ISO 9001:2015 / AS9100:2016 (Rev. D) - Basic Training

Beyond ISO 9001 / AS9100, sec. 7.2 “Competence”, there are many “hidden” or overlooked requirements in ISO 9001 / AS9100 involving training for which records are not explicitly required. These requirements usually involve “communicating” specific topics to personnel, ensuring that certain communicated topics are “understood”, and making personnel “aware” of certain topics.

For example:

5.1 Leadership and Commitment
5.1.1 General
Top management shall demonstrate leadership and commitment with respect to the quality management system by:
f. communicating the importance of effective quality management and of conforming to the quality management system requirements;

5.2.2 Communicating the Quality Policy
The quality policy shall:
b. be communicated, understood, and applied within the organization;

5.3 Organizational Roles, Responsibilities, and Authorities
Top management shall ensure that the responsibilities and authorities for relevant roles are assigned, communicated, and understood within the organization.

6.2 Quality Objectives and Planning to Achieve Them
6.2.1 The organization shall establish quality objectives at relevant functions, levels, and processes needed for the quality management system.
The quality objectives shall:
f. be communicated;

7.3 Awareness
The organization shall ensure that persons doing work under the organization’s control are aware of:
a. the quality policy;
b. relevant quality objectives;
c. their contribution to the effectiveness of the quality management system, including the benefits of improved performance;
d. the implications of not conforming with the quality management system requirements;
e. relevant quality management system documented information and changes thereto;
f. their contribution to product or service conformity;
g. their contribution to product safety;
h. the importance of ethical behavior.

Note: The bold text in section 7.3 e-h is unique to AS9100:2016.

While there are no records explicitly required in any of the above requirements, some auditors will point to ISO 9001/AS9100, sec. 4.4.2 and interpret it as requiring records for virtually every requirement contained in the standard.

4.4.2 To the extent necessary, the organization shall:
b. retain documented information to have confidence that the processes are being carried out as planned.

The best way to address/avoid this potential issue is to include these topics in “Indoctrination Training” or “ISO9001/AS9100 Basic Training” for all employees.