Dean Prigelmeier, President of Proactive Technologies, Inc.
When attempting to comply with the worker training provision of ISO, AS, TS, 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 section provides enough guidance but places the responsibility on the registrant to end any past practices that were inconclusive and open to questions:
A. PERSONNEL
A.1 Training
A.1.1 Are there training procedures that assure personnel performing critical tasks and associated quality and test functions are competent to perform assigned tasks?
A.1.2 Do records indicate that training is scheduled in accordance with procedures, and documented?
B.2 Evaluation of Personnel
B.2.1 Do procedures require periodic evaluation to ensure that approved personnel maintain proficiency in their assigned tasks?.
B.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 4.1 and 4.2. Section 4.1 addresses the underlying training of workers to the processes they are expected to perform and comply. Structured on-the-job training, designed exactly to the written processes or from an analysis of the best practice, will provide the necessary task-based training and documentation for a compliance framework. 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 NADCAP, AS, and ISO.
Section 4.2 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 areas. 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.”
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. 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 4.2, but I am sure they consider that. Nevertheless, any quality program that addresses section 4.2 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 4.1. An audit checklist is not a training tool or a training record in the literal sense. Furthermore, written processes are not training tools or tests. 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 4.1 and 4.2, but audit procedures and checklists cannot. At best, they add to what has already been established for 4.2.
Although Quality Departments tend to view a “quality imitative” 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 which 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 and tracking on-the-job training which should lead to the worker being certified; the Engineering/Technical Writing departments that develop the process documents to which the worker must ultimately comply and, therefore, be able to read and understand.
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.
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