Purpose: To assess whether your organization can demonstrate due diligence by proving that required training was identified, delivered, documented, refreshed, and enforced.
1. Training Inventory & Coverage
- A master list exists of all mandatory training by role, hazard, and jurisdiction
- Training requirements are reviewed at least annually
- New roles and job changes trigger a training review
- Contractors and temporary workers are included where required
Evidence to produce: Training matrix by role or job classification
2. Individual Training Records
- Each worker has an individual training record
- Records clearly show: Course title, Date completed, Delivery method (eLearning, ILT, toolbox, etc.), Instructor or provider
- Records are retained even after an employee leaves
Red flag: Training completed but not tied to a specific individual
3. Proof of Competency (Not Just Attendance)
- Training includes a knowledge check, quiz, or assessment
- Practical or hands-on training is documented where required
- Supervisors sign off where competency must be observed
- Refresher training is tracked and enforced
Evidence to produce: Quizzes, evaluations, sign-offs, or LMS completion reports
4. Training Delivery Consistency
- Standardized training content is used across locations
- Outdated materials are removed from circulation
- Language accessibility is addressed (English, Spanish, French, etc.)
- Remote and offline workers are included
5. Record Storage & Retrieval
- Training records are stored in one central system
- Records can be retrieved within 24 hours of a request
- Backups exist and are tested
- Records are protected from alteration or loss
Reality check: If an inspector asked today, could you produce records by name and by topic?
6. Incident & Enforcement Readiness
- Training records are linked to incident investigations
- Gaps trigger corrective action and retraining
- Near misses are used to update training content
- Training history can be shown for injured workers
7. Management Oversight
- Leadership receives training compliance reports
- Overdue training is visible and escalated
- Supervisors are accountable for team compliance
- Training completion is enforced, not optional
Readiness Score
- 0–7 gaps: High legal exposure
- 8–14 gaps: Moderate risk, poor defensibility
- 15+ gaps: Strong due diligence posture
