A Case Study on Verbatim Compliance
8/10/2020
One project that my company was recently engaged, involved a considerable amount of investigation to understand the extent of hazardous materials contamination. Getting access to this location requires specific training and clearance approvals. Without these qualifications; no matter how qualified one may be (i.e. education, professional certifications and experience), getting access to such an area would not be granted.
And so, it happened one day last week, our team needed access to an area for the purpose examining a location to determine specific sampling points. No work activities other than walking over the area was going to be conducted. Yet we came across a sign that seemed to be unusually posted, nevertheless requiring personnel that wish to enter the field to call the access control station upon entering and existing the area. Our crew agreed that the sign seemed to be oddly placed while it appeared to be old and worn and therefore, probably was no longer valid as all work activities associated in the area were no longer being conducted while the facility in the immediate area has long since been abandoned; yet the sign indicated the field was a radiological controlled area and contacting the access station was a requirement.
After a brief discussion we all agreed that even though the sign was old and probably obsolete, it was not our decision to make assumptions as to the signs’ validity. Therefore, verbatim compliance necessitated us to call the access station. As we suspected, the contact person at the access station sounded a bit confused with our request to enter the area (probably because such a request was never made in recent history) but nevertheless, granted access to our crew.
Verbatim compliance is a human performance measure to ensure procedures are followed 100% and that complying to the requirements is not an option. In this particular case, it seemed that the sign was once a required posting to ensure the health and safety of those assigned to the area; however, it now seemed apparent that the sign was now no longer valid, and as such, should be removed. And if this sign needed to be removed, this was clearly the responsibility of the area manager. Until this is performed, or a formal notice is issued, explaining that entry/exit into and out of the site no longer requires permission from the access station, it is our responsibility (as well as any other person or field team wanting to enter) to continue to perform the required actions as posted on the sign. Ignoring such postings for whatever reason, no matter how reasonable an assumption may be, would be considered a willful violation of existing direction and could result in serious consequences.
As it has been brought up before, verbatim compliance means to do exactly as written (taken from the Latin, “verbatim ac literatim,” meaning “Word for Word and Letter for Letter”) and no assumptions shall be made. If an instruction, operating procedure or other document appears to have an error or incorrect instruction, then it is our responsibility to have a safety pause and discuss the concerns. If indeed, the instruction appears to be incorrect or by following the instruction can result in a workplace accident or other undesired effect, contacting the PM is required. At this point, it is the PM’s responsibility to make the appropriate changes (with the assistance of the proper subject matter experts) and revise the document. This would be followed by training personnel to the new/revised process with proper documentation. After these steps have been implemented, work may then proceed.
“Let everything happen to you…Beauty and terror…Just keep going…No feeling is final.”
Rainer Maria Rilke (ending line in JoJo Rabbit)