AS9100 and the Competence Requirement

Within the AS9100 REV D standard Competency (Clause 7.2) and Awareness(Clause 7.3) are split into 2 separate clauses, that makes sense if you look at competency as purely skill or knowledge based but you do have to ask if it is to have any Competency without Awareness (or Communication!). As an organisation it';s for you to decide how you manage it within your systems, but for simplicity sake we'll take each of the sections in turn so in this post let's talk about Competency and how AS9100 REV D handles that in section 7.2 of the new standard.

In a nutshell the standard requires a you do a couple of things 1. you to assess personnel competency in terms of the quality management system and may have a direct or indirect effect on product quality and conformity to requirements and 2. I a note for the clause It suggests that you review this on a periodic basis, what that means is the auditor is going to be looking for evidence you are reviewing things.

Pausing for a second, let's agree what Competence actually means. In terms of AS9100 REV D Clause 7.2 Competence we can use the definition with the "ISO9001:2015 Fundamentals & Vocabulary" document (since AS9100d is based on the ISO9011:2015 standard) which says competency is the "Ability to apply knowledge and skills to achieve the intended result". In other words, just giving someone training does not mean they are competent. Think about it a bit like driving, even after your initial driver training you are not fully competent are you, you perhaps haven't driven in heavy rain or snow, what about handling a skid? You become more competent over time with practice and experience and it's the same here, training alone isn't enough. You need to test for understanding and then add practice and further testing over time. You'd also have varying levels of competence, we'd all argue that we are competent to drive our cars, what about a truck or a bus? Would you still be competent if we handed you an F1 racing car? Probably not! Organisations need to keep this in mind when assessing a person's competence for anything, it needs to be reflective of requirements of the role they are undertaking and not of the business as a whole.  

When you look at competence in terms of your quality management system, for example, you do need to provide training to people who will be involved in the quality management system. They need to know how to find the information they need, what your acronyms mean, what the expectations are and how to follow through on the various procedures you have. It's best to do this as you go along with the implementation if you are starting from scratch. If you have an existing system and someone new joins, then you need a training plan for them to get up to speed on your system. Everyone learns differently and at different speeds but as a rule of thumb, as you go through this training, small tests will create the proof that people have the understanding that will help build the competence in the system. Don't make them big heavy serious tests, keep it light & enjoyable – pop quizzes or lunchtime competitions with pizza are always good.

Like any training you should look at where you believe the gaps are, so how do you do this? Well, the trusty old skills matrix is really hard to beat here. On one axis your matrix list all the skills that you will need to have to ensure your quality system delivers both in terms of the Quality Management System directly but also think about the skills required to deliver your products or services at the level your customers require. On the other axis you want all your team, but here is a really helpful hint... include the position in there as well. Over time the names will change but the positions probably won't, so the matrix remains correct in terms of what skill are required per position at all times, but as new people fill the roles it becomes easy to see the gaps.

From this, you can now have a gap analysis of your skills within the organisation and so where you need to carry out further training.  

You should remember that people joining or existing in your organisation come with pre-existing skills from previous training, courses, and experience, these need to be incorporated into your skills matrix as well. It's not uncommon for this previous knowledge to be ignored which is a huge loss to the organisation and the individual.

Keep this in mind when looking at the requirement for competence as it will extend into the day-to-day job someone does as well as the ability to understand and execute your procedures. The standard does specify that you need to assess someone's competence based on education, training or experience. That means if you have someone who has their degree and the right training and support you could say they are competent, equally if someone has 24 years of actual hands-on experience but no degree (which you may have specified in the job spec) they are still deemed to be competent.

Now you have the gap analysis you need to take the required steps to close your gaps. Here you have a number of valid options, you can train internally or externally for it, you can, of course, hire new people, or you can contract in that expertise where appropriate, this is about taking the right actions to acquire the necessary competence which is part c of this clause. Our Virtual Quality Management service would be a typical example of this step where a companies decide that they don't have someone internally who can fully manage their QMS or they don't need a full time person so decide to do a contract option for a set amount of time per month. This is perfectly acceptable within the standard.

As part of AS9100 REV D clause 7.2 for Competence clause you need to maintain appropriate documentation to demonstrate you have a basis for your claimed level of competence. This is typically where you need a really clear set of training records that are easily reviewed, tracked and updated. Paper systems can, of course, work but as you become a larger organisation it gets harder so having a proper management system is hugely beneficial. The HR module of the Mango QHSE system covers this section and has an e-Assessment module which would let you create internal training and exams which of course are tracked automatically back to your employee making the meeting this requirement simple.

Finally, as we noted at the start, the standard does have a not that says, "Consideration should be given for the periodic review of the necessary competence". This is obviously up to the organisation; however, the auditor will be looking for evidence that you do it or reasons you don't. When you think about it it makes sense doesn't it? Every so often double checking your people are still following the processes and doing things right just helps keep things in tune. A good method of this are internal audits on the process and people and / or rerunning your internal testing. With our Mango clients we simply hit the retest button or automatically retest employees on certain skills as agreed time-frames and the system takes care of it automatically.

The AS9100 REV D Clause 7.2 for competence is all about ensuring you have the knowledge and skills at the correct level to be able to effectively run your quality management system and deliver your products and services to your clients. Creating a visual skills matrix is an effective way of doing this and allowing you to create the right training plans for the right areas where you are short of the required skills. You must remember however to retain the evidence of assessing those skills as the basis for your decision on competence.