We did refresher training on everything before our first re-certification audit because everything was so new the first time around that it made sense to do a complete review after our first year. For our facility, doing all of that training every year is unnecessary, so this year (our second re-certification), we took another look at everything (and called it a "training needs analysis") and cut way back.
Moving forward, we are using 3 different training frequencies:
- There are some programs that we will only do initial training for new hires and then refresher training as needed (e.g., employee disciplinary process);
- Some programs we will continue to train on annually (e.g., receiving, shipping, GWPs, site security) (or as needed); and
- Other programs we will train on every 3 years (more frequently if something changes or as part of corrective action).
My interpretation of the Code is that we just have to have thought about what is needed and used that information to establish the training system. I outlined our system and why we decided on it in our Employee Training Program document.Go to the full post