HR Access Issue after upgrade from IFS9 to IFS10

I have found that the HR Access - HR Application Manager must be check for a select few users in our doc control dept. to be able to add training documents to the person documents tab (tbwPersonalDocumentTab). Without the HR Application Manager access checked, the users can only see their own data. This seems to be new behavior for IFS10 as compared to IFS9. Note that we do not use the HR Module for Organization maintenance.  How can we allow the users to add our training documents to the person document tab without applying HR Application Manager access? Is there a way to assign these documents to a person w/o using the person document tab? What are the risks associated with HR Application Manager access?