Worker Compliance With Engineering, Quality and Safety Specifications; Avoid Audits Without Clear Worker Training/Certification Policy/Program

by Dean Prigelmeier, President of Proactive Technologies, Inc.^®

When attempting to comply with the worker training provisions of ISO, AS, IATF, or Nadcap, it is important to keep in mind the intent of the requirement. The goal should include avoiding an “overshoot” with unnecessary additional work and/or creating an infrastructure that is hard to manage and prone to noncompliance. Often interdepartmental rivalries interfere with logical discussions of how to meet the requirement without creating an internal institution to manage it.

Typically, the guidelines for each of the major quality initiatives listed contains a section that provides a fairly open requirement for worker training to make sure the worker component of the “quality system” is sufficient to ensure that process-based tasks can be performed as designed. If they cannot, the effectiveness of the rest of the quality assurance system will be thrown into doubt. The framework below provides guidance but places the responsibility on the registrant to end any past practices that were inconclusive and open to questions:

A. PERSONNEL DEVELOPMENT AND CERTIFICATION

A.1 Training and Certification

A.1.1 Has all work performance “knowledge” been captured for use in developing and maintaining a consistently compliant workforce?

A.1.2 Are there structured, consistent training procedures that assure personnel performing critical tasks and associated quality and test functions are competent to perform assigned tasks?

A.1.3 Do records exist and indicate that training and certification is conducted in accordance with procedures?

A.2 Evaluation of Personnel

A.2.1 Do training procedures require periodic evaluation to ensure that approved personnel maintain proficiency in their assigned tasks, which might have changed since employee certification?

A.2.2 Do records indicate that the evaluations are performed at documented frequencies and the results reviewed with employees in a program of continuous improvement of personnel?

There are two parts to this process of worker training represented by sections A.1 and A.2. Section A.1 addresses the underlying training of and certification of workers to the processes they are expected to perform and comply. Structured on-the-job training, designed exactly to the written processes, safety requirements and quality standards and/or from an analysis of the best practice performance by subject matter experts, will provide the necessary task-based training and documentation for a compliance framework. It also satisfies the “knowledge capture” requirement of the certification program. A “Workforce Development and Training Policy” should be developed (or amended if already in existence) to clearly guide a more formal implementation, enhancing support for ISO, AS, IATF, and Nadcap.

In addition to the robust improvements this approach provides for developing a worker to comply with processes, procedures and policies in the performance of work, it is the most effective and efficient method of maximizing each worker’s value to the organization.

“An audit checklist is not a training tool nor a training record in the literal sense. Furthermore, written processes are not training tools or tests, they are ‘job performance aids’.”

Section A.2 addresses the requalification of employees which, again, the infrastructure established for section 4.1 compliance can cover thoroughly. This can be formalized in a section of the Workforce Development and Training policy to establish requalification schedules, which can be more frequent for the more critical job tasks and job areas and should include the time a certified employee is away from the tasks for which they are certified, such as job reassignments, personal time off, sick leave. For most quality initiatives this will more than suffice and be easy enough to manage. In this approach, the enterprise does not create too much criteria that may lead to disqualification in the event of “training program neglect,” but enough to ensure compliance.

A quality control department may insist on a requalification process that is more formal and controlled by their department. There is no reason while quality assurance can’t create audit checklists and schedule their own annual audits of employees, but they should be in complete sync with the training and certification program developed and implemented to policy to avoid contradictions and conflicts. It may turn out to be time-consuming to manage and, if not managed properly, cause more harm than good when trying to comply with A.2, but I am sure they will consider that. Nevertheless, any quality program that addresses section A.2 should be described as a policy section in their Quality Compliance Procedures manual, showing a link to the appropriate policies in the Workforce Development and Training policy manual.

This, however, should not be confused with complying with section A.1. An audit checklist is not a training tool nor a training record in the literal sense. Furthermore, written processes are not training tools or tests, the are “Job Performance Aids.” This is the point at which a lot of quality efforts fail regarding worker certification. The quality department takes on more responsibility than their understanding will allow. The Workforce Development and Training policy (and the rest of the document that describes a holistic system to worker selection, training, evaluation) provides quality initiative support of both sections A.1 and A.2, but audit procedures and checklists cannot. At best, they add to what has already been established for A.2.

Although Quality Departments tend to view a “quality initiative” as their department’s domain, many other departments directly influence the process that leads to worker certification, including the Human Resources department which does the hiring and pre-hire testing. The Human Resource Development department should be directly involved in the selection and delivery of related technical instruction (to build a learning base), along with their primary function of developing, oversight and tracking on-the-job training – “peer-to-peer” one-on-one training that is typically delivered informally, unstructured and undocumented without intervention – which, when structured, should lead to the worker being certified. Any job descriptions, pre-hire assessments or post-hire related technical instruction must be based on the job-specific data developed in A.1 to make sure it is accurate and “job-relevant,” for which the data will support “job content validity” and legal defensibility, if needed  The certified worker can then be audited by the Quality Department for compliance with the Engineering/Technical Writing departments standards and specifications embedded in the process documents they develop, and worker compliance confirming the certified worker is able to read, understand and comply.

While the Quality Department does its job best when certifying the worker to compliance with process-driven tasks, it must clearly understand its limitations and allow for experts to provide the task-based training infrastructure development and management…if the organization’s culture will permit.

Contact Proactive Technologies, Inc. for information on how their structured on-the-job training system approach can establish auditable training programs to accelerate the transfer of worker expertise and boost worker compliance. It can standardize process and compliance at your firm, your family of facilities or your region. Contact a Proactive Technologies representative today to schedule a GoToMeeting videoconference briefing to your computer. This can be followed up with an onsite presentation for you and your colleagues.