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.