This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||7.1 Training|
|BRCGS Packaging Issue 6||6.1 Training|
|BRCGS Agents & Brokers Issue 3||5.1 Training and competency|
|BRCGS Storage & Distribution Issue 4||8.1 Training and competency|
|FSSC22000 Version 5.1||ISO 22000:2018 7.2 Competence and 7.3 Awareness|
|IFS Food Version 7||3.3 Training and instruction|
|SQF Edition 9||2.9 Training|
There must be a procedure in place which defines:
- Initial (induction) training.
- Supervision requirements.
- How training for visitors, contractors and third-party engineers is handled.
- CCP training.
- Job based training.
- Level of training.
- Updates or changes.
To establish what training is required, the competencies for each specific job role must be assessed.
Where staff perform specific job-based tasks, procedural training must be provided. This will involve training staff on company documentation.
Make a list of all the job roles within the company. Then work your way through each one and identify:
- What job-based training is needed, based on the tasks that, that role will carry out.
- What subject matter training that role needs.
Once the training for each role has been defined, it’s a good idea to add this to a training matrix. That way you can add in all staff on site and assign the right training to each person.
Having training in one place is useful so that you can visually see if training is up-to-date.
When you add training to the matrix, just remember to do two things:
- Add the date and ensure that the spreadsheet will calculate (conditional formatting is great for this) when retraining is needed, based on a set retraining frequency.
- Add the version of the documents that were used during the training – so that you can tell when retraining is needed due to updates.
And don’t forget to cover roles such as:
- Product Safety Team – members.
- Product Safety Team Leader.
- Vulnerability assessment team members.
- Threat assessment team members.
- Decision makers (those who decide what should happen to non-conforming product).
- Incident team members.
- Root cause analysis team members.
- Chemical handlers.
- Internal auditors.
- GMP inspectors.
Before we get into what the Standards require, with regard to competency – let’s quickly go through what it means.
To be competent means that you have the required knowledge, skills and ability to be able to carry out a task to the required standard.
The term ‘competency’ is used frequently in the Standards, and you may be surprised to find that doesn’t necessarily mean you have to have a training certificate for a particular subject.
You can be competent in a subject, but have never sat an official exam to prove that you are. Sitting the exam doesn’t make you competent. Doing the task to the required standard makes you competent. And if you’re competent in a particular subject, taking the exam then just gives you the piece of paper to prove it.
However, before you all run off to cancel your training courses – let’s talk about how you prove that you’re competent.
If you think about it, an auditor can’t work with you and decide whether you’re competent or not. So they need to have something be able to prove that you’re competent – which is why training certificates are used.
So, let’s look at how to comply with the Standards.
Competency is split into two parts:
- Initial competency checks.
- Ongoing competency checks.
Initial competency checks
Initial competency must be checked following training. This means that once you’ve completed the training, there needs to be a test of some sort – to prove that the learner has understood what they’ve been taught.
This can be:
- A written test or exam.
- A practical assessment – ‘show me how you should do…’.
- A verbal assessment – ‘tell me what you would do…’.
Ongoing competency checks
Ongoing competency checks make sure that the learner continues to remember what they’ve learnt. We all know that when we don’t do something frequently, we tend to forget it.
The typical solution to proving ongoing competency is to apply retraining at a set frequency.
However, it doesn’t mean that you have to retrain someone, just because the retraining frequency says so. You could ask them to complete the initial competency check again and if they pass, this proves that they still remember what they’ve been taught. And so, they wouldn’t need to complete the training again.
Ongoing competency checks can also include assessment of things like:
- Results of internal audits for a specific topic.
- Results of GMP inspections for a particular area.
For example, if your Product Safety Plan flies through all of its internal and external audits, you could say that this proves that the Product Safety Team are competent.
This is a really good question! Do you have to do competency checks on all training aspects?
The BRCGS Standard is a little contradictory on this subject. All four BRCGS Standards say that “competency shall routinely be reviewed”. Shall means must. So, it means that competency must be checked.
However, the Standards also state that for CCP checks, training must be assessed for competency. The fact that they’ve highlighted CCPs specifically, sort of implies it’s not really needed for everything else.
So, our advice would be to base it on risk. Obviously CCPs (Product Safety Controls) are high risk, so they should be done following initial training, following any update training (where the version of the procedure has been updated) and at a set frequency – which typically is yearly.
We would then work back from that. So, training that’s less risky – perhaps doesn’t need competency to be checked after each version update but may just be checked on initial training and then at a set frequency. You can also extend the frequency, based on risk.
Records of training must be kept and include:
- The name of the trainee to confirmation their attendance.
- The date of the training.
- The duration of the training.
- The course title or procedure name, reference and version number.
- The name of the training provider (if external).
- A summary of the curriculum where an internal training presentation has been used, or a copy of the presentation.
- Where verbal translation is used during training, the translator must sign the training record and the language used must be recorded.
There are instances where formal training isn’t necessary and other methods such as toolbox talks may be used. Where this is the case, the above rules around keeping a record of the training must still be applied.
Updates and changes
When updates are made to documentation that’s used for training, there must be rules that define when training must occur, including:
- When a change doesn’t require retraining, e.g. spelling corrections.
- How changes will be implemented and maximum timeframe from publishing to completion of retraining.
- How document changes will be communicated to those who provide the training.
Add your comments, top tips and questions in the comments box below.