6 replies to this topic

[That Guy]

Do I require training on policies, programs and procedures that I wrote?

 

For example, I wrote all of the GMP policies and procedures and the training coordinator is responsible for training all personnel to these policies and procedures. She has included me in the training list and I am not sure if this is necessary. I think that I would be covered if it is clearly documented that I wrote the policies and procedures.

 

 

In addition to that,

there is no training record showing that the training coordinator has been trained. (No Train-the-Trainer Record).

Is a record like this required? Would the author of the policy/procedure be responsible for training-the-trainer?

 

[pHruit]

I have occasionally had auditors challenge the position that the author/owner of a policy hasn't been trained on it, even though it becomes logically rather silly as you'd get stuck in a loop of needing to train yourself as the author of the policy, but you haven't been trained on the policy so you need to train yourself, but you can't do that because you haven't been trained....

The possible exceptions to this might be for work instructions / procedures where something physical actually happens based on them - for example, authoring a procedure doesn't necessarily mean you've had the training on the actual "doing" of using a machine or similar.

 

I would definitely suggest a train-the-trainer record, otherwise there is the obvious question: if you can't show that the tutor has been trained and therefore knows what they are doing, how can you be sure that they are able to teach it to others.

[The Food Scientist]

What is your role/position at the company? Audit Scheme? For example at an SQF facility the SQF practitioner is already "trained" and knowledge to write all the procedures and policies and auditors look for their HACCP training (requirements for SQFP). So automatically that makes you trained on all these policies and procedures. Never had an auditor ask me to show them if I was trained on aynthing I wrote given I am the practitioner. 

[QAGB]

We had an electronic training system (videos, remotes, database setup) so I still had all my appropriate training for GMPs and Food Safety.

 

As to lab training, we conducted "round robins", so I was part of that as well, as a way to show I hadn't lost my touch.

 

For training I received externally (like HACCP), I always had my certificate as evidence.

 

I also indicated all of my technical training including my background previously as a chemist with hands-on-knowledge of most equipment. For items that I didn't previously have training or knowledge about, I had a previously trained person train me and used that for reference.

[FurFarmandFork]

I've always written into my training SOP that signatories on a document were considered "trainers" and considered to be experts in the subject matter, having reviewed it.

 

This becomes more difficult if you have delegated sign offs, but in general I've always excluded senior staff as "trainers" and simply audited whether they knew their stuff as part of my normal training effectiveness tchecks.

[Hoosiersmoker]

I have not technically "authored" every procedure as I haven't the experience level to write operation of equipment type SOPs. For these, Supervisors fill in the specifics and I fill in the other required information as needed. I am not an expert but have reviewed them, but also I do not have to perform the operations so I do not technically need to be trained on them either. System SOPs are mine and I train on those. Our Quality Manager has me train many of his SOPs and he sits in on at least one of them and signs in as such. How are you to know what is being conveyed to the "class" if you are not there? How can you verify its accuracy and content if you don't witness it personally? Why would you not want to verify the training by observation? You don't need to watch over every session but do need to know what's being taught.

[Faith S]

I personally think that you would not need to be trained on procedures and policies that you wrote but you would need to have some form of training which enables you to write those procedures e.g SQF, HACCP, PRP training