addressing missing training records for company seeking ISO 9001 certification
Hello all,  I am looking for guidance on best practice for addressing missing training records for existing employees for a company that will be seeking ISO 9001 certification in 2021.  Production has always done a good job with their training records, but some other departments have historically held informal training for their processes without generating training records.  What is the best way to address this issue for the existing employees who where trained to the processes, and are performing them daily but lack a training record?

New employees are not an issue as measures have been put in place to insure when new employees are trained, training records are now generated and retained.

Thank you in advance for any help or guidance,
8 Replies
As an auditor, I would accept a document signed and dated by each employee per job description of their verification that they received on the job (or other type) training as appropriate to the new trainIng procedure/policy.  The audit must lead back to a current approved policy document that defines the required training per job description. I don’t know that it would be enough to ‘grandfather’ in the required training prior to certification.  Good luck, and I look forward to any other more appropriate answers.

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I second Shelley's comments.  Generally speaking, every quality gap that is identified needs to be addressed when it is discovered and you've done that.  I might add to this a review of any key positions or processes that can have the ability to affect product quality and determine if immediate (or planned) retrospective training is appropriate.  This review would be documented as well.  
I agree with all said and have been in similar situations. The important issue is that you identified an issue and are taking action. I suggest you identify this in your corrective action process, specifically noting you immediate actions taken in addition to the long term solution to maintain an effective training process.
One possible solution would be to do a general review training where you hand them some paperwork and ask a few questions. This could be done at their work station very quickly so as not to disrupt production. ISO 9001:2015 does not state how to train your employees. it only states that an employee shall be competent. This is not an exact quote however it is the jist of what it means.
Matthew Miller
Thanks to all of you for your comments and input.  It is much appreciated and I feel I have a solid path forward through our CAPA process to address the issue now.  Thx, Tony
Good morning,

You can grandfather long term employees lack of training records by establishing a start date for the requirement for all training to be documented.  Any employee who has worked there before that date can be grandfathered forby issuing a record attesting to the following kind of a statement:

The is to certify that John doe is hereby grandfathered and by virtue of their long term of service and demonstrated work performance is deemed to be competent in their current work assignments.


Hank Fahrlander
Just keep in mind that ISO 9000 defines competency as the demonstrated ability to apply knowledge and skills.  You are grandfathering the employee's competence thru demonstrated acceptable performance.
The simplest way to address this is to have a mass training sign off.  List all of the documents then attach a sign off sheet for each employee to sign.  This ensures you have a record for the "latest and greatest" for each document for each employee.