Insights / Learning and development
How do you audit your training against your operating conditions?
Ten questions, three possible answers and one afternoon. This is the audit that pulls the whole Urban and Suburban Employer Series together.
By McKinley Malbrough III, J.D., MS-HRM. Published October 25, 2026. Last reviewed October 25, 2026.
Short answer
Answer ten questions with yes, partly or no, and write the evidence beside each. Five cover your conditions, from session times to languages and hybrid staff. Five cover delivery and records, from supervisor tracks to make-up paths. Fix the nos that touch a legal requirement first, then pick three fixes to finish this quarter.
Who this is for: Owners, HR leads and trainers at California employers with 10 to 150 employees who run required training.
What does this audit check?
It checks whether your required training fits the conditions your people actually work in. The law sets what must be taught. Your operating conditions decide whether a session can be attended, understood and documented. This audit looks at the second half.
It is the last part of a seven-part series, and it pulls the other six together. Part 1 sets out the urban and suburban conditions. Part 2 lists the questions I ask first. Part 3 covers scheduling for transit riders, Part 4 language, Part 5 records and Part 6 what suburban employers need. The audit turns them into ten questions you can answer in an afternoon.
I wrote it for employers with 10 to 150 people in California. It is a planning tool, not legal advice, and I am not an attorney. Where a question touches a rule, I link the source.
How do you score it?
Answer each question with one of three words: yes, partly or no. Yes means you can show it today. Partly means it is true for some sessions or some sites. No means you cannot show it, or you have not looked.
Do not score generously. A partial answer is useful, because it tells you where to start. Write the evidence next to each answer: a calendar entry, a roster, a record folder, a translated file.
When you finish, count the nos first, then the partlys. Fix the nos that touch a legal requirement before the ones that touch convenience.
Give the audit a date and an owner. Two people scoring the same question separately often disagree, and the disagreement shows you where the evidence is thin.
Which five questions cover your conditions?
- Do your session times fit the close crew and the commute? Check the end time against the last reliable transit departure for the people who ride. Part 3 covers the pay and attendance rules around it.
- Do your examples match the hazards on your site? Workplace violence training has to cover job-specific hazards (Lab. Code 6401.9(e)(2)(D)). Cash, stock, public access and isolated shifts change the scenarios.
- Do you know the language each person wants for training and notices? The roster should show it by site. Part 4 sets out where the law names language.
- Is your roster sorted by city? A team that lives and works in several cities may meet local rules the state rules do not cover. Confirm the current text for each city before you add a local section.
- Do you know how many staff are hybrid or remote, and how they are trained? A live online version with its own facilitator gives remote staff the same chance to ask questions as the on-site group.
Which five questions cover your delivery and records?
- Does each supervisor have a track of their own? The harassment prevention training statute sets two hours for supervisors and one hour for other employees where the employer has five or more employees (Gov. Code 12950.1).
- Does each session have a named trainer who can answer questions in the language of the room? Workplace violence training requires interactive questions and answers (Lab. Code 6401.9(e)(2)(F)).
- Do you keep the ten record fields for each session? Part 5 sets out the fields and the retention periods I could confirm at the source.
- Is there a make-up path for people who missed a session? The roster should show who still owes a session and by when.
- Do new hires get required training on a schedule that fits their first week? Part 2 lists the hiring and onboarding questions I ask.
How do you read your results?
Group your answers by theme. If most of the nos sit in the conditions questions, your content is probably sound but your delivery does not fit the team. If they sit in the delivery questions, your sessions may be well designed but difficult to prove.
Look for a pair of nos that share a cause. A team that cannot attend because of the schedule and a team without make-up records are often the same problem. Fix the schedule and the make-up path together.
Then pick three. Three fixes you finish this quarter are worth more than a plan for ten.
Does the audit read differently for urban and suburban employers?
The questions are the same. The weights differ. An urban employer with a close crew on public transit will find questions 1 and 3 do most of the work. A suburban employer with staff in four cities and a hybrid group will find questions 4, 5 and 6 do.
That difference is the point of the series. The setting does not change what the law requires. It changes which of your answers are weak. Part 1 and Part 6 go through those patterns in detail.
What does a worked reading look like?
Here is a hypothetical, built only to show how to read the scores. It is not a client and not a result.
Hypothetical employer, 40 people, two sites. Answers: question 1 partly, 2 yes, 3 no, 4 no, 5 partly, 6 no, 7 yes, 8 no, 9 partly, 10 yes. Reading: the three languages and records answers (3, 4 and 8) share a cause, which is that no one owns the roster or the record folder. First three fixes: name an owner, add the language question to onboarding and open a record folder with the ten fields.
Notice that the owner fix comes first. Several of the nos clear once one person has the job.
Who should see your results?
Share them with the people who can change the answers: whoever owns payroll, whoever schedules shifts and the supervisors who run the sessions. A page of nos that stays in one inbox changes nothing.
Keep the evidence with the score. When someone asks later what you did about a no, the dated note beside it is your answer. Store the completed audit in the same folder as your training records.
Keep the tone factual. The audit finds gaps in a system. It does not grade the person who ran the system last year.
How often should you repeat the audit?
Once a year at minimum, and again whenever a condition changes: a new site, a move, a shift pattern, a new language on the roster or a jump in headcount. Any of those can turn a yes into a partly without anyone noticing.
Put the date on the calendar next to your required-topic cycle, so the audit happens before you plan the next round of sessions and not after. A short repeat takes about an hour when the evidence folder is already in place.
Compare each year to the last. The count of nos should fall, and the evidence column should get shorter to find.
Training audit FAQ
How long does the audit take?
Plan on an afternoon for a team of 10 to 150 people. Most of the time goes into finding the evidence, not answering.
Who should complete it?
The person who runs training, with the payroll or operations lead beside them. Questions 1, 3 and 8 need both views.
Is it a legal compliance check?
No. It is a planning check on how well your training fits your conditions. Where a question touches a rule, use the linked source and ask your own counsel about your situation.
Do this week
Print the ten questions, answer them with evidence and circle the three fixes you will finish this quarter. If you want a second read, book a free consult or use the contact page.
This is part 7 of the Urban and Suburban Employer Series. The other six: Part 1: how training differs between urban and suburban employers, Part 2: the first questions I ask before I design training, Part 3: scheduling required training for transit riders, Part 4: training in the language your employees use, Part 5: training records to keep, Part 6: what suburban employers need from training.
Where these numbers come from
| California Labor Code 6401.9 | Read October 25, 2026. Subdivisions (e)(2)(D) and (e)(2)(F). |
| California Government Code 12950.1 | Hours of harassment prevention training for supervisors and other employees. |
| Training records California employers should keep (this site) | Retention periods and record fields, sourced there. |
All sources accessed October 25, 2026.
McKinley Malbrough provides education and is not an attorney. Contacting him creates no attorney-client relationship. If you have a legal question or need legal advice, contact an employment attorney.
Keep going
California training requirements tool
Check which required topics apply.
Training needs analysis for a small team
A short version for 10 to 150 people.
California harassment prevention training requirements
Hours, cycles and who is covered.
The Legal Side of Training
Two sessions on consent, mandates and exposure.


