C.02.006 Well-shoed shoe-maker

On the other of the looking-glass

Do you know the internet? Not the one we use for online shopping but the one that is full of information about compliance. I was looking through the Health Canada web site recently, looking for some inspiration for this very newsletter. Under “what’s new”, I saw a document about the Quality system management and the training program for Health Canada’s investigators. Upon reading it some interesting findings were brought to my attention about the structure of their training program but also on the structure of training per se. Well, well…

One big question I have when an audit is announced is : what kind of expectations do these investigators have in mind? We all have policies and corporate guidelines. Is it enough? Are we focusing on the right things? In other words, do we manage the training program, the training functions, in an efficient and compliant way?

Let’s take a closer look at this official document. I strongly suggest you download it form the official web site of Health Canada.

I will quote the document throughout the newsletter : section 6.

Everything seems reasonable enough.

A job description

A training plan

A training file including proofs of training (with the evaluation’s results! ), education and experience (CV) and… oh joy!

A direct link with the performance appraisal system!

It is therefore easy to understand their disappointment during an audit when they see the state some of our training systems. Experts are frequently NOT an example. In this case, Canadian investigators are indeed not in the position of the shoe maker wearing worn out shoes.

At the same time, note that we are comparing their policy and official guideline to our system. They are actually able to dig in our system and training files whereas we cannot return the favor. I would be curious to see THEIR training files… Nonetheless, we have to admit that their audit findings are somewhat inconsistent with the way our procedures describe our training files and system. Their procedure sure looks good. Do they have the same challenge staying in compliance with it as we have? We know that our compliance level to our procedures is usually inversely proportional to the proximity of the shop-floor : the higher the writing level (e.g. corporate offices) the lesser the connexion with real life (i.e. our plants!).

This being said, when you look at the Quality System guidance document of Health Canada, it is a model to follow. And that is not all!

In several instances in this document the reader will find statements referring to the human aspect as being essential towards achieving the Quality mission of any organization. These could be pious only words but one must admit that has been a recurrent theme in the last few years. The simple fact that this type of statement appears in documents written by bureaucrats is encouraging. When I read the following statement, I can only approve : the inspectorate qualifies AND maintains.

The Inspectorate qualifies and maintains proficiency of its personnel by:

? Evaluating general education, experience and proficiency of its personnel for the activities to be performed.

? Identifying individual training needs against those required for satisfactory performance,

? Planning, organizing and carrying out appropriate training or re-training, either in-hous or by external organization.

? Recording training and achievement so that records can be updated and deficiencies in training can be readily identified and corrected.

? Evaluating all changes in each process for any additional training requirements.

WOW! C.02.006 really put in practice, real continuous training! As a wise manager once said (call me if you really want to know who!) your boots must follow you lips… or walk the talk (believe me, it sounds awesome in French…). By the looks of it, as far as Health Canada is concerned, is seems to be the case.


I must now ask another set of questions:

Who is responsible for the training program?

What is the ratio trainer/employee at Health Canada?

This ratio is approximately 6/1000 according the latest numbers from ASTD. Only about half as much as the general manufacturing industry. If what is suggested by Health Canada is to be taken seriously, if we are to be compliant, we should :

Rethink several training departments and take them to the next level.

Or decrease the number of SOP revisions.

Or expand our views of the training methodology.

And revise the new employee orientation program.

And create retention incentives in order to reduce the number of times we re-train on the same procedure.

And think about motivating environment to stimulate employees to learn on their own.

And re-evaluate the way we control the changes on procedures.

And create a new way for employee to contribute significantly to SOP revisions.

And provide an iPod Touch to everybody…

Hmmm, I might be overexcited here and on my way over the edge.

In any case, solutions exist. This is a certainty. The real desire to implement them is another ball game altogether. Any change implies an upheaval. Training is fundamental to insure product quality but also the quality of employees. Especially the latter. It always saddens me when my clients announce that their training budgets have been cut or that the per capita spending is higher for managers than operators. Those same managers who will voluntarily attend a 3-day long seminar, a very expensive one at that, and at the same time will refuse a 4h shut-down of production to train their employee. 4h of NON-production!


4 hours of human capital investment.

4 hours of support and learning oasis.

4 hours to confirm the message that is conveyed in the Health Canada document: qualifies AND maintains their qualification.


The dictionary states it that way: frm the latin qualis, which or what and facere, to do. To expresso quality : attribute a specified quality. To do something, to learn to do something.

To qualify : Officially recognize by satisfying the relevant conditions

To qualify people. To make them quality people.

Because quality IS people.

Yum! Brands (A&W, Pizza Hut and Taco Bell) V-P was recently interview by the TD magazine and mentioned that their success formula was :”People capability first… satisfied customers and profitability follow”.

This is soooooo obvious.

It is what I understand from the Health Canada document.

Quality in execution through quality in training.

Yep… I like that.

A lot.

Have fun, learn well and stay compliant !


Each Inspectorate employee has a personnel file which contains the following records:

1. A work description, based on the employee’s occupational group and level, which lists work activities and responsibilities

2. An Inspectorate training curricula, based on the employee’s position category;

3. Training records which includes the certificates of training;

4. A curriculum vitae detailing education, work experience, occupational certification, expertise and specialization;

5. Results of the level obtained in the official language proficiency test administered by the Public Service Commission (when applicable);

6. Annual performance appraisals (Performance Discussion Process – PDP);

7. Work objectives for the upcoming year.


“The quality of an organization never exceeds the quality of the minds that make it up”   Harold McAlindon

Par François Lavallée, M. Sc.


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