The late Jay Cross, who is credited with coining the term “e-learning”, galvanized the crucial difference between “education” and “training” when he famously said: “If your sixteen year-old daughter told you that she was going to take a sex education course at school, you might be pleased. What if she announced she was going to take part in some sex training at school?”
The terms learning, education and training are often used interchangeably. But as the quote above illustrates there are some important differences. These differences are critical in the regulatory environment where compliance is vital to safe and legal operations.
This article is intended for those people stepping into a regulatory compliance role for the first time. It will help clarify the role and the anatomy of compliance training to help those charged with its oversight become and remain successful.
Learning vs Education and Training
By definition, any conversation about compliance implies two things: a set of standards, and regulatory oversight. For the remainder of this article, we will assume the compliance in question is with the regulations of the United States Government, be that the Nuclear Regulatory Agency, Department of Transportation, OSHA or a thousand others. With that audience in mind, let’s remove one word from the mix: “learning”.
The U.S. Government uses a simple but elegant definition of learning across all of its various enterprises: “A change in behavior as a result of experience.” Learning, therefore, is a fundamentally separate process from training and from education. Training or education is what the company provides; learning is what the student does in response to that training or education – hopefully.
Strategic vs Tactical
Now that we’ve narrowed our conversation to training vs education, it’s important to differentiate these terms as well. Education describes both a process and a knowledge base which is “foundational” in nature. Training, by comparison, describes a process and skill set which is “task-oriented”. In the simplest of terms, education is strategic and training is tactical. When you pursue a college education in physics you might study how a satellite orbits the earth, but you don’t actually launch anything.
While fundamentally different, education and training are by no means mutually exclusive. Many professions such as law, medicine and aviation require a period of training after one’s formal education and before being allowed to practice their craft. A pilot must have both an education in aerodynamics AND be trained in landing procedures before being allowed to fly.
Applied to your mandate for compliance training, these concepts are fairly straightforward to employ. That’s because the U.S. Government is (if nothing else) highly predictable. Regardless of the industry you’re working in, compliance training can be broken down into three fundamental activities:
2. Testing, and
Underlying all of this, of course, are the specific skill set and standards in question. These could be the procedures required to remove an aircraft’s oil filter, or the procedures required to take a random drug test. There will be a task and there will be a defined completion standard.
“You had ONE job!” (Well, three…)
If you’re in charge of compliance training for your organization, you really have three fundamental jobs. First: you must ensure that the required information to complete a task is presented to the learner. This includes the courseware, the lecture, etc. Whatever methodology you use, this is “experience” that will hopefully induce the change in behavior we mentioned previously.
Second: you must verify that the training stuck; that the learner’s behavior has in fact changed. In the dry parlance of the military this is referred to as “demonstrated consolidation of knowledge and skill”; to the rest of us it’s simply testing.
Testing (which the government often refers to as “qualification”) can take as many different forms as training does. The most common form is a written test (because it’s easy to audit -- we’ll come back to this shortly). But testing can also include activities like successfully demonstrating the task in front of an instructor, or solving scenario-based problems for a review board or committee.
Third: you must be able to prove you accomplished the aforementioned first and second jobs. And that you did so within the required time frame. This last step constitutes the record-keeping phase. If testing is the logical corollary to training, then “audit” is the equivalent corollary to record keeping. Audits can be internal or external and the very mention of the term raises the hair on the neck of those just stepping into the compliance role. However, you’ll quickly come to learn that internal audits are your best friend.
The role of regulatory compliance is vital to any organization. Developing a comprehensive understanding of the fundamentals will ensure a long and successful career in keeping your organization on the straight and narrow.
At the core of all of this is the oversight of your organization’s compliance training. Keep in mind the task-oriented nature of training. As you review your regulatory training programs, ensure that they contain specific, measurable outcomes which meet the mandate of the regulation. And make sure you have a tracking mechanism in place to trigger all recurring events in a timely fashion.
Make sure the tasks and outcomes are in fact measured (tested) and that those test results can be subsequently verified. Here again, review the controlling regulations carefully to establish any recurring testing requirements and place them into a tracking program which can push notifications of upcoming deadlines.
Conduct regular internal audits of your training, your testing and your record keeping. Ensure that one element of your internal audit is a soup-to-nuts review of the controlling regulation(s). Monitor for changes in scope, content or requirements that can drive changes in all of the aforementioned areas.
Finally, remember that all government overseers have some form of guidance document they are required to use when inspecting your organization. A few minutes with Google can usually unearth it, and there’s no better guide for your internal audit than the Government’s guidance documents! If you can’t find the guidance on your own, odds are your inspector will be more than happy to provide it. Nothing makes their life easier than an organization which is in full compliance.