Proving compliance – not just attendance

Posted 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 use

Give 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.

If you’re interested in this area you might check out a recent, busy discussion (registration required) on the LinkedIn Compliance Exchange forum. Paraphrasing 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.

One Response to “Proving compliance – not just attendance”

  1. […] Assessments are the best way to document that training needed for compliance has taken place. See Proving compliance – not just attendance for more on […]

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