It lands as a single line in a principal contractor's onboarding email: "Please confirm all operatives on the attached list are competent for the works." Someone opens the training matrix, sees a row of green cells against every name, and replies "confirmed". Nobody in that exchange has asked, or answered, whether those people can actually do this work on this job. The matrix said yes, so the business did too.
That is the problem with the training matrix. It is not that it is wrong. It is that it quietly takes the place of a decision that nobody ever made.
What's Actually Being Asked
Under CDM 2015 and Part 2A of the Building Regulations, competence does not mean "has been trained". The Construction (Design and Management) Regulations 2015 require appointed designers and contractors to have the skills, knowledge and experience (and, for organisations, the organisational capability) for the role, and workers to have the skills, knowledge, training and experience for their work, or to be gaining them under supervision. Part 2A of the Building Regulations 2010, in force in England since 1 October 2023, sets its own competence test of skills, knowledge, experience and behaviours for designers and contractors, and requires organisations to have the organisational capability, including policies, procedures and systems, to work in compliance with the relevant requirements. Under Part 2A, anyone appointing a designer or contractor must take all reasonable steps to satisfy themselves that the appointee meets the competence requirements; CDM sets a similar reasonable-steps duty.
Training appears in all of this as one input. Knowledge can come from a course; skills are shown by doing the work; experience is built up over time on real jobs; behaviours are observed. A training matrix tracks the first of those well and the other three barely at all. So when a client or principal contractor asks you to confirm competence, the honest question behind the request is: who decided this person can do this operation, when, and on what evidence?
The Evidence That Answers It
The records that answer that question are not certificates. Certificates are part of the evidence, but the answer is a decision and the trail behind it:
- A competence decision per person, per operation: "competent to install system X unsupervised", not "holds course Y". The operation is the unit, because that is what the client is relying on.
- The assessor and the date: a named person, with their own recorded competence to assess that operation, and the date they made the call.
- The evidence relied on: the training certificate, yes, but also the supervised installs, the observed assessment, the manufacturer's system training and any quality record that bears on it.
- Supervision records for people still in training: who supervised them, on which operations, and when they were judged ready to work without supervision.
- Withdrawals and restrictions: the decision to stand someone down from an operation after a quality failure or a long gap, with the reason. A competence record that can only ever say "yes" is not a competence record.
- The link to the work: which operations the person was allocated to, where on the building, and whether their decision was in force on that date.
If you need a structure for the decisions themselves, the competency matrix post sets out the framework and register in detail. This post is about the thing that usually stands in their place.
Why the Spreadsheet Version Fails
The training matrix is built to answer one question well: is this certificate in date? Names down the side, courses across the top, expiry dates in the cells, red when something lapses. Over time it becomes the competence system by default, because it is the only record anyone keeps. Then the gaps show. It rarely says which operations a course covers, so "in date" gets read as "competent" for work the course never touched. It has no column for the assessor, so the judgement a supervisor made on site is never written down. Experience and behaviours have nowhere to go. Renewals are usually typed over old dates, so the record of who was in scope last spring is gone. And the certificates behind the green cells sit in a shared folder, an email chain and a WhatsApp group, in whichever version someone last saved. Green cells feel like assurance. They are a record of attendance.
Keeping It Provable
The fix is not to throw the training matrix away. It is to demote it. Training records become evidence that feeds a competence decision, rather than the decision itself. The decision is its own record: made by a named assessor, dated, tied to an operation, and never overwritten. When a certificate lapses, the decision it supported is flagged for review, not silently left green. When someone is restricted, that is a new entry, not a deleted one.
Then build the record as the work happens. When operatives are allocated to an operation at a location on the building, check the decision for that operation at that point, not at the tender stage. Let the inspection sign-offs and photographs for that location carry the names of the people who did the work, alongside the decisions that were in force on the day. A record kept that way, anchored to the building rather than to a spreadsheet, can still answer "who decided, when, and on what evidence?" long after the job has finished.
The Monday Checklist
- Open your training matrix and pick the five operations on your current work where a competence failure would matter most. Ask, for each green name: who decided this person can do it?
- Where the answer is "the course", write down what the course does not cover for that operation: the skills, experience and behaviours still unevidenced.
- Name the people in your business who are allowed to make competence decisions, and record their own competence for the operations they assess.
- Start a decision record alongside the matrix: person, operation, level, assessor, date, evidence relied on. Begin with the five operations, not the whole business.
- Change how lapses work: an expired certificate should put the decision it supports up for review, not just turn a cell red.
- Record supervision for anyone still in training on those operations, and the date each was signed off to work alone.
- Next time you are asked to confirm competence, answer from the decision record, and attach the evidence rather than the matrix.
Where BrieXO Fits
In BrieXO, competence records sit in the FIELD bundle, which is live today. Its competence app, XO Comp, holds role frameworks and person scopes, with evidence reviews, training plans, CPD and verification links, and the bundle tracks labour approvals, eligibility signals, competency evidence and assessor decisions alongside site operations. Training plans and CPD sit alongside evidence reviews and assessor decisions, rather than standing in for them. It does not make the competence judgement for you: that stays with your assessors. It supports your competence duties; it doesn't discharge them. The detail is on the XO Comp page.
Related reading: construction competency matrix: building one that holds up, competence on the day: proving who was competent, and SKEB in practice: skills, knowledge, experience, behaviours.