Verbatim Compliance

Published by Robert Brounstein on

June 29, 2020

Working at Department of Energy and Department of Defense projects as well as wastewater treatment facilities, our commitment to employee safety requires that persons in the field follow our various work procedures verbatim. This word, verbatim, comes from the Latin, and means, “exactly as written.” So, when we are told to follow specific work practices verbatim, it means that we need to do the assigned work activity exactly as it is written. No deviation and no off-the-cuff interpretation of any written instruction as well as refraining from improvisation. Even when confronted with an unusual circumstance, and one may think it would be OK to bend the rules – just a little bit – so we can complete our task; this falls outside of our commitment to verbatim compliance.    

There are so many stories written in the annals of Safety and Health that describe an unfortunate event when someone made the decision to circumvent a process step.  Not because anyone wants to disobey a formal process or procedure just because they want to be defiant; but rather because they believe the extra step is not warranted. Maybe it was the end of a shift or the crew’s work schedule was overloaded and by skipping what is perceived to be a menial and seemingly unimportant step, a specific task could be completed without any trouble, and thereby, allowing a crew to move on to the next task or to call it a day and get home.

Some of the most egregious examples of skipping a job step have occurred during electrical work when someone ignores a lockout/tagout procedure or enters a confined space without checking the atmosphere or entering an excavation without the approval of the competent person – only for a moment – or ignores the required working distance from an overhead power line. For whatever reason; to expediate a work task or because a step just seems to be too tedious or unnecessary, all it takes is just one time.  As it has been expounded all too often, skipping a step doesn’t automatically mean that one will suffer a debilitating injury; only that it places an increased risk for having one.

Verbatim compliance is a proven method to ensure worker safety and health.  And, should a particular work step appear to not be justified or even to cause an unwarranted burden towards task completion, we all have the right: actually, the obligation, to question it’s validity.  In the name of continuous improvement – that is, the understanding that nothing stays stagnant and as scenarios change, so does our specific risks – we need to forever re-examine our processes. It just may mean that as we take a second look at a procedure step – even though we may have been performing this action for years – that we have found a better and even safer way to complete a task. 

OK, so once we find an improved way to perform our work, do we just get in a huddle and agree on a process change? Well, not quite. Changing a work step is a formalized process. This means working with our PM, who, in turn, needs to work with our customer so that all sides can agree that a revision to a work step needs to be modified and that the proposed modification is acceptable. Once this happens, revisions to work plans, integrated work documents and activity hazard analyses need to be incorporated. And finally, all persons involved (aka affected employees) need to receive new training. 

And in these days of COVID-19, verbatim compliance cannot be compromised.  Face masks, social distancing and disinfecting surfaces as well as frequent hand washing are all mandatory. Omitting one of these steps, would be enough to place yourself as well as fellow workers at risk (not to mention transmitting the virus to family members). It may seem like we are going a little overboard with precautions, but if it’s one thing that has emerged over the past few months, verbatim compliance is everything, It was just a few weeks ago when it looked like the entire country was ready to enter a downward trend in new cases and COVID-19 related deaths. And then areas around the nation got a little lax with regards to social distancing and face mask use; and now it looks like we are in a resurgence of the disease.

I can only hope that this Safety Message will serve as a reminder (in a rather long-winded and round-about way) that we all need to exercise prudent judgement and to never take anything for granted.  Through verbatim compliance of the specific practices detailed in our newly created safety documents, we can do our part to control the spread of this disease with the ultimate goal to rid ourselves of this pandemic and finally return to what life was like just a little while ago when this illness was not even a topic in the news.   So, if you are not feeling well; stay at home. We all appreciate the dedication to which one might feel to put forth an effort regardless of you not feeling 100%. But for now, it would be appreciated to take the precaution and take care of yourself at home!

“Remember you are just an extra in everyone else’s play.”

Franklin D. Roosevelt
Categories: Compliance