TS 16949 - Allow Auditor to see Performance Evaluations?

[SteelWoman]

Tom, I disagree with your assertion that, "To me this seems like a company that didn't know how to do this or didn't want to do this any other way so they went the route of employee appraisals." Our company utilizes the performance evals as a measure of competence because THAT'S WHAT THEY ARE - it's an annual/semi annual sit-down to review how capable you are of doing your job, with criteria on the evals that measure on scales how good you are at doing certain aspects of the job. I'm a huge fan of NOT reinventing the wheel or INVENTING a new system purely for the sake of meeting someone's interpretation of the standard. Our MRT reviewed this particular requirement (the competence issue) from the standard, as part of our TS planning, and universally agreed our evals meet that need. So why create ANOTHER, additional program that checks off competence in a way that makes an auditor happier?

 

[Tom W]

While I apologize about making the assumption about your company, you answered your own question. If everyone agrees that the employee appraisals are the method that adresses the evaluation of the actions taken to assure competence, then you would have to show the auditor the evals, not necessarily the detail on the employee but maybe just the section related to competence. If you are using the overall appraisal as evidence of competence, you might have other issues.

Employee apprasials are an ongoing evaluation of how the employee is doing for that period of time, usually beign used to determine wage increases. This does show competence, but do you have a system in place to address (corrective action) when someones rating is lower than the previsous review? The standard requires that you determine the competence required for the job, then take actions to make sure people meet the competence criteria. If you are using the employee appraisal as the only tool to measure competence, then A - it would have to be available for the auditor to review for conformance to the requriements that you established, and B - you would have to have a corrective action system that would address the competence issue directly if evidence showed a decrease in the competence, or even a lack of improvement.

Since this is your situation, I would pose the internal auditor question to you. Has an internal audit ever been done on the competence issue? Did the internal auditor get to review the records? Objective evidence is required, not just hear say. Your system can not say you do something then you as a company take the approach that the auditor is not allowed to verify it based on confidentiality. (Unless there is health realted issues in the employee appraisal form, then confidentiality of the employee is legally required).

Employee ratings on appraisals can go down from time to time based on a lot of different reasons, some may have nothing to do with competence of personnel performing work affecting product quality. This however would still require corrective action based on the measurement of competence being tied to the appraisal.

I am not saying your method is wrong, I do however think there are easier methods to do this without recreating the wheel.

This obviously is a good topic, thanks for bring it up - you have gotten a lot of people interested.

 

[SteelWoman]

In previous audits, both internal and external, we were under QS9000 and the glance at our eval procedure was in relation to "effectiveness of training" - now we're headed toward TS and everyone's making so much of the "competence clause", but it's really not THAT different. In past audits auditors have asked to see evidence that we DID reviews, had training records, and that something was in place for a supervisor to offer/suggest further training if the eval was poor. We actually deliver WRITEUPS with poor evals, and those entail specifc corrective actions that must be taken, along with a re-review date to check effectiveness of the actions. So, yes, those kinds of things are already in place.

 

[db]

In a quality record sense, the organization should record whether folks operating machinery, inspecting goods, or any other activity under the Quality Management System have demonstrated MINIMUM competence to perform the activity. Otherwise, why let them perform the activity?

Why would I need to record this information? If I see that an employee is able (or not) to perform the task I make decisions based on that observation. Why must I generate a record for this, when generating a record is not required, and really serves no purpose?

 

[Tom W]

In previous audits, both internal and external, we were under QS9000 and the glance at our eval procedure was in relation to "effectiveness of training" - now we're headed toward TS and everyone's making so much of the "competence clause", but it's really not THAT different. In past audits auditors have asked to see evidence that we DID reviews, had training records, and that something was in place for a supervisor to offer/suggest further training if the eval was poor. We actually deliver WRITEUPS with poor evals, and those entail specifc corrective actions that must be taken, along with a re-review date to check effectiveness of the actions. So, yes, those kinds of things are already in place.

We just went through our TS2 audit a couple of weeks ago, and they looked into the competence issue a little, but I think they looked more at the workmanship and knowledge of the people interviewed to determine competence. It was not a very detailled look at our system to measure the competance or the effectiveness of the system for competence, so it sounds like based on what you have said that you should be fine as long as your organization is comfortable with it. Thanks for the topic.

 

[Randy Stewart]

In the audit we just completed this very issue was addressed and here is what transpired.
Competence is based upon employee evaluations and there are 2 different paths that these take. First, if it is UAW it is covered by the contract and recorded on a training matrix. Second, all admin and salary personnel are evaluated annually, engineering and program managers have career paths based upon a training matrix. IT and Quality & Ops Eng personnel have specialized applications and have generic training paths.
To show that the reviews are being completed one of the Management Review measurables (monthly review) is "On Time Evaluations".
I did not have to show any reviews and did not have to produce any record other than our Measureable Review Agenda.

 

[Paul Simpson]

Aah .... there is the shall!

Db said: “If I am processing orders, I would expect that I have to process them without error. There is your competency (6.2.2a). Because I have demonstrated (and continue to demonstrate) my ability to process orders without error, you have met the needs (6.2.2 b) and you have evaluated (and are continuing to evaluate) my work, you have determined the actions taken are effective (6.2.2 c). I know how important getting the orders processed correctly is (because you told me), so we filled 6.2.2 d). You have plenty of records of properly processed orders, so you have records of the evaluation (although none are required).
That leaves 6.2.2 e. What are the appropriate records of education, training, skills and experience? I submit that there are no records necessary, in this case. If you sent me to training to learn the software, then it would be appropriate to maintain a record of that.”

Thanks for the example db. I would answer as follows: It is not my responsibility to demonstrate competence it is for the organization to determine what competence is, they set the standard and then evaluate that the person in post meets the requirements.

As such there is a process in place that states what the requirements are and there is evidence that shows that the person meets it. How they set the standard and what form of evidence they require is up to them but there has to be a record to show that Jo meets the competency criteria.

 

[db]

...but there has to be a record to show that Jo meets the competency criteria.

Where is the requirement for a record? However, in my example the record is the "You have plenty of records of properly processed orders, so you have records of the evaluation (although none are required)." My argument is that you can use normal production records to show the action taken to meet the competency requirement was adequate.

 

[Paul Simpson]

Is this so difficult?

I’m not a great one for quoting clause numbers but it seems this thread is coming down to it, so here goes. The responsibility is for the organization to define competence requirements (6.2.2a). So somewhere if the system there needs to be a record that says what those requirements are for a given job.

Then Jo is taken on and, not being competent when they joined, has been through a process of education, training, providing skills and / or experience to become competent at this role. At some point in the process somebody in the organization has decided they meet the criteria. As evidence of the effective operation of this part of the quality system (4.2.4) a record is created.

 

[db]

The responsibility is for the organization to define competence requirements (6.2.2a). So somewhere if the system there needs to be a record that says what those requirements are for a given job.

Where does it say I have to have a record? Where does it say that all "shalls" must be accompanied by a record?

In my scenario, I stated that "If I am processing orders, I would expect that I have to process them without error." Does this need to have a record attached? If so, then wouldn't every decision require some form of documented record? We would spend so much time generating records that we would not have time to make the product!