Training Does Not Equal Competence: Rethinking Capability in Regulated Operations

Across food manufacturing, logistics and packaging, training has long been treated as the primary lever for compliance. If an incident occurs, the first question often asked is whether the individuals involved were trained. Certificates are retrieved, attendance sheets are reviewed and learning management system records are exported.
Yet when regulatory scrutiny intensifies or a major customer initiates an audit, a more demanding question follows. Were those individuals demonstrably competent at the point of performance?
In regulated operational environments, the distinction matters.

The Regulatory Context: Competence Under Scrutiny

Organisations operating under BRCGS Global Standards are required to demonstrate that personnel are competent to carry out activities that affect product safety, legality and quality. The standards require documented procedures for training and the assessment of competence, alongside evidence that employees understand their responsibilities.
This requirement spans food manufacturers, packaging producers and storage and distribution operations. Whether the risk concerns allergen control, label verification, traceability, hygiene, stock rotation or vehicle checks, the expectation is the same. Staff must be able to perform their tasks correctly and consistently.
Regulators reinforce this emphasis. The Health and Safety Executive has repeatedly highlighted the importance of competence in preventing harm, including in sectors such as food production where flour dust is recognised as a leading cause of occupational asthma in the United Kingdom. Competence is positioned as a protective control, embedded in day to day work.
Against this backdrop, it becomes clear that a record of training attendance is only part of the picture. During a BRCGS audit, the expectation is not simply that training records exist, but that organisations can demonstrate control. Auditors routinely triangulate evidence by reviewing documentation, interviewing staff and observing activities on the floor. If an operator cannot clearly explain an allergen control step or a label verification process, the existence of a completed training module offers limited protection.

When Incidents Expose the Gap

Consider a product recall triggered by an undeclared allergen. In the United Kingdom, undeclared allergens remain one of the most common causes of food recalls. According to Food Standards Agency annual incident data, allergen related issues have accounted for approximately one third of food recalls in recent years, frequently making them the single largest category of recall [1]. The Food Standards Agency routinely publishes recall notices, and allergen labelling failures consistently feature among the leading causes cited in annual summaries of food incidents [1].
In such cases, scrutiny rarely focuses on a single organisation. The food manufacturer may be examined for failures in ingredient declaration or label approval. The packaging supplier may be asked to demonstrate how artwork was verified and how changes were controlled. Logistics partners may be drawn into traceability reviews where product segregation or stock handling is relevant.
In each case, the spotlight turns to the people who executed the tasks. Who approved the label? Who verified the allergen statement? Who uploaded the correct artwork version? Who confirmed segregation controls in storage and dispatch? And crucially, were they competent to do so?
If the only evidence available is that those individuals attended a classroom session months earlier, the defence can appear fragile. The operational reality is that knowledge delivered in a detached setting does not automatically translate into reliable performance on the line, in the warehouse or at the packing bench.
This is where the hypothesis becomes unavoidable. Training does not equal competence.

The Limits of Traditional Training Models

Many organisations continue to rely on periodic classroom sessions or generic eLearning modules to address regulatory requirements. These approaches have value. They provide structured information, they can introduce new concepts and they can ensure a baseline of awareness.
However, operational work is contextual. The decision to reject a pallet, to escalate a discrepancy, to halt a line or to quarantine stock occurs in a live environment shaped by time pressure, production targets and competing priorities. The cues that guide action are embedded in the physical workspace and the workflow itself.
Situated learning theory, widely discussed in educational research, proposes that learning is inseparable from the context in which it is applied. In frontline environments, competence develops through participation in real tasks, supported by coaching, feedback and reinforcement.
When employees are removed from the production floor for a half day session, two consequences follow. Output is reduced while they are absent, and the learning experience is detached from the environment in which the behaviour must be executed. The transfer from classroom to shop floor becomes an assumption rather than a structured process.
In high risk, high volume operations, assumptions are rarely sufficient.

Competence as a Defensible Position

For cross regulated organisations, competence must withstand external challenge. BRCGS audits, customer visits and regulatory inspections increasingly probe beyond training records. Auditors ask operators to explain procedures, to describe critical limits and to demonstrate understanding of why controls exist.
In parallel, senior leaders are conscious of litigation risk and brand exposure. Product recalls in the food sector continue to attract significant media attention. The Food Standards Agency regularly publishes recall notices, many of which relate to labelling errors and undeclared allergens. Each incident raises questions about process control and human performance.

A defensible competence framework therefore needs to answer three questions.
1.    Has the individual been given access to the required knowledge?
2.    Has their ability to perform the task been assessed in context?
3.    Is there evidence that competence is maintained over time?
Training addresses the first question. Competence frameworks address all three.

The Operational Cost of Competence Gaps

Competence gaps do not only manifest during recalls or audit findings. They also surface in everyday inefficiencies.
In logistics environments, errors in stock rotation or scanning can compromise traceability and inflate waste. In packaging operations, incorrect machine settings or artwork handling can generate rework and scrap. In food manufacturing, deviations from cleaning procedures or CCP monitoring can trigger investigations and downtime.
Industry reports from organisations such as the Chartered Institute of Logistics and Transport and the Food and Drink Federation have consistently emphasised the productivity challenges facing UK supply chains, including skills shortages and workforce turnover. When turnover is high, the pressure to onboard quickly can result in compressed training cycles that prioritise speed over depth.
Without structured competence validation, organisations risk embedding variability into critical processes.

From Training Events to Capability Systems

If training is only one component of competence, what should replace the event based mindset?
First, competence should be defined at task level. For each role, the organisation must identify the specific activities that impact safety, legality and quality. This mapping exercise links directly to hazard analysis, quality management systems and BRCGS clauses.

Second, assessment must occur in the operational setting. Observation, supervised practice and structured sign off by qualified assessors create evidence that the individual can perform the task under normal working conditions.

Third, competence must be dynamic. Changes in legislation, product range, equipment or process should trigger targeted reassessment. Refresher training should be informed by risk and performance data rather than arbitrary calendar intervals.

Fourth, documentation must be accessible and auditable. Digital platforms can support this by linking training content, task checklists, assessments and revision histories within a single system. The objective is not simply administrative convenience but rather to ensure that evidence of competence can be produced quickly and confidently.

Aligning with BRCGS Expectations

BRCGS Global Standards for Food Safety, Packaging Materials and Storage and Distribution require that personnel performing work affecting product safety, legality and quality are suitably trained and demonstrably competent [2].

The standards also require that training and competence are reviewed for effectiveness.
A competence led approach strengthens compliance with these expectations. During audits, non conformances frequently arise not because procedures are absent, but because their application is inconsistent or poorly evidenced. When allergen risk assessments, label approval workflows and change management processes are explicitly linked to named individuals and validated task sign offs, organisations are better positioned to demonstrate effective implementation rather than theoretical compliance.

In allergen management specifically, this linkage is critical. Guidance from the Food Standards Agency and industry bodies such as the Food and Drink Federation stresses the importance of robust procedures, clear labelling controls and effective staff training to prevent allergen incidents [3].

However, procedures and training alone are insufficient if there is no structured confirmation that individuals can apply them correctly in live scenarios. Auditors increasingly expect to see objective evidence that competence has been assessed in practice.
In this sense, competence data becomes both a diagnostic tool and an audit defence mechanism rather than a compliance formality.

The Role of Technology in Bridging the Gap

The landscape of learning management systems is crowded, and the term learning carries varied interpretations. In operational settings, the focus must extend beyond content delivery.
Platforms that support frontline capability need to integrate on the job task management, assessment workflows and real time visibility for supervisors. They should enable micro learning linked to specific activities, reinforce expectations at the point of use and capture evidence of performance.

This approach aligns with research in adult learning, which indicates that retention improves when learning is immediately applied and reinforced. It also aligns with the realities of shift based operations, where time away from the line is limited.

For food manufacturers, logistics providers and packaging organisations, the priority is operational integrity. Technology should serve that priority by strengthening competence where work actually happens.

Leadership, Culture and Accountability

Competence frameworks cannot operate in isolation from culture. Supervisors and managers must understand their role in coaching, observation and feedback. Accountability for competence should sit alongside accountability for output and efficiency.

When competence is treated as a shared responsibility, frontline staff are more likely to view assessments as support rather than surveillance. Clear expectations, consistent standards and visible follow through from leadership reinforce the message that capability is central to performance.

In regulated sectors, culture is frequently cited as a contributing factor in both success and failure. Embedding competence into daily routines signals that compliance and quality are operational priorities rather than periodic exercises.

Building Evergreen Value

The argument that training does not equal competence resonates beyond a single regulatory cycle. Workforce mobility, automation and evolving customer expectations will continue to reshape operational roles. As tasks change, so too must the definition and validation of competence.
Organisations that invest in structured, contextualised capability systems position themselves to adapt. They can onboard new employees more effectively, respond to audit findings with confidence and demonstrate due diligence when incidents occur.

In a congested market of learning platforms, the differentiator is clarity of purpose. The objective is not to deliver more courses but instead to ensure that every individual performing a regulated task can do so safely, legally and efficiently, with defensible credible evidence to support that claim.

Conclusion

For food manufacturing, logistics and packaging organisations operating under BRCGS and related regulatory frameworks, the stakes are high. Product safety, brand reputation and worker wellbeing depend on consistent execution at the frontline.
Allergen management illustrates the challenge clearly. A single failure in artwork approval, specification transfer or stock segregation can trigger a recall with significant financial and reputational consequences. The FSA has repeatedly emphasised that getting allergen information right is critical to protecting consumers [1]. In that environment, competence in task execution is a core control.

Training remains an essential component of capability. Yet it is only the starting point. Competence requires contextual assessment, ongoing validation and leadership commitment.
This is where platforms purpose built for operational capability differ from traditional learning management systems. Nvolve is designed around frontline task execution rather than course administration. The platform enables organisations to map roles to critical tasks, link those tasks directly to risk and compliance requirements, and manage structured on the job assessments within the operational environment. The approach reflects the emphasis on contextualised frontline learning explored previously in Nvolve’s discussion on rethinking frontline training [4].

Supervisors can assign and verify task based competence, capture evidence in real time and maintain a clear audit trail aligned to quality and safety standards. Training content, standard operating procedures and revision histories can be connected directly to the activities they govern, ensuring that updates in process or regulation are reflected in the expectations placed on frontline staff. Visibility across sites and shifts provides leadership teams with defensible data on who is competent to perform which activities at any given time.

In regulated operations, that level of integration changes the conversation. Instead of presenting attendance records, organisations can demonstrate structured capability frameworks tied to real tasks and validated performance. During an audit, this enables a shift from reactive explanation to proactive evidence. Managers can show exactly which individuals are signed off against allergen critical tasks, when they were assessed, by whom, and against which version of the procedure.
That level of traceability strengthens internal governance and reduces the risk of major non conformances linked to training and competence clauses. It also signals to auditors and customers that competence is treated as a control measure embedded within the quality management system, not as an administrative exercise conducted in parallel.

When incidents occur, organisations must be able to demonstrate more than attendance. They must show that their people were capable, assessed and supported in the environments where critical decisions were made. In regulated operations, that distinction can define the difference between vulnerability and defensibility.
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References

[1] Food Standards Agency, Food Alerts and Recalls. Available at: https://www.food.gov.uk/news-alerts/alerts
[2] BRCGS Global Standards, Food Safety Issue 9; Packaging Materials Issue 6; Storage and Distribution Issue 4. Clauses relating to training and competence requirements.
[3] Food Standards Agency, Industry guidance on allergen labelling and management. Available at: https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses
[4] Nvolve Group, Rethinking Frontline Training: Why Traditional Training is Failing at the Frontline. Available at: https://nvolvegroup.com/blog/rethinking-frontline-training-why-traditional-training-is-failing-at-the-frontline