Documenting compliance training: are signatures enough?
Many of us in the SAP Ecosystem need to document that people have been through training, either to meet regulatory compliance needs or for our own safety or security needs. I’ve been researching recently the requirements around documenting training and thought I’d share some of what I’ve learned.
Many regulators require you to document training, and it’s general good practice to document that training has taken place. For instance, the OECD in its good practice guidance on internal controls, ethics and compliance recommends “measures designed to ensure periodic communication, and documented training for all levels of the company, on the company’s ethics and compliance programme”.
But how do you document training? The three most common ways are:
- Keeping an attendance record
- Getting someone to sign a form (on paper or electronically) that they’ve attended and understood the training
- Giving a quiz or test at the end of training to confirm not only attendance but also understanding
Keeping an attendance record
Keeping an attendance record is the simplest and easiest method. It shows that someone attended but obviously not that they were there in mind as well as body. There is also the risk that someone might attend at the start but not throughout the course.
Signing a form
Getting someone to confirm that they’ve understood the training by signing a form is another common method of documenting training. Getting employees to sign a form after training sessions acknowledging that they understood the lesson and will put it into practice is better than an attendance record. But this also has its weaknesses, as people will sometimes sign forms without thinking about them or under pressure. “Have you read the safety manual?” … “Yes, of course I have, let’s get on with the work.”
There was an interesting US Court of Appeal legal case which involved a company who claimed they’d trained someone sufficiently by getting them to sign a form and the Court ruled (my bolding) that “merely having an individual sign a form acknowledging his responsibility to read the safety manual is insufficient to insure that the detailed instructions contained therein have actually been communicated”.
Giving a quiz or test at end of training
The advantage of a quiz or test at the end of training is that this checks understanding not just attendance. By delivering and recording the results of the test, you confirm not only that the employee attended training but also that he or she learned from the training. Results from such assessments can also feed back into the training programme – for instance if people score weakly in a topic, then training on that can be improved. A test also encourages employees to pay attention.
As the UK Financial Services Authority has commented: “where staff understanding has not been tested, it is hard for firms to judge how well the relevant training has been absorbed”
If you want to learn more about good practice in documenting training, there is an excellent blog series on the safetyXchange website – see http://www.safetyxchange.org/compliance-risk-management/how-to-document-safety-training-part-4-of-4 for a summary. They also suggest that observing employees put the training into practice or getting employees to demonstrate what they’ve learned to others are good procedures.
What does it mean for you?
In the SAP Ecosystem, for many people the best way of documenting training will be with SAP Enterprise Learning (aka LSO), where you can record that people have been through training and deliver quizzes and tests (either directly or using an external assessment system like Questionmark). See my earlier blog entry How SAP and Questionmark software promote safety at one of America’s Nuclear Power Stations for how one organization does this.
Like everything else in compliance, you have to take risk into account, and in some situations, you may be happy just to use attendance records or getting people to sign forms, but if the training is important and failure to understand it could be critical, then using a test will help.
To quote the US regulator OSHA: Documentation can also supply an answer to one of the first questions an accident investigator will ask: “Was the injured employee trained to do the job?” Using a quiz or test at the end of the training might ensure it is understood – and avoid future accidents or compliance failures.