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Training Competency

  • 1.  Training Competency

    Posted 12-Oct-2017 11:36

    My company is struggling with how to prove training competency for the staff who indirectly affect product quality.


    QA/RA

    Purchasing

    Sales


    Does anyone have suggestions they would be willing to share, or resources to point me in a direction.


    Thanks

    Keri Froese

    QA Manager



  • 2.  RE: Training Competency

    Posted 12-Oct-2017 12:42
    Basic GMP, safety, OSHA, Company policy, etc. training is mandatory to all employees including sales, purchasing, mechanic, cleaner, temporary workers, etc.

    QA/RA - All SOP in the company, directly or indirectly they are working on it.

    Purchasing - Production SOP, inventory management, material receiving, etc.

    Sales - Basic GMP, safety, OSHA, Company policy, etc.

    ------------------------------
    Gaurang Bhavsar, MS, RAC
    Scientist-II, R&D and RA
    Sunrise Pharmaceutical, Inc.
    Rahway, NJ 07065
    USA
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  • 3.  RE: Training Competency

    Posted 13-Oct-2017 11:35
    I agree completely.  It will be imperative that there is documentation in each person's file that they have completed the requisite training.  This information should also be stored with the employee files/training records with the QA group.  

    Ensure all records are up to date and as a QA group, verifying the correct training and updating as necessary will also be critical to ensuring people who are either directly or indirectly involved have the appropriate training.

    Sandra Bihary-Waltz, DBA(c), MSN
    Senior Strategic Consultant
    Sam Waltz & Associates
    Greenville, DE 19807

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    Sandra Bihary-Waltz MS
    Greenville DE
    United States
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  • 4.  RE: Training Competency

    Posted 20-Oct-2017 04:03
    Edited by Mark Swanson 20-Oct-2017 04:13
    Hi Gaurang,

    Please take a look at Dan's post. While there are regulations that require training, the 2016 edition of ISO 13485 does not require training for these. The requirement in ISO 13485 is for the organization to have procedures to establish (achieve and maintain) competence of personnel affecting product quality. Training just is one of the possible actions to meet this requirement. In the past, the focus has been on the training as this is an item that you can provide a document (list of training completed). This is not the right focus, but we want to know that the people know how to do their job (the right focus).

    ------------------------------
    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE MBA
    Becker MN
    United States
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  • 5.  RE: Training Competency

    Posted 13-Oct-2017 08:17
    This can be a challenging question. One of the "easiest" ways, from a proof point, is to have short quizzes about SOPs, that show at least comprehension. Obviously though, it can be burdensome to create quizzes and track results.

    Another way, but also resource intensive, is to "audit" their work, and document the results. This can be done by a manager or an independent function.

    I will be interested to hear the ideas from others.

    g-

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    Ginger Glaser RAC
    Vice-President, Engineering
    MN
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  • 6.  RE: Training Competency

    Posted 13-Oct-2017 11:13

    I infer the context is ISO 13485:2016 clause 6.2 which requires three activities:

    • Determine the necessary competence for personnel performing work affecting product quality
    • Provide training or take other actions to achieve or maintain the necessary competence
    • Evaluate the effectiveness of the actions taken

     

    The standard doesn't make a distinction between personnel who directly affect product quality and those who indirectly affect product quality.

     

    I also infer that the question relates to evaluating training effectiveness, not determining the need for training. Employees need to be competent on the basis of appropriate education, training, skills, and experience. You must have a process to establish competence; the most common way is a job description that includes the required training to perform that job. A gap analysis between the required training and a given person's actual training (based on the training records), identifies needed training.

     

    It is usually easy to provide the training, but this leaves open the training effectiveness question.

     

    The newly published ISO 13485:2016 Handbook offers some methods to "evaluate [training] effectiveness based on the risks associated with the work for which the training or other action is being provided:

    • Surveying the trained personnel to assess whether he or she feels they have learned the required information
    • Testing or questioning the trained personnel to assess their competence using objective criteria
    • Evaluating the work performance of the trained personnel
    • Reviewing the trainer assessment of training effectiveness

     

    ISO 10015:1999 Quality management – Guidelines for training provides a comprehensive system that works well. Clause 4.5.1 says, "The purpose of the evaluation is to confirm that both organizational and training objectives have been met, i.e., training has been effective." It recommends evaluation on both a short-term and a long-term basis. In the short-term, use trainee feedback information on the training methods, resources used, and knowledge and skills gained as a result of the training. In the long-term, assess trainee job performance and productivity improvement. In addition, Table A.4 provides suggestions on the inputs, process, outputs, and records for evaluating training outcomes.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 7.  RE: Training Competency

    Posted 17-Oct-2017 09:01
    Yes, you are right I am finding it a challenge to look at showing training effectiveness, mostly for QA (since I am QA). How do I show that I am effective at my job.

    Any help is appreciated.

    Keri

    ------------------------------
    Keri Froese RAC
    Quality Assurance Manager
    Spartan Bioscience
    Dunrobin ON
    Canada
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  • 8.  RE: Training Competency

    Posted 18-Oct-2017 07:54

    I think you have raised a second issue.

     

    The first is training effectiveness, in which one is trying to determine if people learned things from the training that would maintain or improve skills, performance, etc.

     

    The second is individual effectiveness. This question is independent of, but perhaps influenced by, training effectiveness. For example, I could have a job for which I attend training to maintain a skill or knowledge. Perhaps it is annual QMS refresher training. If the trainer were to do a poor job, and I don't learn anything, I could still be effective at the job. On the other hand, if the trainer were to do a good job, I still might not learn anything new. I am already effective at my job and the training reinforced what I already know.

     

    As often happens in these cases, there are four possible states for any given person and training. The training is effective, Yes/No. The person is effective, Yes/No.

     

    The usual tool for a person's effectiveness is the performance review. In an earlier post, I described some tools for training effectiveness.



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    Dan O'Leary
    Swanzey NH
    United States
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  • 9.  RE: Training Competency

    Posted 19-Oct-2017 07:13
    Dan you always do such a good job explaining things clearly.  Thanks for your contributions.  

    Mark DuVal, President & CEO
    DuVal & Associates, P.A.



    Sent from my Verizon, Samsung Galaxy smartphone





  • 10.  RE: Training Competency

    Posted 20-Oct-2017 04:10
    Hi all,

    I would still go back and focus on the requirement to document procedures to establish and maintain competence. We need to shift the focus away from training as this is just one action that can be taken to establish and maintain competence.

    ------------------------------
    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE MBA
    Becker MN
    United States
    ------------------------------



  • 11.  RE: Training Competency

    Posted 13-Oct-2017 15:29
    ​Keri,

    We use a matrix that defines the competency, skill, or training (C/S/T) needed, who (by position) it applies to, how often, and to what level of C/S/T is required (intermediate, advanced, etc).  We then document the attainment of the levels in their training records.  Finally, we have a training needs assessment for each employee that describes there position responsibilities and tasks, whether they already possess the C/S/T or if they need further development to reach the level specified in the C/S/T matrix.  We then schedule them for training, OJT, etc to develop that C/S/T.  Once again, that training, etc is logged on the employee's training record.  Also new skills get reported on the training needs assessment and incorporated into the C/S/T matrix by position.  All of this is validated by management with input from the employee.

    Within the training program there are the typical evaluation methods used (test, practical application, etc) to show attainment of the knowledge level intended.

    An approach among approaches.

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    William Coulston
    Quality & Regulatory Affairs
    Rochal Industries LLC
    San Antonio TX
    United States
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  • 12.  RE: Training Competency

    Posted 20-Oct-2017 04:40
    Edited by Mark Swanson 20-Oct-2017 04:45
    Hi Keri,

    It seems to me that people are making this too hard. I would advise that you keep focused on the requirement. The first part is to determine how to establish competence (not prove competency, but provide verifiable evidence that your organization takes action do this through a process). This should be a natural skill of a manager (or other supervisor). We all know when there is a job to do who we would rely on to do the job well. There are others that we might say, "they are not the right person for that job". This likely means there is a gap in competence. We should then work to close that gap. You have to get used to the fact that people will have gaps (after all if you have complete competence to all job responsibilities, you are either ready to get promoted or really bored and about to leave).

    A method I recommend is to form a competence file (similar in nature to what you have likely done in the past with a training file). In this file you have:
    1) a description of their job responsibilities
    2) current information on their experiences and skills (perhaps a resume or CV)
    3) identification of education and training (including any certifications)
    4) a summary statement by a manager or supervisor assessing their competence that is periodically updated (risk based approach)

    As stated above, a competence of a manager or supervisor should be their ability to assess competence of the personnel in their area and this can then be one of the items the next level manager or supervisor assesses for them. You can do this throughout your organization. In this way, you are assessing the competence of all personnel affecting product quality.

    In addition, you can assess the effectiveness of actions taken (for training or those other actions) by having a manager or supervisor assess them after they have completed the action. Maybe they ask them questions or observe their performance of duties or any way they feel the can assess them (that is their competence as a manager or supervisor).

    For any audit, you must provide audit evidence to support this. I would advocate that perhaps you also keep some sort of data that indicates competence (looking for mistakes). This could be items like documentation mistakes (GDP) or audit findings for their area of responsibilities or other items that indicate a gap to competence. I don't recommend the use of performance reviews as this can draw concerns on confidentiality of that information (as an auditor, I did ask to review a performance review during an audit as the organization insisted that was how they showed competence...they changed their practice after).

    In the end, it is what your organization believes is a sufficient control to adequately mitigate the risk (risk based approach) of having people that are not competent that will determine the actions you take. Remember also that you use the process approach (PDCA) and then look for improvement opportunities so you might not get it right from the beginning, but through improvement, you will. Good luck!

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    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE MBA
    Becker MN
    United States
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  • 13.  RE: Training Competency

    Posted 13-Dec-2017 11:42
    Mark- 
    I am a little late to the party on this one, but I am wondering if you have any input on this:

    I am planning to reference initial CV vs. Job Description for establishing competence; training records for 'maintaining' and QMS (orientation) training; and performance reviews for continued evaluation/effectivity.

    I see you suggest not referencing performance reviews, but does this include for effectivity?  Would an auditor really need to see performance reviews in this case as well?


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    Emilia Gonzalez
    Lyndhurst OH
    United States
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  • 14.  RE: Training Competency

    Posted 14-Dec-2017 06:10
    Competency (as part of job requirements) is related, as the ISO 9000 definition, to the demonstrated ability to apply knowledge and skills to achieve desired results.

    Defining and evaluating (including evaluation the effectiveness of actions related to competency) depends on the objects of the application of knowledge and skill , but I would take care with determining the objectives. Job creation and competency/training evaluation is part of the human factors engineering field (unfortunately most implementers do not know this or the HFE area), and should be backed by activities such as task analysis and the like.

    To developing training, there's several known methods (known as Intructional System Design) in the HFE literature. One that I use and find is great is the ADDIE Model used by the military - http://www.nwlink.com/~donclark/history_isd/addie.html.

    Then, depending on what you need to train, there's several techniques for evaluation, for example, take a look at the TOC of this book: Amazon.com: Handbook of Task Analysis Procedures (9780275926847): Wallace Hannum, David H Jonassen, Martin Tessmer: Books, it has examples of techniques for learning analysis, job/skill/behavior analysis techniques, and subject matter/content analysis techniques. So, depending on the objective of the training (analyze learning, analyze  job/skill/behavior, etc.) you may use one or more of those techniques.

    CVs and job descriptions are marketing tools used to hire people. They have nothing to do with competency (unfortunately most implementers and auditors do not know this :-). 

    Performance reviews are related to results, but not to the application of knowledge and skill. So they are really not related to competency.

    (please note that CVs, jobs description and performance reviews "can"be related to competency if someone includes real competency requirements in them, even if the usual ones are not related to competency, however, as mentioned, their focus is not competency definition or assessment).

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    Marcelo Antunes RAC
    Regulatory Strategy Consultant
    SQR Consulting
    Sao Paulo
    Brazil
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