an auditor insisting on seeing 'training records', I like Richard's response:

Only if he /she is particularly stupid!

However: if the incumbent has specific defined responsibilities in the organization, and those have been identified as requiring specific training and/or competence; then YES to verify same would be within the remit of the Auditor.

An example could be if the "top manager' formally conducts Internal Audits.

Good example.

I once had a somewhat blinkered auditor ask, at the end of a 3-day certification audit, to see the 'training file' for the CEO of his own small and now highly successful and fast-growing company, which he'd taken from an annual turnover of <$100K to $20m in approx 4 years. I said he'd seen the evidence all throughout during his audit. And when he attempted to argue the need for even the CEO to have a 'training file' quoted the relevant sections from the Standard to him. Demonstrated skills, experience and education were more than adequate.

He stopped asking.

As well he should.

A better auditor wouldn't have even asked in the first place.

 

[John Broomfield]

There is a very important word in the clause 5 of the ISO 9001; TOP MANAGEMENT.
Who is your Top management ? One person say the MD or CEO ., Board of Directors., A Top Management Team., .... ?
How deep is their understanding about the ISO9001 standard, the 2008 release. Have they been trained about the standard, about the intents of the clause 5. Do you maintain their training records ? Are they mapped in the training plans going further ? Does your certification agency ask and look for this anytime in the audits ? Is the same done in your internal audits ??.

Someshekar,

Top management is defined in ISO 9000 and this is a normative reference. Normative means it reinforces the requirements of ISO 9001 in defining corrective action for example. If ISO 9000 were an informative reference it would be a guide to interpreting ISO 9001. But it is not, it is an itegral part of the ISO 9001's requirements.

Only the internal auditors (and management rep) are required to know the requirements of ISO 9001. Top management is not. Neither are the employees generally required to know ISO 9001. They all are required to know their system for determining and fulfilling requirements.

Top management are meant to be competent in consistently showing their commitment to requirements from customers, regulators, employees, shareholders and their management system.

This comes from providing the resources (think>speak>action>follow-up)

They should be able to explain to the employees how their system works and how it helps the employees do good work. They should be able to explain the obligations and benefits of their system instead of leaving this to the System Manager or worse - the consultant.

I see little evidence of auditing evidence of top management commitment and competence. When is the last time any of us issued a corrective action request against clause 5.1?

John