SOP on internal & external training program

Rahul Kashyap
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Purpose
To describe the procedure for internal & external training program and to ensure the competency of personnel performing any activity and to get appropriate training related to their job responsibilities.
Scope
The scope of this SOP is to provide training procedure is applicable to all employees (Skilled/Unskilled) who are engaged in QMS, cGMP and allied activities in different departments within ABC Limited.
Procedure
Definition
Training is an organized activity aimed for imparting information and/or instructions to improve the recipient’s performance or to help him or her attain a required level of knowledge or skill to perform the activities.
All the employees engaged  in  Quality  Management  System  (QMS),  cGMP   and   allied activities (Manufacturing,   Packing,  Warehouse,   Quality  Control,  Quality  Assurance, Engineering, Human Resources, Environmental Health & Safety, Regulatory Affairs  and all  other associated  departments), shall  be  adequately  trained  and  such  training   must be assessed  and documented.
Training shall be conducted in accordance with approved and written training programs/ procedures by appropriately Qualified Expert Resource /Certified Trainer/ respective department Head/ Designee.
Only   the   trained   personnel    shall   be   allowed    to   carry out    their respective   activities independently.
Training may be given by different training aids such as Audio visual media, Power Point Slides and tools such as white board, papers and posters, projector, LCD or any other electronic device to train the employees.
The training program shall comprise of following types of training:

Ø  Induction Training
Ø  Basic GxP i.e. (GMP, GLP, GDP, GEP & GWP Etc.) training
Ø  On Job Training
Ø  Scheduled and Unscheduled Training
External Training
Induction Training:
All newly appointed employees shall undergo the induction schedule for “Induction Schedule”.
Induction schedule shall be completed within 7 working days of the employee
Head/Designee-HRD shall prepare the schedule by mentioning the name of department Head/Designee, date of visiting the department and introduce the new employee with respective department Head/Designee.
The induction training shall cover all the departments as well as the department to which he or she belongs.
Head - HRD or Designee shall explain the new employee at least the following (but not limited to):
Ø  Company discipline, Benefits, Perks and welfare activity.
Ø  First Aid / Medical Policy
Ø  Personal Hygiene
Ø  Leave Policy
Entry & Exit Procedure
During induction the department Heads / Designee shall brief the procedures followed at their department / section explaining the functions & role of their section / department.
On completion of the induction program employee shall get the signs from all the department head and complete the induction format and submit the same in HR department
GxP (GMP, GLP, GDP, GEP & GWP Etc.) training:
GxP training shall be imparted during induction of the new Joinees. Under  this training,  the  employee  is  imparted  training  on  Good  Practices   in  Production, Quality Control,  Personnel, Sanitation and Hygiene,  Good  Documentation  Practice and QMS System (Wherever Applicable) by concerned department.
GxP training shall be given to all employees (existing and newly joined) those are directly or indirectly associated with the quality of the drug product, cGMP training also cover the safety aspects of the personnel engaged in manufacturing operation. During induction Concerned department shall describe about GxP
Specimen Signature of Employee:
The specimen signatures and initials of every employee / staff member of the company shall be taken after completion of induction program.
After completion of induction program HR personnel shall be responsible to introduced the newly join person to QA for specimen signature.
These specimen signatures shall be documented
The specimen signature shall be maintained by QA department.
The specimen signature and initials shall be added at the time of new recruitment from time to time.
If any employee wants to change his signature he / she should inform to QA personnel to take new signature in specimen signature log book accordingly and old signature will be invalidated.
Job Responsibilities:
Job Responsibilities shall be finalized, signed and approved by the concern HOD after  Induction to the trainee
All Responsibilities shall be approved by department head, Should be accepted by designee & acknowledged by HR and same shall be retain in personal training file of employee / trainee.
Personnel are authorized to perform activities which are listed in job responsibilities.
Job Responsibilities will be revised in case of additional responsibility provided to employee or change in the designation or yearly basis.
job Responsibilities will be given version number
Previous superseded Job Responsibilities shall also be retained in personnel training file.
In case of additional responsibility to be given to employee same procedure to be followed.
On completion of basic induction/GxP training,& Job Responsibility concerned department head or his designee shall prepare “Training Need Identification” for the new joinee.
On job Training:
On job training shall be given based upon the Training Need Identification of new employee.
Training  Need Identification  for new joinee shall be prepared by concerned department Head/Designee in consultation with Head QAD/ Designee on the  basis  of individual's  qualification, experience,  and  the job  he/she is going  to handle which include departmental SOPs and relevant cross functional departmental SOPs
For the  new  employee,  Training  Need Identification / On job  training  program shall  be  governed   for a period  of approximately 7 working days  or more  as decided  by department Head.
During on job training, the person shall be trained on actual area of working. This includes class  room  training as well  as shop floor training, adherence to cGMP  and procedure related to Safety, Health and Environmental standards  of the working area, SOPs related to the equipment’s, instruments and working area, Unit operations, use and operation of equipment and instruments, change room  practices etc.
Topics of training for the training need identification (TNI) / On job training shall be
decided by  the  respective department Heads.
On job training takes place in a normal working condition, using the actual tools, equipment, documents or materials that trainees will use when fully trained. New joinee having instrument/equipment/activity operational responsibility shall be trained through on job training and same shall be recorded in “Training Attendance Record”.
The SOPs for Operation of Equipment / Instrument / Process / In-process checks etc. shall be explained by the Qualified Trainer of concern department to operators / technician and checkers.
On Job Training shall be evaluated by the trainer based on the satisfactory operation of task and evaluation shall be done based on “Training Assessment Form”
The evaluation of the new entrance shall be done either by written examination or questionnaires on the topic covered during training to assess the level of competence and same shall be evaluated and recorded.
Trainees questionnaire shall be assessed for the satisfactory training, trainees who score less than 80 % marks shall be considered unsatisfactory and retraining shall be imparted.
Questionnaires shall be prepared or set as per certified trainer's assessment for the evaluation of trainee at the time of conduction of training for the identified subject.
A certificate stating the declaration of the trainee to carry out the assigned activities/test and/ or handling of the selected equipment/instrument independently shall be issued based on technical and training need identification.    
Certificate is to be signed by the Department Head/Designee and Head-QAD.
The date on which the certificate is signed by Head-QAD is to be considered as effective date for that certification. After certification person shall be assigned for his/her duties and responsibilities.
Evaluation:
Training Assessment Form shall have the questionnaire in objective, True / False, Fill in blanks or descriptive forms
The Training Assessment Form shall be prepared in Hindi also for operators / technicians if required.   
The filled Training Assessment Form shall be checked by trainer and checked Training Assessment Form shall be attached in personal training file by trainee.
In case the new joinee scores less than 80% marks in any of the SOP, he/she shall be re- trained for that SOP, Retraining will be done in same way and shall be considered only twice.
In such cases evaluation shall be with different questionnaire than that of previous questionnaire.
In case the trainee didn’t qualify the passing criteria even after two retraining and getting scores less than 80% marks in any of the SOP, then it should be investigated and  provide the training related to other work.
Scheduled and Unscheduled Training
In-house training shall be arranged for existing staff to upgrade their knowledge and skills to familiarize with the principle of new instruments, new equipment, process, methods and new dosage forms etc. and same shall be recorded in “Training Attendance Record”.  
Unscheduled trainings shall be imparted and same shall be recorded in “Training Attendance Record” as and when required in case of following changes may be considered but not limited to:
Ø  Change in the nature of job and responsibilities
Ø  Whenever a change shall be made in the SOP / STP/ Specifications or whenever SOP/STP/Specifications shall be revised due to any revision of system.
Ø  Whenever the method of operation and analysis changes.
Ø  Whenever any changes are made in the operating parameters or change in
any operational procedure, cleaning procedures.
Ø  Changes required due to regulatory requirements.
Ø  Changes in master protocol and new protocols.
In case of internal audit findings complaints and other foreseen or unforeseen reasons.
External Training:
External trainings (in plant or outside plant) shall be organized if required
Head-QAD/HRD or Designee shall share the training program to all concerned departments as and whenever required.
Head HRD/Designee shall make arrangements of external training.
Department Head shall nominate the name of trainees for scheduled external training.
After completion of external training, trainees shall fill the External Trainer Feedback Form to check the effectiveness of training and further decision
Head HRD/Designee shall review the External Trainer Feedback Form and same shall be retain in personal training file of employee/trainee.
The employees, who shall get external training from outside the plant shall conduct internal training program.
Training Schedule:
All the Department Heads/ Designee shall prepare Training Schedule \ on half yearly basis i.e. Jan.-June & July- Dec.)
General  Annual training Schedule shall be prepared by QA Which must contain the GMP and cultural trainings related to all department and shall be imparted by all concerned HODs & tracked by HR in training schedule.
Un controlled copy of training schedule shall be submitted to HR department for monitoring and ensure the training of each department.
Department shall provide the trainings to the employee as per training schedule with information to HR and cross functional department if required and same shall be recorded in “Training Attendance Record”. 
After completion of training, training attendance sheet and evaluated training assessment form shall be enclosed in personal training file by the trainee and shall update the Employee Training Record.
All the trainings as per schedule shall be completed in specified time period (±3 Working days) and if the people not attend the training due to some reason training shall be imparted individually and same shall be recorded in Employee Training Record. In case training not imparted on agreed time Deviation shall be raised. 
Department head shall ensure the compliance of the training schedule.
Qualification of Trainer:
Training shall be conducted by qualified trainer only.
The trainers shall have good understanding of respective subject/ training topic to ensure the understanding of topic/ subject.
The trainers shall be nominated by the head of department based on at least the following but not limited to:
Ø  Subject Matter Expert
Ø  Skills on preparation and delivery of training modules and Good communication skills.
Ø  Section Head of respective SOP shall be the trainer.
Ø  Employee who prepared the SOP.
Ø  Head –QA or Approver of SOP.
Ø  Employee obtaining 100% marks in a SOP qualifies trainer criteria for that SOP.
Person has five or more years of experience in similar field & qualifies the training.
Certificate of qualified trainer shall be approved by department head and authorized by Head QAD and these certificates shall be maintained with their respective training file.
A list of qualified trainer shall be prepared by concerned department head and shall be kept in department file.
General Training Program for contractual employees/ workmen and service provider:
Basic GMP , safety  training  shall be imparted by the HR-Person in vernacular language verbally at the joining of new contract employee with respect to Good Manufacturing  Practices,  Do's and Don’ts, Sanitization, Hygiene and Entry &  Exit Procedure  for the change rooms and same shall be recorded.
Contract/temporary worker should not be the part of training need identification/On Job Training.
Authorized HRD Personal shall conduct the abbreviated GMP training program for contractual employee.
Service provider shall be accompanied by company personnel.  Service provider shall include those parties who are performing activities like calibration, maintenance, filter cleaning, HVAC validation, Painting or civil works, Pest Control etc., this list is not a comprehensive list by itself. Before initiating any activity, service provider shall be instructed by HR department regarding basic norms of GMP, hygiene, safety and entry and exit procedure etc.
Training for Department heads and top management team:
Department head who joined in the company shall be inducted by the HRD personal for all relevant cross functional department heads.
Induction shall be documented as per “Induction Training”
After induction program the employee shall be inducted within the department.
Before starting of the job employee shall read the company policies / applicable procedures & department SOP’s. Same shall be documented by himself as per “Employee Training Record”
Evaluation of this training shall not be done.
After induction and training procedure Job Responsibilities for the employee is prepared by HRD in co-ordination with concern heads or top management.
Documentation and Controlling:
Personal training file of each employee shall be prepared by each department, for new joining.
Training file shall contain the following but not limited to:
Ø  Training Need identification.
Ø  Certificate of Trainee
Ø  Employee Training Record.
Ø  Training Assessment Form, if any.
Ø  Training Attendance Record, if any.
Ø  Job Responsibility.
Ø  Certificate of Qualified Trainer, (if any).
Records of External Training (if any).
Concerned department head shall be responsible for ensuring & Tracking  the training file of individual for the implementation  & evaluation as recorded by individual employee.
The training file of the employee shall be kept in the respective department.
These training file shall be updated by the employee during or after training session.
Personal training file of each employee of concerned department shall be submitted to QA department on yearly basis i.e. end of the year month (December).
After relieving the job, one copy of the relieving letter shall be attached with personal training file.

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