Records in the Training System

Records serve the purpose of controlling and directing the organization, helping to orient personnel to a common goal or purpose. For the purpose of training these records includes a training plan (and its subparts like curricula) and evidence of training performance (e.g.  attendance) and assessment

There are two main audiences for record-keeping: operational staff and various auditors/inspectors. The operational perspective is ideally proactive, while the auditor’s perspective is typically retroactive.

For the training program this breaks down as:

• Operational staff are interested in the trainee’s currency in their individual training plans for purposes of work assignments. Supervisors need to be sure people are doing the tasks they are trained on. Management is also ensuring they have enough capacity of trained individuals to ensure upcoming activities can be supported.
• Auditors (internal and external) are interested  in whether the individual who completed a task (e.g. approved a document) was trained to the appropriate process/procedure before doing the task. In this case the training records provide evidence of the organization’s past fulfillment of its regulatory obligations. Auditors will also look at the general health of the training system.

Training records (like all records) must demonstrate that training is implemented, responsible, consistent:

• Implemented means that training events can be duly recorded in the system.
• A responsible system’s controlled documents (i.e. procedure for training record-keeping) are written and followed, plus the procedure clearly identifies the responsible party for each task. For example, training is completed within the specified period.
• Consistent systems ensure identical activities generate identical outcomes. Therefore, we validate Learning Management Systems (LMS)

Documentation of individual training is a captured record (training is captured as it happens), a maintained record (training can be verified after it happened) and a usable record (decisions can be made).

Captured records means the record has the following:

Record Management Term	ALCOA Principle	Means
Authorized	Attributable	Created by an authorized person, for example a qualified trainer.
Comprehensive	Contemporaneous	A record is created for every training event.
Identifiable	Attributable	The created record can be linked to the particular training event
Complete	Accurate	Includes all information on the training event (who participated, what was covered, who trained and when)

Maintained records means the record has the following:

Record Management Term	ALCOA Principle	Means
Inviolate	Legible	Any alteration or modification is traceable
Auditable	Original	Every use of the record leaves an audit trail
Appropriately retained	Original	Training records must be subject to a retention schedule and then disposed according to procedure

Usable means the training records can be used by authorized parties to make decisions:

Record Management Term	ALCOA Principle	Means
Retrievable	Original	Training records are I a form that can be searched and retrieved within a reasonable period of time and expenditure of resources
Accessible to Authorized Parties	Legible	Available to those who are authorized to access them

Training Unit as Audience for Records

The training unit is a special case as an audience of documentation that has both operational and audit similarities. Some uses include:

• Level of effort being applied to training oversight
• Test and verify accuracy of statements about the benefits and impact of training