Training records vs experience and education

[Andy Cheung]

Some of my colleagues come to an argument when our internal auditor asked the Quality Control Supervisor showing her training record of IPC standards (which used as part of the criteria for the inspection), she had no evidence about it but said she had enough experience and education on this topic. Is it acceptable?

 

[John C]

Andy,
In the standard, 4.18 it says 'appropriate training records must be kept' and refers to 4.16 Quality Records. So, if someone is claiming, to the internal auditor, that their process is compliant with the standard because of their training history, then they'd better have the records before it can even be considered. If they haven't the record, then they're dinged twice; Once against the process and again against 4.18. Maybe even against 1.16 as well.

[This message has been edited by Marc Smith (edited 13 March 2000).]

 

[Marc]

If the gal took an 'official' course, all you need is 'a cancelled check' type of evidence. Even a copy of the bill. Typically folks giving classes give some sort of certificate.

You can use experience in lieu of training. Just cite the experience clained (such as 5 years working in lab as ... and ....). The auditor cannot tell you what minimum experience is. You have to determine that and be ready to tell the auditor what the company considers adequate. Your company should have some sort of job description which states some 'standard'. Often this issue gets sticky as there is typically no published standard for experience. Some places you can see evidence of an attempt - for example, even auditors have 'minimum' experience / education / training requirements. Check out the RAB or IRCA stated requirements. For lab personel you might check the A2LA and see if they have guidelines. I know this topic ('minimum' experience / education / training requirements) hase been recently discussed in Greg Gogates listserv. There's a lot fo debate here.

... she said she had enough experience and education on this topic. Is it acceptable?...

Yes - if you can state what that experience is and how it meets the job description / requirements. I saw one auditor ask for a resume a year or so ago. He was being awful picky... But - it wasn't a problem.

[This message has been edited by Marc Smith (edited 13 March 2000).]

 

[Christian Lupo]

I worked for a company where the average employee had 20 years experience at their job. There were a lot of employees with 30+ years at the same job. They were around long before ISO training requirements were created. Obviously we did not require an artisan (it was a complex process) of 30 years to have a step by step procedure. The (valid)arguement for the Quality department was, what if the artisan of 30 years leaves, through vacation, early retirement (that did happen), promotion, fired, etc... What would happen to that process? This was not a valid arguement to the worker of 30 years since "he was from the old school" and didn't miss any days!

So we compromised, the job description defined the minimum amount (years) of experience needed to perform the experienced artisans position. We let the employee decide how much experience was needed, which gave that person input in the creation of the new system and a chance to pad their ego. They usually said that their job could not be done without procedures with less than 5-10 years experience, which gave them security. They agreed to train backups, and eventually found it easier to write procedures.

I was always in favor of accurate josb decriptions approved by responsible management. You wouldn't bring in raw materials that didn't have specifications, why would you bring in new employees (the most valuable resources) without defined specifications in the form of education and experience.

 

[Kevin Mader]

JC,

Looks fine to me too. I couldn't locate a quick link to your email though. You might want to consider adding 'Contact JC...'.

As far as the topic. I would review the Job Description of any associate who would fall back on the "experience or education" angle. I would want to see that it is defined to some extent.

Kevin

 

[Andy Bassett]

Hello John C

I cannot reach you be E Mail, can you contact me.

Regards



------------------
Andy B

 

[John C]

Andy Cheung,

Regards Training Records; Note that the primary requirement of 4.18 is to identify training needs and it states; The supplier shall....provide for the training of all personnel performing activities affecting quality. The second sentence contradicts this to an extent in offering experience as an alternative in specific situations. In such cases, I believe that the substitution of training with experience is not at the discression of the persons implementing the process but of those designing the process. Therefore, either the document says that experience is an alternative or it isn't an option. Either way, there is no argument about the QC Supervisor's position. Either she should have training records or the document says she doesn't need them. If the latter is the case, then she needs a record of the experience.

I take Christian's point about experience; It is important to specify personnel requirements and we don't do it very well. But this leads me to wonder what value is experience, anyway? or training, for that matter? It varies so much that we can't really say without objective evidence. Some of those 30 year men may have been carried by the firm and their colleagues for three decades. The intention of audit is to establish whether the company is capable of producing the goods. What is documented must be capable of being tested and able to stand up to the test.

Process Validation Test is the way to verify whether training and experience is working, along with the other process attributes. If we have to keep training records then it is even more important to keep records of validation of training - on file, in HR. I'm not suggesting the standard requires that. Maybe it should.

rgds, John C

[This message has been edited by Marc Smith (edited 13 March 2000).]