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7.2 Competence: How much documentation is needed?

Discussion in 'ISO 9001:2015 - Quality Management Systems' started by John Apostoli, Sep 20, 2016.

  1. John Apostoli

    John Apostoli New Member

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    In terms of 7.2, d) just wondering what an registration auditor might be looking for in terms of evidence of competence. For example, let's assume we hire to predefined criteria (experience, education, certifications, etc.) and collect records to demonstrate. In-house training is given and at the end of a specific period an overall job performance evaluation is done. The evaluation is simply signed-off on a log adjacent to the persons name and position. Is the signature adequate, or does the record require the criteria for the evaluation and the specific results documented. This could be documented evidence of work samples, witness of work, interviews, work history, etc. How much documentation is needed?
     
  2. Andy Nichols

    Andy Nichols Moderator Staff Member

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    We can't tell you what an auditor will ask/look for! Every one is different and some have better understanding than others. Competence is defined as "the demonstrated ability to apply skills and knowledge", so you need to have something recorded to that effect...
     
  3. hogheavenfarm

    hogheavenfarm Well-Known Member

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    The corollary to Andy's statement is you also need to show NO evidence that somewhere along the line "skills and competence" caused a problem. In other words, if your customer feedback (from NCR's, CARS, or whatever) show that you have recurring issues with welds, you had better check out how you determine competence in the welding department! If you simply depend on a certificate, but the results are not satisfactory, your company has a problem determining competence and is relying on 'unreliable' and unverified data.
     
  4. RoxaneB

    RoxaneB Moderator Staff Member

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    Being the type of person who believes that there are always at least 3 options, I blend the approaches from both Andy and hogheavenfarm. Having resumes and certificates and signed training documents is all well and good, but, let's be honest...we all drive the car according to the law when there is a police car behind us. In other words, we're all on our best behavior during training and follow the procedures/instructor. There is a term for this...can't remember it...but I fully expect Andy to know the term I'm looking for (no pressure!).

    Once training is over and we're in the "real world", things don't always work out the way the procedure is outlined. This is where hogheavenfarm's approach comes in. We analyzed our nonconformances down to the crew (sometimes individual) level - this could be impacted by employee and/or collective agreements. In some cases, formal training was provided. In other cases, one point lessons or process alerts were communicated. In other cases, processes and/or procedures were changed because people were doing things BETTER than we had originally trained them on.

    This may sound like a lot of work, but it does add value in my opinion. Not only did we train to a standardized process, our assessment and analysis led to identifying gaps or slips in competency and, in some cases, process improvement.
     
  5. Eric Twiname

    Eric Twiname Well-Known Member

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    I'm not Andy, but it is often referred to as the "Hawthorne Effect" or "Observer Effect".
    Werner Heisenberg just got totally left out of it this time...though his "Principle" is sorta similar...
     
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  6. askartsolutions

    askartsolutions Member

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    Here is my take on this topic. Clause 7.2 requires:
    1. PLAN - Determine competency requirements which your organization should determine far better than any external auditor.
    2. DO - Determine the effectiveness of competency through demonstration or other means.
    3. CHECK - If employee performance (through resulting n/c's and other evidence) fails to meet established product and competency requirements,
    4. ACT - then remedial actions must be taken.
    5. So the "documented information" required would be a) competency criteria as established by your org; b) performance data on the activity or process that the the employee is engaged in (e.g production records); c) evidence of remedial training or reassigment, etc for non-competent performance.
    6. Always keep the PDCA cycle in mind in developing your QMS.
     
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  7. tony s

    tony s Well-Known Member

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    7.2c requires evaluation of the effectiveness of the actions taken. If we dissect "effectiveness" it has two parts: planned results that must be achieved AND planned activities that must be realized. So if we are to evaluate effectiveness, we have to be clear of the "planned results" in providing the necessary action/s or intervention/s to address competency needs. Documenting the evidence of reviewing whether the "planned results" are achieved after provision of the necessary action/intervention (i.e. planned activities) will satisfy the documented information requirement on 7.2c.
     
  8. askartsolutions

    askartsolutions Member

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    If an employee is not sufficiently competent as required by clause 7.2a and b, then clause 7.2.c calls for remedial actions (perhaps refresher training or reassignment) to be taken to bring that employee up to speed or find someone else who can to do QMS work effectively. Whatever remedial course of action is taken, (in this case the refresher training or assigning another competent employee), it must be evaluated for effectiveness in terms of achieving QMS performance requirements. The remedial course of action and its effectiveness must be documented.
     
  9. Andy Nichols

    Andy Nichols Moderator Staff Member

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    This is why, IMHO, the requirement for competency and not simply training is so good. Organizations can waste a lot of money "training" without any useful goal in mind - I've personally witnessed a requirement to fulfil 40 hours training annually and people have gone to the same 40 hr course 2 and 3 times. What a waste...
     
  10. dibdab

    dibdab Member

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    Bear in mind the need for ongoing checking to confirm that eyesight etc. has not deteriorated and that measuring equipment, comparative standards continue to be accurately used
     
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  11. callmechuck

    callmechuck Member

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    We have a few training requirements that I know of no other way to evaluate the effectiveness of other than waiting to see if something goes sideways. For instance we have an image and data policy that specifies how/where photos and data are stored on the network that we require employees to be trained on. I can look through folders to see if it looks like things are in order but I probably won't find a problem until someone complains or an audit uncovers missing or mislabeled files. Another is the QMS training for new hires, I don't really know if they "got it"unless something happens to uncover a weakness or lack of understanding. I see these things as hard to measure but maybe there is a simple solution I'm missing.
     
  12. Andy Nichols

    Andy Nichols Moderator Staff Member

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    You may be confusing awareness, education and training. No-one needs training as a new hire, on the QMS. The best you can do is make them aware. No-one develops skills on day 1.
     
  13. callmechuck

    callmechuck Member

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    Yes, I think I may be.
    Thanks
     
  14. callmechuck

    callmechuck Member

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    After giving Andy's reply more thought I realized that the image and data policy was a good example of where I have been veering off track. Anytime a policy is released or changed everyone is made AWARE by email announcement at the very least, If it is the product of a CA or IA I may follow up with special instructions. After this policy was released it was obvious that people were not following it, we revised it and made all aware again and still saw issues with compliance. That is when I decided to treat it more like training and require everyone to sign a record that they had read and understand the policy. We are not ISO certified yet and employees are at different levels as far as being "on board" and doing their part. The QMS training I referred to is, as Andy mentioned simply making new hires aware of our quality policy and their role in contributing to the QMS. It's not really a training either but sometimes people don't do things that they have been made aware of and it causes problems, I was trying to fix this by verifying that they got the message. I would like to know how others develop confidence that when people are made aware, that they actually are aware.
     
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  15. RoxaneB

    RoxaneB Moderator Staff Member

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    One size does not fit all when it comes to awareness, competence, and training. For some items, sure, an email is just lovely. For other items - such as those that have more of an impact on the organization's ability to consistently meet requirements and/or support risk mitigation - well, an email might not be enough...and maybe having them read a document isn't enough...or maybe it is. It really depends on the topic, the nature of the change (if we're talking a revision here), the connection to the stakeholder, etc.

    This is why the generic nature of the standard is so wonderful...it tells us WHAT to do...not HOW to do it. That being said, it is this same generic nature that causes overthinking.

    How do I know folks are made aware? Because there are no issues...no complaints, no nonconformances, no out-of-control (i.e., outside of control limits) results/outcomes, no audit findings...and, depending on the topic, I probably have some sign-off that they've been trained.
     
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  16. RoxaneB

    RoxaneB Moderator Staff Member

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    As with all things Business Management System, what's important is to ensure the requirements fit your organization, not the other way around. Many of us have a tendency to create systems that are unwieldy and cumbersome, focusing only meeting requirements and keeping auditors happy. Then we wonder why people refer to us as "necessary overhead" (not a lie...I have been called that). What we need to remember is that this about ensuring our systems and processes add sustainable value to the organization and all applicable stakeholders.

    This includes training and awareness. Don't limit yourself to emails or classroom training - consider on-the-job training, e-modules, one point lessons, and so on. And, depending on the topic AND the audience, there may be multiple training methods employed. I have a particular topic where it's simply an email to some, but full-blown, 2 hours of interactive classroom time for others, all because of their role within the topic.

    Organizations are in business to make money - if we don't help contribute to that achievement, why do they need us?
     
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  17. callmechuck

    callmechuck Member

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    That makes a lot of sense and when thinking of it it that way, I was kind of heading down that path by trial and error. I guess a lot of it comes down to organizing so that when a requirement crosses over from awareness to required training, records of the training are retained for evidence. I have never heard the term "one point lesson", that is an interesting concept. Thank you for the input!
     
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  18. RoxaneB

    RoxaneB Moderator Staff Member

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    Full disclosure - We usually employed this approach *after* a discrepancy/nonconformance had been detected. However, rather than re-teach on the whole process or activity, a one-point lesson focuses only just that...one point. It shows the incorrect way to do something and the correct way - well, that's how we used them.
     
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