14 replies to this topic

[SpursGirl]

Hi all,


Once again I am floundering around trying to understand the requirements of the SQF code and the expectations of the auditors - this time around training evaluation and competence sign off - and I was hoping someone here could help me out with some clarification.

The code requirements for the training matrix/register states that: "A training skills register describing who has been trained in relevant skills shall be maintained. The register shall indicate the participant name, skills description, description of the training provided, date training completed, the trainer or training provider, and the supervisor's verification the training was completed and that the trainee is competent to complete the required tasks."


My question is what is the requirement for verification of trainee competency? The guidance notes do not give any indication of what the verification should look like but the auditors I have had audit my 3 sites have all expected some kind of quiz following training. I agree with this on system element training such as pest control awareness, GMP standards, allergen awareness etc etc, and I do have documented quizes for all this style of training with a defined pass/fail mark. The area where I am struggling to understand requirement vs expectation is on specific task training against work instructions/SOP's and evaluation following this. I have literally hundreds of SOP's in my QMS covering all the tasks carried out in the factory - ie using a knife, cleaning the oven, checking vehicle cleanliness, finished product weight checks - and my evaluation of competency for these types of training against a SOP is basically observation by a supervisor/trainer. CCP tasks are evaluated by observation and specific audit questions around the critical limits and deviance process. However the auditors were expecting a quiz for each person trained against all of the procedures trained which I dont believe is the requirement - what is the view of other SQF users? And if you do perform quizes for every task trained how do you manage to find the time to do this?!


Thank you in advance!

Sarah

[esquef]

Hi SpursGirl,

The way I understand it is that verification of training is the record keeping portion of your defined training program. This consists of what training is done, who receives it, how often and when, and employee's signatures demonstrate that they received the training as prescribed in your SQF policy and procedures. SQF loosely defines verification as how you prove that you are doing what you say you are doing.

Validation can accomplished via a quiz. This shows that the training was effective, and with SQF validation means that you're proving that what you're doing is effective. It sounds like your question involves the scope of training validation. I don't beleive that all training needs to be validated (i.e. specific SOP's or SSOP's). If you validate (quiz) on the "big ticket" items such as cGMP's, Food Defense, HACCP, Allergen Control, Employee Hygiene, Waste Disposal, Sanitation, etc. I would think you'd be covered.

Job specific task training can be covered with an "On the Job Training" program where the verification would be the employees sign off that they received the training (we do ours by having the supervisors train small groups of line employees right on the floor) and validation would simply be the observation of the supervisors ensuring that the employees were following the training requirements.

Hope that helps,
esquef

[bacon]

And if you do perform quizes for every task trained how do you manage to find the time to do this?!

I am working on the same thing. Quizes are clever way tackle the problem, however, the use of quizes to "verify" training can be excessively bureaucratic in managing all the training requirements of 150+ employees (or even less). With BRC in the past, I have tacked it by having an extra "verification" trainer initial when they feel that the employee is "competent" in understanding. This was a "work-in-progress" rationale and I hear the last auditor that evaluated that training system (I am working for another company now) said it was weak.

But to counter that argument: the burden of training is placed on the effectiveness of the training; the "verification" initial of the trainer IS verification (who knows more about how the work works than the people doing the work?) Now, it is the auditor's job is to randomly interview... I have a matrix that provides: "name, skill, date training completed, trainer/supervisor’s verification. * job description used (written or on-the-job training) provided in manual."

Per SQF, this training matrix satisfies clause 2.9.7.1:
i. Participant name;
ii. Skills description;
iii. Description of the training provided;
iv. Date training completed;
v. Trainer or training provider; and
vi. Supervisor’s verification the training was completed and that the trainee is competent to complete the required tasks.

Hope this is helpful.

Not perfect but this is how I am going about it as I refuse to implement bureaucratic measures that are NOT effective. I stand behind training 100%, but effective training. One can have the "paperwork" and "check" it off as "verified", but yet still have horrible employee GMP's. It is up to the auditor to test(quiz) ones training program; if a training program is faulty, so be it, and CA's on it will further improvements.

I think many would value other feedback on this.

Cheers

[SpursGirl]

Thank you for your feedback - it is always good to hear the views and experiences of other people.


I do have a training matrix that absolutely covers the elements of the SQF standard and I do perform quizes on the big training modules (GMP, HACCP, Pest Control, Allergens etc) but the last auditor I had very definately wanted quiz type verification for ALL training. She wanted documented Q&A for things such as hand-washing, PPE change procedure, pH testing. I currently have a sign off by both trainer and trainee post training as verification of training completion and perform the verification of these with observation and sign off by a supervisor but she wanted more than that.

I dont beleive that quizes for these type of activities are:

a) required by the SQF standard

b) effective

c) practical/managable

Has anyone else had this kind of request by an SQF auditor or is it just a case of an auditor setting their own requirements/expectations?


Thanks again!


Sarah

[bacon]

I dont believe that quizes for these type of activities are:
a) required by the SQF standard
b) effective
c) practical/manageable

Quizzes are a novel attempt at "validation" it seems. However, quizzes are NOT required by the standard: per page 22, 1.9 - "The guidance documents are available to assist the supplier, but are not auditable documents. Where there is a divergence between the guidance document and the SQF Code, the SQF Code prevails." even if the auditor would point to a guidance document.

So if one has a different way of establish validity of ones training program, you dont have to be stuck with quizzes for everything.

Look at clause 2.9.1.1:

"Appropriate training shall be provided for personnel carrying out the tasks critical to the effective implementation of the SQF level 2 System and the maintenance of food safety and regulatory requirements.

i. Developing and applying Good Agricultural Practices, Good Aquaculture Practices, or Good Manufacturing Practices (as appropriate).
ii. Applying food regulatory requirements;
iii. Steps identified by the hazard analysis and/or other instructions as critical to effective implementation of the food safety plan and the maintenance of food safety; and
iv. Tasks identified as critical to meeting the effective implementation and maintenance of the SQF System."

i.e. - An employee who is being trained to make sure the eviscerated body cavity of a fish is clean only needs on-the-job demonstrated training as "appropriate" for carrying out the task. Verified by the supervisor who trained them. Validation could be assess at a later date and judged to be "competent" by the said trainer/supervisor (some BRC auditors were satisfied with this).

For more complex training "big ticket" items, as esquef had mentioned, like pest control and pesticide/chemical handling or CCP's, more detailed documentation/certs or even quizzes can be used (and more manageable by having merely less authorized employees). A machinist with 40+ years on-the-job experience in in control of CCP's can arguably be validation enough.

Edited by baron, 23 October 2012 - 07:34 PM.

[Cobus]

Hi Sarah

I am not familiar with SQF as it is a standard that is not very prominent in our country.

My perspective as an auditor is as follows when it comes to verification of training of SOP's.


I would accept visual observation by a qualified person as a valid method of verification of effectiveness of training as long as
this is clearly documented and more importantly the observed behavior (during the audit) of the person is competent. I also establish competence by interviewing an employee about his work methods and then verify this by studying the SOP.
I our country we have a fairly large part of our workforce that cannot read or write so this method in used widely.

Have a great day

[bacon]

My perspective as an auditor is as follows when it comes to verification of training of SOP's.

I would accept visual observation by a qualified person as a valid method of verification of effectiveness of training as long as this is clearly documented and more importantly the observed behavior (during the audit) of the person is competent.

I also establish competence by interviewing an employee about his work methods and then verify this by studying the SOP.

I our country we have a fairly large part of our workforce that cannot read or write so this method in used widely.

Have a great day

Absolutely Cobus! Great example. Thank you for that feedback!

[SpursGirl]

Thank you all for the feedback!

I am going to stick with the system I currently have which appears to be very similar to the systems you guys use in your businesses.

Should I get any issues around this in my next SQF audit I will let you know - and if anyone comes up against anything related to this in their SQF audit I would be really interested to know the outcome.


Many thanks again for all the sage advice

Sarah

[Urban Explorer]

I had this issue come up and I am a bit flustered about it.

The auditors "interviewed" several employees on the manufacturing floor, where it is loud and noisy. They didn't ask whether the employee spoke English and didn't ask me to provide a translator for them. Our workforce is made up of mostly people that can understand basic instructions in English. Of course most of them couldn't answer them satisfactorily.

I found this to be unfair and I was under the impression that they had to communicate themselves effectively. Our training is done with translators of their individual languages.

I then asked, what if they are illiterate in their own language? For instance, many of our Spanish speakers cannot actually read Spanish. So me going through and translating every training document into Spanish is a waste of time. Not to mention the more obscure languages. In this case, a signed quiz is just as much of a waste of time.

[Charles.C]

I had this issue come up and I am a bit flustered about it.

The auditors "interviewed" several employees on the manufacturing floor, where it is loud and noisy. They didn't ask whether the employee spoke English and didn't ask me to provide a translator for them. Our workforce is made up of mostly people that can understand basic instructions in English. Of course most of them couldn't answer them satisfactorily.

I found this to be unfair and I was under the impression that they had to communicate themselves effectively. Our training is done with translators of their individual languages.

I then asked, what if they are illiterate in their own language? For instance, many of our Spanish speakers cannot actually read Spanish. So me going through and translating every training document into Spanish is a waste of time. Not to mention the more obscure languages. In this case, a signed quiz is just as much of a waste of time.

Dear Destinee,

Our workforce is made up of mostly people that can understand basic instructions in English.

perhaps i misunderstand but i assume you mean "can understand (only) basic.... ?

Are you mainly referring to auditor queries with respect to basic hygiene issues or including HACCP aspects, etc ?

It seems highly unlikely that SQF demands employees must be fluent in English (?) in which case I agree with you. IMEX with non-English speaking workers, the auditor simply used their language or communicated via an interpreter. If this was not possible i would probably hv stopped the audit due to it being a waste of time for both sides.

As far as lack of reading ability goes,-

(1) basic hygiene is, i think, auditorialy accepted as being communicatable via spoken / visual methods and it seems to me that allowance for this must be compromisable within the FSMS set-up. Internal audits should verify the effectiveness.

(2) for verbal + video hygiene instruction follow-up, i have used pictorial based Yes/No quizzes.

(3) For HACCP aspects as mentioned in my post in yr other current thread, this does seems to be a significant constraint. If widespread, i don't hv any ready solution except via specific nominees which might not conform to SQF sampling rules. I'm interested to hear how other people, and auditors?, handle this.

Rgds / Charles.C

[Urban Explorer]

For our hygiene training, I found some cartoon pictures from a Canadian Food Inspection Agency of employees practicing bad GMP habits. Our employees were asked to circle the bad habits. To my surprise, most everyone found the majority of the errors without me coaching them, indicating that they do understand.

Like I said, I believe it was a combination of the environment, the language barrier and the employees' nervousness. We spoke to all of them the day before about it, but it either didn't register or they were playing dumb.

[bacon]

I had this issue come up and I am a bit flustered about it.

The auditors "interviewed" several employees on the manufacturing floor, where it is loud and noisy. They didn't ask whether the employee spoke English and didn't ask me to provide a translator for them. Our workforce is made up of mostly people that can understand basic instructions in English. Of course most of them couldn't answer them satisfactorily.

I am about to help a company go thought its 2nd SQF audit, and I have the same concerns with "competency interviews". But (as i read from your other post, if a NC kicked you out of passing), I would protest by petitioning SQFI. BRC does have that option to challenge a CB's evaluation, but I don't know if SQF has this option (it would think it would....)

-B

Edited by baron, 07 January 2013 - 08:05 PM.

[bacon]

I am about to help a company go thought its 2nd SQF audit, and I have the same concerns with "competency interviews". But (as i read from your other post, if a NC kicked you out of passing), I would protest by petitioning SQFI. BRC does have that option to challenge a CB's evaluation, but I don't know if SQF has this option (it would think it would....)

-B

See attached for handeling “Appeals, Complains and Disputes”.

Our CB only referenced the procedure but did not provide us that document. One nevery really wants to go down that route, but if one must, your CB should have provided you one.

-B

Attached Files

•  Pages from Criteria-for-Certification-Bodies-7-24-12.pdf   49.5KB   350 downloads

[scole]

For our hygiene training, I found some cartoon pictures from a Canadian Food Inspection Agency of employees practicing bad GMP habits. Our employees were asked to circle the bad habits. To my surprise, most everyone found the majority of the errors without me coaching them, indicating that they do understand.

 

Would you have a link for that?  I have been searching for some fun ways to "test" our refresher training. 

[fgjuadi]

Would you have a link for that?  I have been searching for some fun ways to "test" our refresher training. 

I showed our guys this clip and asked what was going wrong to break the ice before our refresher training.  It was pretty fun, but I work in a chocolate factory, and most of our employees hadn't seen it yet.     

 

 

The description says it's good for training lean manufacturing as well, so two birds there.