ISO 9001:2015 – Newsletter – Issue 128

Issue 128 – What are the requirements for Training and Competency?

ISO 9001:2015…

What are the requirements for Training and Competency?

I appreciate receiving emails with questions and/or comments from readers of this Newsletter… please continue to do so since it provides me with ideas on what these publications should cover.  In my last Newsletter (ISO 9001:2015 Newsletter Issue 127) we discussed the topic of  “What Exclusions or NA’s can I take (Clause 4.3)?”, and now in this Newsletter we will discuss “What are the requirements for Training and Competency?”.

The ISO 9001:2015 Element numbering…

Element 4 – Context of the organization
Element 5 – Leadership
Element 6 – Planning
Element 7 – Support
Element 8 – Operation
Element 9 – Performance evaluation
Element 10 – Improvement

Training and Competency requirements?…  One of my Newsletter Readers was kind enough to take the time to send me an email suggesting this topic.  The reason he thought “train-the-trainer” qualifications would be a good topic was due to some interesting interpretations being made by his Auditors with regards to the qualifications of the Trainer who performed various training events in their company.  In one instance, the Auditor insisted on seeing the qualification of a “Trainer” for a piece of equipment… and then who trained that “Trainer”… and then who trained that “Trainer”… and so on… and so on… all the way back in time, in order to demonstrate traceability right back to the manufacturer’s training on this particular piece of equipment.  To make matters even more challenging, this piece of equipment had already been installed at the time when this building was purchased by his company!

The second instance, was in regards to an Auditor insisting that forklift drivers had to be trained by an outside company who specialized in forklift training.  I’ll add a third example of my own from one of my Client’s who were being challenged with questions like “Who performed your internal auditor training?” and “What are the qualifications of the Trainer who performed this internal auditor training?”… essentially implying that Internal Auditors had to be trained by an outside ISO accredited training organization (… and let’s not forget that “training” is a big revenue generator for these external ISO Registrars, so when they see an organization using a DIY approach they challenge it).

So what exactly does the ISO 9001 Standard say?…  There are actually two (2) primary Clauses that cover this topic.  The first place is found in Clause 7.1.2 (People), which states: “The organization shall determine and provide the persons necessary for the effective implementation of its quality management system and for the operation and control of its processes”.  Which basically means, figure out what type of people are needed within your QMS… and then find those people and put them in place… or as I sometimes say, put round pegs into round holes.

The second place is found in Clause 7.2 (Competence), which states: “The organization shall: a) determine the necessary competence of person(s) doing work under its control that affects the performance and effectiveness of the quality management system; b) ensure that these persons are competent on the basis of appropriate education, training, or experience; c) where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken; d) retain appropriate documented information as evidence of competence”.  By the way, the word “training” only shows up ONE (1) TIME in ISO 9001:2015 and it is here in Clause 7.2… nowhere else.  Essentially Clause 7.2 wants you to have a way to keep those “people” (that you identified back in Clause 7.1.2) competent while they are performing the jobs they have been assigned to within your QMS.

The ISO 9001:2015 Standard allows you lots of flexibility on how you demonstrate competency for those people doing a job… AND for how you decide who gets to train them (i.e. the qualifications of the Trainer).
The three (3) audit scenarios mentioned above are extreme examples of how far an External Auditor can stretch their interpretation of the “shall” requirements.  In the last example, I reminded my Client that there are no ISO requirements to train internal auditors but rather that he ensure they are “competent” when they conduct internal audits.  My Client could have simply said that based on his opinion his internal auditors were “competent”… and then documented that decision in an email or some other type of record… and he would have met the “shall” requirements in ISO 9001.  The same also holds true for “train-the-trainer” qualifications… my Client can also simply proclaim that based on his opinion, Person A is competent to train/teach Person B… period… end of discussion… and of course, document that decision to satisfy the requirement found in Clause 7.2 (d).