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.

ISO 9001 / AS9100 states in sec. 0.1

Information marked as “NOTE” is for guidance in understanding or clarifying the associated requirement.

Consequently, AS9100 also includes some “training” requirements identified in “Notes” that, when applicable, should be addressed as if they were a part of AS9100, sec. 7.2 “Competence”,

8.1.3 Product Safety
The organization shall plan, implement, and control the processes needed to assure product safety during the entire product life cycle, as appropriate to the organization and the product.

NOTE: Examples of these processes include:
− assessment of hazards and management of associated risks (see 8.1.1);
− management of safety critical items;
− analysis and reporting of occurred events affecting safety;
− communication of these events and training of persons.

8.1.4 Prevention of Counterfeit Parts
The organization shall plan, implement, and control processes, appropriate to the organization and the product, for the prevention of counterfeit or suspect counterfeit part use and their inclusion in product(s) delivered to the customer.

NOTE: Counterfeit part prevention processes should consider:
− training of appropriate persons in the awareness and prevention of counterfeit parts;

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.