Proving compliance – not just attendance

This is a re-post from a popular blog entry previously published by John Kleeman

Many regulators require you to train employees – in financial services, pharmaceuticals, utilities and in health & safety across all industries. You need to train them and when you are audited or if something goes wrong, you need to document that you did the training. 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?”

Is it good enough to get the participant to sign something saying that they’ve attended the training or read the safety manual? An excellent blog series on the SafetyXChange says no:

Some companies ask their workers to sign a form after training sessions acknowledging that they understood the lesson and will put it into practice. Don’t let these forms lull you into a false sense of security. “Most workers will just sign these things without even reading them, let alone making sure that they understood everything you told them,” says a health and safety attorney in New York City. This is especially true if the training and instructions are complicated.

In the safety field, a US Appeals Court law case ruled in 2005 (my underlining):

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.

Two good ways to show that someone not only attending the training but also understood it:

Workplace assessment on ladder useGive employees a test or quiz at the end of the training to confirm that they understood it. This will also give them practice retrieving information to slow the forgetting curve (see Answering Questions directly helps you learn). And it will allow you to pick out people who didn’t get the learning or weak points in the class.

For more practical skills, you might want to observe people to check they understood the training and can practice it, or in the safety world demonstrate that they can do the job safely. For example the screenshot on the right shows how a supervisor can use an iPad to check and log someone’s skill on using a ladder.

My view is that you want to give these kinds of tests for two reasons. First and most importantly, you want to prevent your employees from falling off ladders or making other mistakes. Second, if something does go awry, you want evidence that you’ve trained people well.

A busy discussion on the LinkedIn’s Compliance Exchange forum dove into this further. I have paraphrased some of the views there:

Yes, you should give a quiz as it proves attendance – videoing the training is another option.

Yes, you should give a test and regulators in particular the US FDIC are increasingly demanding this

No. Danger of a test is that you need to take action if scores are bad, which may give you a lot of work. Safer not to ask the questions in case you don’t like the answers.

Yes, you should give a test but it can be a very easy and simple one, to check basic understanding and prove attendance

Yes, you should test, as well as confirming understanding it will also highlight vulnerabilities in the training

What do you think? Use the reply form below and contribute to the dialog.

For information on how to make trustable assessments, see John Kleeman and Questionmark CEO Eric Shepherd’s newest white paper “Assessment Results You can Trust”  –  This 26-page white paper will help corporate and government stakeholders create, deliver and report on assessments to produce trustable results that can effectively measure the competence of employees and their extended workforce.

2 Responses to “Proving compliance – not just attendance”

  1. Ted Villella says:

    Yes you should not only test but use WBT as a prerequisite to hands on training. For example, many people need to wear a safety harness designed to catch them should they fall from a height This is a common practice in warehouse work and construction. In the Americas 4-5 people die almost every day from falls that are preventable. So many organizations require some form of fall protection. What many may not know much about is suspension trauma. Being suspended in a harness is dangerous in and of itself. A person hanging in a harness could die if not rescued within just 5 minutes. People should get very specific and closely supervised training that includes experience being suspended for less than a minute (it is dangerous). People who have been suspended also should not lie down, just the opposite they should spend 30-40 minutes going from kneeling, to sitting to standing to protect their heart.

  2. Hi Ted– This is a great point. Thank you for your comment.

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