Compliance Training: No More Passive Learning!

By November 9, 2020November 10th, 2020LTEN Focus On Training

FEATURE STORY – By Vivian Bringslimark

Compliance Training: No More Passive Learning!

Only 10% are active learners. Compliance training doesn’t have to be this way.

Over and over and over again, I’ve seen learners sitting in training rooms, conference rooms and even makeshift cafeteria training rooms with their heads down, while one person is standing in the front of the room, at the podium or near the wall next to a projected slide. And I cringe; I can’t tell who’s more bored, the participants or the talking head speaker.

I want to interrupt and announce, “Excuse me, there will be no more passive learning in this room, at least not on my watch!” And yet, this scene is so prevalent, we’ve come to expect compliance training to be delivered this way. We even bring our laptops and tablets to multitask.

Attendees Are in Listen-Only Mode

In fact, Randy Emelo in January 2013 issue of Chief Learning Officer magazine wrote that 60% of people are passive learners. They quietly take in the new information, but they don’t engage with it. Another 30% are blocked, closed off from even hearing about or trying to learn something. Sadly, only 10% are active learners. But compliance training doesn’t have to be this way.

Of all of the Good Manufacturing Practices (GMP) topics that get added to the refresher agenda, Good Documentation Practices (GDPs) has to be by far the driest and most boring content to deliver and for the learners to sit through. The “rules” never change and every year we repeat (“refresh on”) them because as an industry, we still can’t get our GDPs right. Perhaps lecture-only is a realistic example of the least effective approach for GMP Refreshers.

Higher-Order Thinking Happens in an Active Learning Environment

So, why do I get into teaching GDPs?  For a number of reasons, first and foremost is data integrity. If we can’t get data integrity requirements right, what success will there be for us to adhere to an overall data governance program? But mainly, it’s for the learners: It’s an opportunity for them to learn the principles behind the GDPs, not just recite what ALCOA stands for (attributable, legible, contemporaneous, original and accurate).  This means raising the level on Benjamin Bloom’s Taxonomy of Learning Objectives from [Remembering and Understanding] to [Applying] back on the job. Learning objectives that are too low on the taxonomy don’t give learners the chance to think critically enough about what they are learning.

Do I Have Your Attention Now?

Being able to use site-specific examples is priceless. Talk about relevancy. In one class, we had to pause for a lengthy FDA inspection that involved a lot of records review. Unfortunately, examples of questionable GDPs were identified and discussed in the inspection front room with either the individuals directly involved or the identified lead in cases where the employee no longer worked at the company.

During the back-room debriefing with these individuals, I asked them to share their
experience. For most, they shared their amazement at how “seemingly innocent” annotations escalated into a front-room interview defending their workaround.  Another commented about the value of what one extra sentence would have
provided him. The original individual had long left the company and took “the story” with her. It got real, really fast for these folks.

Training Is an Awesome Responsibility

“Learners put tremendous trust in us, because as trainers, we spend their most precious property – their time.” Michael Allen, Training magazine

It’s time to step away from the podium and put yourself in your learners’ shoes.  Think about the experience first. Ask yourself, what’s it going to be like to attend the GxP Refresher you are designing?

Then think about interactivity. What can our learners do that will make the content seem more tangible? How about learning from “mistakes”? Deviations are great learning opportunities. They are like mini-case studies and this-really-happened here
incidents. Split up the attendees, divide them into small groups or pick a partner. This allows for more peer-to-peer interaction and ensures better engagement.

And in my experience, it is the No. 1 reason why a “facilitated discussion” with the
entire audience such as Q&A can crash and burn. Everyone is waiting for someone to ask the first question or they are secretly hoping that no one asks a question so they can end the session. It is much more effective to break them into groups. Peers tend to hold each other accountable, so passive learners can’t hide from their peers in small groups.

Also think individualism. The one-size-fits-all approach doesn’t meet today’s diverse group of learners. Some believe that offering variety and choice enriches the overall learning experience. It honors the inherent diversity of learners at any given moment and it stimulates intrinsic motivation because the freedom to choose is self-directed. If feasible, let them choose which group to join and which example best matches their work situation. It supercharges the content’s relevance.  Providing choice also  enhances and reinforces learning; learners come to the same conclusions without enduring repetitive content.

Completing activities isn’t enough. Provide opportunities for the learners to debrief the activities as well. Learners need to reflect on their experience to gain insights about the learning that will reinforce the compliance behaviors we seek.

No more passive learning in this room, please. Your learners will thank you. They
just might become cooperative, collaborative and, dare I say, more active?

Vivian Bringslimark is president of HPIS Consulting. Email Vivian at



About LTEN

The Life Sciences Trainers & Educators Network ( is the only global 501(c)(3) nonprofit organization specializing in meeting the needs of life sciences learning professionals. LTEN shares the knowledge of industry leaders, provides insight into new technologies, offers innovative solutions and communities of practice that grow careers and organizational capabilities. Founded in 1971, LTEN has grown to more than 3,200 individual members who work in pharmaceutical, biotech, medical device and diagnostic companies, and industry partners who support the life sciences training departments.

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