I get all that, but I really do not think that requiring an observer once a year to document that an associate: does QC related to releasing a FFP, does maintenance related to releasing a FFP, does a "blind" related to releasing FFP, performs a "test" related to releasing FFP, releases results related to releasing a FFP, and a written test related to releasing FFP: will not guarentee that an associate who does not work in Blood Bank often will be competent when they try to actually release a unit of FFP months down the line. If someone is not proficient in an area, I agree that observation and/or testing is needed to ensure they are competent when they need to be. This is something that management needs to be aware of, but no amount of documentation, by itself, is going to guarentee anything. I think this may be another case where a massive amount of documantation may give a false sense of security. We shouldn't be so superficial with competencies. These blanket requirements for comeptencies are draconian. Managers will be spending a hige amount of time documenting that the regs are followed, when they should be more concerned with how associates are doing in each area on a regular basis. At least, that's what I think. We will, of course, comply with the regs as written.