I'm sensitive to the concern. There are risks. Certainly the last thing I would want to see is a ground of appeal generated as a result of some requirement that someone has indicated wasn't complied with. I'd be sensitive to the degree to which record-keeping is done. I think the idea is one of more than moral persuasion. If you recommend training, the resource reality means the training won't happen to the degree you want it to. Even if you strongly recommend training, we don't get trained unless we're forced to, and even then we're all scrambling to try to meet our mandatory requirements. But we meet them. Making it mandatory is a way to have it happen. As to how to check up on it, I think there are some risks.
On April 11th, 2017. See this statement in context.