AS9100D training records should show competence, not attendance alone. Keep the evidence behind each competence decision, a record of the awareness the 2016 revision added (of conformity, product safety and ethical behavior), and counterfeit-part prevention training (clause 8.1.4) for the roles that need it, such as procurement, inspection and design.
Edition matters. This article refers to AS9100D (9100:2016). IAQG's standards register, revised May 2026, lists AS9100 Rev D (2016-09-20) as the current issued version in the Americas, alongside EN 9100:2018 in Europe and JIS Q 9100:2016 and KS Q 9100 in Asia Pacific. SAE's abstract says the standard includes the ISO 9001:2015 requirements and adds aviation, space and defense requirements. ISO now lists ISO 9001:2015 as withdrawn and replaced by ISO 9001:2026, so confirm the current 9100 revision with IAQG and your certification body before relying on clause numbers. Our ISO 9001 training records guide covers the ISO 9001 side.
- Record the competence decision as well as the attendance: who assessed whom, on which task, when and with what result.
- Record awareness of product or service conformity, product safety and ethical behavior, not only the quality policy.
- Map counterfeit-part awareness and prevention training (clause 8.1.4) to the roles that need it, such as procurement, inspection and design.
- A software record supports the evidence; it does not decide certification or an audit outcome.
AS9100D clauses that touch training records
| Clause and source | What the public material says, and a record that answers it |
|---|---|
| 7.2 Competence (from ISO 9001:2015)APG competence paper | Keep suitable documented evidence of competence; the organization decides which evidence has value. Record: the completion, plus a competency assessment with the outcome, the assessor and the date. |
| 7.3 AwarenessIAQG 9100:2016 overview | The 2016 revision added awareness of each person's contribution to product or service conformity and to product safety, and of the importance of ethical behavior. Record: the briefing, with the signed sheet attached. |
| 8.1.3 Product safetyIAQG 9100:2016 overviewIAQG auditor guidance | A new clause in 9100:2016; IAQG's guidance lists product safety training and awareness campaigns. Record: the product safety course on the roles that need it. |
| 8.1.4 Prevention of counterfeit partsIAQG 9100:2016 overviewIAQG 9100:2016 FAQ | A new clause; IAQG lists training in the awareness and prevention of counterfeit parts as one way to implement it, for procurement, inspection and design personnel. Record: the course as required training on those positions. |
| 8.5.1.2 Special processesIAQG auditor guidance | IAQG's guidance lists qualification of persons, through training, workplace assessment and competency assessment, and requalification to keep a process approved. Record: an assessed outcome with a reassessment date. |
| 9.2.2 Internal auditorsIAQG clarifications | IAQG says there is no specific 9100-series training requirement for internal auditors. They need to be competent under clause 7.2, against the organization's own internal auditor competence requirements, which IAQG says include understanding of 9100, awareness of 9101, the IAQG Supply Chain Management Handbook and ISO 19011. Record: those topics as required training on the internal auditor position, with an assessed outcome. |
Competence: keep the decision, not only the attendance
Clause 7.2 comes from ISO 9001:2015. The ISO 9001 Auditing Practices Group (APG), an informal group of experts from ISO/TC 176 and the International Accreditation Forum (IAF), explains in its competence paper that the organization keeps suitable documented evidence of competence and decides which of that evidence has value. The same APG paper says that “participation at the course alone does not necessarily provide evidence that the trainee is competent” (edition 2, 2022, printed page 6).
IAQG's auditor guidance for clause 7.2 lists defined competency requirements, skills matrices, periodic assessment of competency, and evidence such as training certificates, on-the-job training and workplace assessments. A skills or competency matrix keeps the assessment beside the training, so attendance is not mistaken for competence.
People doing work under your control can include individuals at external providers, as the APG paper notes, so agency and contract workers belong in the same records. Every TrainGrid workspace starts with the employment type External (agency / contract) for them.
Awareness: conformity, product safety and ethics
IAQG's 9100:2016 overview says the 2016 revision added a requirement for people to be aware of their contribution to product or service conformity, their contribution to product safety, and the importance of ethical behavior. It lists ways to build that awareness, from direct communication between managers and employees to communication campaigns and formal training. IAQG's FAQ adds that individuals should be able to explain their role and how they contribute to quality.
IAQG's auditor guidance lists what to consider for clause 7.3, including the quality policy, changes to relevant documented information, safety awareness training that covers product end use, and ethics training programs. Clause 8.1.3 on product safety is new in 9100:2016, and the guidance for it lists product safety training and awareness campaigns. IAQG's FAQ explains that clause 8.4.3 m) is meant to ensure that external provider personnel understand their role in conformity, product safety and ethical behavior.
A short briefing on paper can be the awareness record when it is filed against each person. In TrainGrid, attendees can be marked complete together, with the signed sheet uploaded once and attached to each of their completions; the mark-complete guide shows the steps. If your program repeats the briefing, set Repeat every (days) on the course to its interval; the public IAQG material cited here names none.
Counterfeit-part prevention training
Clause 8.1.4 is new in 9100:2016. IAQG's overview describes it as requirements for the prevention of counterfeit parts, with a note giving examples of the associated processes. IAQG's FAQ lists training in the awareness and prevention of counterfeit parts as one way to implement the clause: procurement personnel in trusted source selection and requirements, inspection personnel in the prevention of counterfeit items, and design personnel in obsolescence management. The auditor guidance adds functional training and awareness campaigns.
IAQG's 9100-series clarifications state that its 9100-series teams expect some level of product safety and counterfeit-part prevention in every aviation, space and defense organization, and that treating these clauses as not applicable would be rare.
For US defense contracts, DFARS clause 252.246-7007 lists the training of personnel first among the areas a contractor's counterfeit electronic part detection and avoidance system must address. The clause states when it applies and how it flows down to subcontracts for electronic parts.
In TrainGrid, declare the counterfeit-part course as required training on positions such as buyer, receiving inspector and design engineer, and assign it to the people in them. The Workforce Competency report then compares people with the courses their position requires and names the gaps; the competency functions guide shows the steps.
Special processes and qualified operators
For special processes (clause 8.5.1.2), IAQG's auditor guidance lists qualification of persons, for example through skills matrices, training, workplace assessment and competency assessment, and lists requalification of persons among the conditions to keep a process approved. IAQG's FAQ also lists competency matrices, on-the-job training and succession planning among ways to keep organizational knowledge under clause 7.1.6; how to build a training matrix covers the grid itself.
In TrainGrid, tick Competency assessment required on the special-process course and, where sign-offs must be renewed, set Reassess every (days). Each assessment is recorded as an outcome such as Competent, Competent with conditions or Not competent, not as a certification level; the competency assessment guide shows the steps.
Keeping AS9100 training evidence in TrainGrid
- Attach the signed checklist to the record as Competency evidence, which keeps it apart from a Certificate or an Attendance sheet.
- When a procedure changes, create a new course version. Completed records keep the version they were completed against, and the course versions guide explains the retraining and reassessment options.
- For an audit, TrainGrid's Viewer (auditor) role is read-only, and changes to training records made through the application are written to an append-only audit log of who did what, to which record and when.
When an LMS completion is not enough audit evidence goes further into what an auditor asks to see.
TrainGrid is standard-agnostic and does not certify compliance. It holds no AS9100 certification, is not affiliated with IAQG or SAE International, and does not judge competence: your assessors record each outcome, and TrainGrid works out training and qualification status from those records. This article paraphrases public IAQG, SAE and ISO material about AS9100D. It is not the text of the standard or audit advice, and it does not cover export-control or cybersecurity requirements for defense work.