Summary
In short
- ISO 45001 clause 7.2 and ISO 9001 clause 7.2 both require competence to be determined, achieved and evaluated for effectiveness. Attendance records do not evidence the third.
- Powered industrial truck operation, crane operation and several other activities require a documented practical evaluation separate from instruction, repeated on defined triggers.
- The matrix should be built from tasks and equipment, not from job titles. Two people with the same title frequently do different work in different areas with different hazards.
- Expiry alerts need enough lead time to book, deliver and record a renewal, which for externally provided courses is often sixty to ninety days rather than thirty.
- Role change is the transition that breaks a matrix. New competencies go untrained and old ones stay recorded, so the matrix reports a person as qualified for work they no longer do and unqualified for work they now do daily.
- The population most often missing from a matrix is the one working right now: agency staff, contractors, occasional cover and managers holding rarely used credentials.
What it is
What it is
What is a competency matrix?
A competency matrix maps the competencies each role requires against the people holding that role, showing for each combination whether the person holds it, how it was assessed, when it was achieved and when it expires. It makes gaps visible by role, by person and by area.
What is the difference between training and competency?
Training is an input, an activity delivered to someone. Competency is a demonstrated ability to perform a task to a required standard. Several standards require the effectiveness of training to be evaluated, and some require a documented practical evaluation, which is why a matrix built from course attendance records answers a different question from the one being asked.
When to use it
When to use it, and when not to
The matrix is a currency and gap view. It depends on other records for its content and should not attempt to be them.
Use it for
- Establishing what each role requires, so a vacancy or role change immediately shows the gap
- Reporting currency and gaps by area, shift or role for planning and audit
- Controlling access where competency is a prerequisite for a task or an area
- Planning training demand from actual gaps rather than from an annual budget cycle
- Demonstrating to an auditor who is authorised for a controlled activity, on demand
Not for
- The training record itself, which holds the delivery detail, trainer, content and date
- Practical assessment records, which capture what was observed and by whom
- The licence or certificate, which is issued externally and should be verified at source
- Performance management, which is a different judgement about a different thing
- Job descriptions, which describe the role rather than the competencies it requires
Standards
What it is built against
Competence requirements are spread across management system standards and equipment-specific regulations, and the equipment-specific ones are more prescriptive.
| Clause | Requirement | Where it lands |
|---|---|---|
| ISO 45001 cl.7.2 | Determine competence, ensure competence on the basis of education, training or experience, evaluate effectiveness | Requirement definition |
| ISO 9001 cl.7.2 | Equivalent competence requirement for people affecting quality performance | Requirement definition |
| OSHA 1910.178(l) | Powered industrial truck training plus documented performance evaluation, re-evaluated at least every three years | Assessment method |
| OSHA 1910.147(c)(7) | Lockout training certified by employee name and training dates, with retraining on defined triggers | Currency and expiry |
| OSHA 1910.146(g) | Confined space training by role with certification, and retraining when duties change | Role mapping |
| FMCSA 49 CFR 391 | Driver qualification file including licence and medical certificate with expiry | External credentials |
| ISO 45001 cl.7.3 | Awareness of the OH&S policy, hazards and the ability to remove oneself from danger | Baseline awareness |
| MSHA 30 CFR 46/48 | New miner, task and annual refresher training with records on Form 5000-23 | Sector-specific |
What it does not cover
- The training delivery record, which holds content, trainer and date and is referenced by the matrix rather than replaced by it.
- Practical assessment records, which capture what was demonstrated, by whom and against what standard.
- External licences, which must be verified at source rather than accepted as a photocopy.
- Medical clearance, which is a separate confidential record and should appear in the matrix as a status only.
- Succession and development planning, which uses the matrix as an input but asks a different question.
Filling it in
Filling it in well
A matrix is only as useful as the discipline behind two fields: how the competency was evidenced, and when it stops being valid.
A competency should describe something a person can be observed doing: operate a counterbalance truck, apply a machine specific energy control procedure, perform a pre-operational sanitation inspection. Competencies defined broadly, such as safety awareness, cannot be assessed and cannot fail, which makes them decorative.
Attendance, knowledge check, observed practical assessment, external certification. These carry different weight and different regulatory standing. A matrix showing a green cell without the method behind it cannot support a decision about whether someone can do the work tonight.
The alert must fire early enough to book a course, complete it and record it before the credential lapses. For externally delivered training that is frequently sixty to ninety days. Alerting on the expiry date guarantees a gap during which the person either stops working or works without a valid credential.
When someone moves roles, the matrix should immediately show the competencies the new role requires and they do not hold, and should stop showing them as current for work they no longer do. Without that trigger the matrix reports the previous organisation indefinitely, and role change is the single largest source of matrix drift.
Audit findings
Common audit findings
Competency findings are among the easiest for an auditor to generate, because the evidence is either present or it is not.
| Finding | Clause | What fixes it |
|---|---|---|
| Matrix records attendance where the standard requires a documented practical evaluation. | 1910.178(l)(6) | Record the evaluation as a distinct event with the evaluator named. |
| Credentials expired but the person still shown as current and still performing the task. | ISO 45001 cl.7.2 | Alert with real lead time and prevent task assignment on lapse rather than reporting it. |
| Role change with no reassessment; competencies for the previous role still recorded as current. | ISO 45001 cl.7.2 | Trigger a matrix review on role change, in both directions. |
| Contractors and agency workers absent from the matrix entirely. | ISO 45001 cl.8.1.4 | Include everyone who performs the task on your site, whoever employs them. |
| External licences accepted as photocopies without verification at source. | FMCSA 391 / equivalent | Verify with the issuing body where a register exists, and record the verification event. |
| Competencies defined too broadly to be assessed or failed. | ISO 45001 cl.7.2 | Define at task level, so the competency describes an observable activity. |
| Effectiveness of training never evaluated, only delivery recorded. | ISO 9001 cl.7.2 | Observe the task after a period; the standard asks whether the action worked. |
| Matrix built by job title, missing area and equipment specific requirements. | ISO 45001 cl.7.2 | Derive requirements from tasks and equipment actually encountered. |
| No visible authorisation at the point of use, so an unauthorised person can start the task. | 1910.178(l) | Make authorisation enforceable, not just recorded. |
| Refresher triggered only by calendar, never by incident, observation or procedure change. | 1910.147(c)(7) | Add event triggers, particularly procedure revision, which is missed most often. |
Worked case
Case in point: green on the matrix, absent on the shift
A distribution site reported 97 percent competency currency. The matrix was maintained, reviewed monthly and shown to auditors. During an incident investigation after a reach truck collision, the investigator asked how many people on the night shift were authorised to operate a reach truck.
The matrix could not answer. It held competency by person and by course, but not by shift, and the counterbalance and reach truck authorisations sat under one heading called forklift. Of eleven people rostered that night, four held reach truck evaluations and seven held counterbalance only. The operator involved was in the second group and had been running the reach truck for six months because the site was short and he was capable.
The 97 percent was accurate against what the matrix measured. It measured whether people held a forklift competency, not whether they held the right one for the truck they were on.
Definitions
Definitions and key terms
- Competency
- A demonstrated ability to perform a specific task to a required standard, distinct from having attended training about it.
- Currency
- Whether a held competency remains valid, given its expiry and any triggering events since it was achieved.
- Practical evaluation
- Observation of the person performing the task, required in addition to instruction by several equipment standards.
- Authorisation
- Permission to perform a task, granted on the basis of competency and enforceable at the point of use.
- Gap
- A required competency a person does not hold, or holds but is no longer current, for a role they currently occupy.
- Refresher trigger
- An event requiring retraining regardless of calendar: incident, observed unsafe practice, procedure change, equipment change or role change.
- Skills matrix
- Frequently used interchangeably with competency matrix, though it sometimes describes capability breadth for planning rather than authorisation.
- Verification at source
- Confirming an external credential with the issuing body rather than accepting a copy provided by the holder.
FAQ
Frequently asked questions
Does attendance prove competence?+
No, and several standards say so explicitly. ISO 45001 and ISO 9001 both require the effectiveness of training to be evaluated. Powered industrial truck operation requires a documented evaluation of performance in addition to instruction. For any task where getting it wrong is serious, a signature on an attendance sheet is not defensible evidence.
How much lead time should expiry alerts have?+
Enough to book, deliver and record the renewal. For internally delivered refreshers thirty days may suffice; for externally provided certification, medical assessments or anything requiring a scheduled course, sixty to ninety days is realistic. The test is whether anyone has ever lapsed while a renewal was being arranged.
Should contractors be in the matrix?+
Yes, for the tasks they perform on your site. You carry exposure for hazards created by contractors under your control, and an inspector asking who was authorised to perform a task will not accept that the person was employed by someone else. Their competency should be verified rather than asserted, and recorded where you can retrieve it.
What triggers a competency review?+
Role change, equipment change, procedure revision, an incident or near miss involving the task, observation of unsafe or incorrect practice, and the calendar expiry. The procedure revision trigger is the one that most often fails, because it requires connecting a document change to a training obligation and usually nothing does.
How granular should competencies be?+
Granular enough to distinguish activities that are genuinely different. Counterbalance and reach truck are different competencies because they handle differently and have different failure modes. Grouping them improves your currency percentage and removes the matrix's ability to answer whether a specific person should be on a specific machine.
The agents
What the agents do with it
The matrix is a view. What fails is the currency behind it, the role change nobody processed, and the population that never entered it.
Holds the matrix against roles, tasks and equipment, tracks currency and expiry per person, and raises requirements automatically on hire, role change or new equipment.
Watches procedure revisions and incidents for events that should trigger retraining, and raises the requirement rather than waiting for the anniversary.
Brings contractor and agency competency into the same view, verified rather than asserted, so the matrix covers everyone on site.
Enforces competency as a prerequisite where a task or area requires it, so authorisation is a control rather than a record.
This template lives in KnowTrain — training and credentials. Induction, competency, toolbox talks, refreshers and expiry tracking.
Meet KnowTrain→Sources
Sources
- ISO 45001:2018 clauses 7.2 and 7.3
- ISO 9001:2015 clause 7.2, competence
- 29 CFR 1910.178(l), powered industrial truck operator training and evaluation, OSHA
- 29 CFR 1910.147(c)(7), lockout training and retraining, OSHA
- 49 CFR Part 391, qualifications of drivers, FMCSA