That training was baaaahd! – “Sheep dip training” is not the answer to compliance

There’s a really baaaahd training practice running rampant in organizations and it’s called “sheep dip training”.  To get an understanding of what this is, you have to understand what “sheep dip” means.  According to the web authority extraordinaire, Wikipedia, Sheep dip is a liquid formulation of insecticide and fungicide which farmers use to protect their sheep from infestation against external parasites.  They gather up all of the unsuspecting little sheep and then begin to dunk them in the vat of poisonous liquid…for their own good, of course.

This is not unlike a popular training strategy used today.  It goes like this….

Dip ’em all!  Unsuspecting employees (the sheep) are herded into a training session (generally against their will) and are then subjected to painful lecturing on a compliance related topic like OSHA or GMP.  Everyone gets the same “dip”, at the same dosage, whether they need it or not.  The sheep suffer through it and then try to shake off as much as possible when they are released!  Trainers and Managers (the farmers) proclaim that the sheep are now “safe”.

Dip ’em in the same stuff, every time! Since the dip worked so well the first time, twenty six years ago, it must be good dip, so it stands to reason that farmers should use the same dip as before!  The sheep have started to notice that the farmers never seem to get dipped, and they even wear protective gloves, therefore; suspicion about the safety and efficacy of the dip starts to surface.  I would imagine the reason the farmers don’t need dipping is because they were dipped twenty six years ago and it must last longer for farmers.  ….or farmers are immune to the pesky parasites which afflict the sheep.

Dip ’em again next year!  If sheep aren’t dipped on a regular basis, they may be susceptible to infestation, so someone once declared that all sheep need to be dipped every year to prevent the scourge.  Plus, we know how “refreshing” the sheep find the dipping process, so they should be grateful they are so well taken care of, right?

There are numerous flaws with the “sheep dip training” strategy.

1) Not all sheep are the same, or respond the same to the dip.  Some employees need more emphasis on certain topics than others.  Training delivery, emphasis and duration needs to be commensurate with the learning objectives of each job function.  Learning is more relevant and transferrable when the trainees realize what the training means to them and how to apply it!

2) Not all sheep need the same dosage and concentration of dip to prevent parasites..and quite often a new formula will work better. Some compliance topics relate to everyone in the organization, but not in the same way, and not at the same levels.  Some employees will need to transfer the learning to behavior on the job, which would require good comprehension of the material and an understanding of how to apply those principles.  Some employees will only be in the vicinity of the risk, but never directly exposed, so their needs are clearly different.  By considering current events and the varied needs of staff, it’s possible to make compliance training fresh and relevant every time.  If your organization has been using the same old stale training over and over for years, you need to assess the efficacy of it.  It’s very possible that the training is past the expiry date!

3) Dip lasts longer on some sheep than others.  Depending on the level of risk involved, and the incident rate of particular non-compliances, some training needs to be delivered annually and some does not.  The important thing is to know if the regulations require “annual” refreshers, and for whom.  If the regulation doesn’t dictate the frequency of the training, it’s important to assess the risk level of each job function and provide the training commensurate with that risk.

Think about the training going on in your organization.  Are you a victim of sheep dip training?  If so, renew your training strategy to be more risk based and watch the morale and health of the sheep improve!

Whose Training Is It Anyway?

Is it time for your annual compliance training? Maybe your compliance training is essentially a  quick, on the fly “improv”?  Do you ever wonder who really cares?

Regulators care that you’ve provided it. The U.S. FDA 21 CFR §211.25 states that training should be given “with sufficient frequency to assure that employees remain familiar with cGMP requirements applicable to them.”  

Your quality department cares that they can demonstrate to the regulators that the training was delivered.

Your managers care that they can demonstrate to your quality department that training was delivered.

Your training department would like to deliver something meaningful to trainees, but is often pressured by managers to come up with a “one size fits all” training session for hundreds or thousands of people to ensure  minimal interruption to the business. So, with these varied interests in the delivery of compliance training, whose learning is it anyway?

Have you ever wondered what the employees really care about and for whom the training should actually be designed? In a culture where tracking training and proving that it is delivered is very familiar, we would likely find our efforts a huge waste of time if we actually measured the return on investment (ROI). The intent of the training regulations is not just that employees “remain familiar” with requirements, but rather that they apply the learning to their daily lives and operate in a state of compliance. The preamble to the FDA regulations state: “The Commissioner intends that training be meaningful to the employee, not a formalistic but useless exercise to satisfy a regulation.”  Are you currently inundated with “formalistic, useless exercises to satisfy regulations”?

It’s imperative that we begin to think of the real customer when it comes to delivering compliance training. Are you measuring whether or not the training was actually meaningful? If your training isn’t making a difference in the behaviors, attitudes, skills or knowledge level of employees, then you’re simply wasting your time and money on a “formalistic, useless exercise to satisfy a regulation.”

Training can be designed and delivered in a way that engages employees, helping them take ownership of the learning and apply it to their work! Good training changes behavior and performance. A key to improving performance is driving ownership of learning to the trainees. When training is done properly, organizational effectiveness and business results are enhanced.

Ban the improv sessions when it comes to compliance training, so that you can eliminate those risky, improv performances on the job.


Failing to plan is planning to fail

Winston Churchill said, “He who fails to plan is planning to fail.”  A lot of times people seek the help of workplace learning and performance (WLP) professionals only after they realize through costly mistakes that they’ve failed to properly plan their employees training to build and sharpen skills.  Advance planning and design of a strong training system for your business can prevent these mistakes, but where do you begin?

A well designed curriculum is the cornerstone of a strong training program, whether utilizing a Learning Management System (LMS) or a manual process.  A lot of smaller companies don’t consider the varied needs of  each employee and may attempt to use “one size fits all”, generic training which will likely end up “fitting none” just right.

Job / task analysis is the start to determining the precise needs of employees performing varied functions.  A modular approach, often using a core curriculum, is a good way to get a better fit, for all of your staff.  Larger organizations, using electronic Learning Management Systems tend to overcomplicate this task by making hundreds of separate curricula vs. finding common needs among staff and building from base modules.

Curriculum design and assignment can often seem overwhelming and complex.  However, with proper analysis, this daunting task can be easily managed and explained to regulators and third party customers.  There are some simple techniques to evaluate training requirements and group them in an efficient manner.

Identify the training the applies to “everyone” in the organization.  Then critically ask yourself if every employee will really need that information at the same level, from the same point of view.  Just because a topic applies to everyone, doesn’t mean it should be delivered in the same way to everyone.  Next, determine the ‘cornerstones’ of training that are shared across job titles and will apply to audience groups.  Separate ‘general’ training requirements from ‘specific’ training requirements and use that knowledge to create job specific curriculums, which contain common modules as their foundations.

You’ll be on your way to building a strong training program, uniquely suited to the needs and skills of every member of your staff.  If you need assistance with this type of plan, I’d be happy to help!