Every year around September 11, I think about the most tedious HR compliance work I have ever done.
In 2001, I was an HR Manager for a private company that provided auxiliary employees to airlines at Boston Logan Airport. Our employees included skycaps, baggage handlers, ticket checkers and airport pre-board security screeners.
Before any of those employees could receive an airport badge, they had to pass a rigorous background screening process. Criminal background checks were part of it, but my HR department was also responsible for manually verifying every applicant’s previous 10 years of employment history.
And I do mean manually.
We called former employers and verified that applicants had worked exactly where and when they said they had. If there was a gap between jobs, we had to account for that too, sometimes by contacting a doctor, clergy member or another professional who could verify that they knew the applicant and had seen them regularly during that period.
It was miserable work.
The process was repetitive and incredibly slow. Employers didn’t call us back. Applicants wanted to know why they couldn’t start working yet. And operations needed people—lots of them, fast.
Anyone who has worked in HR knows how this goes: when operations is short-staffed and failing, the conversation immediately becomes, “Why isn’t HR hiring people faster?”
So there was constant pressure to move candidates through the process. And when you’re waiting days for some former supervisor to return your fourth phone call just so you can verify that an applicant really worked at a convenience store six years ago, it would have been very easy to decide that close enough was good enough.
We didn’t.
About a year before September 11, on my very first day with the company, my boss from the corporate office gave me an instruction I have remembered for more than 25 years.
If he ever caught me taking shortcuts with applicant screening, he told me, “You will be gone so fast your head will spin.”
I was a rule follower. I was also, as it happens, strongly in favor of continued employment.
So my HR team did the HR Compliance work. Every phone call. Every verification. Every unexplained gap. However frustrating the process became, we followed it.
At the time, I thought we were complying with an airport security requirement at the expense of hearing the constant wrath of our Operations Managers.
I had no idea what those records would eventually mean to me.
On the morning of September 11, our employees were staffing the American Airlines security screening operation at Boston’s Logan Airport.
The passengers and hijackers aboard American Airlines Flight 11—the first plane to strike the World Trade Center—passed through security staffed by employees my company had hired.
Employees whose background files had come through and been investigated by my HR department.
Within hours, my office was filled with law enforcement: local police, state authorities, airport officials and the FBI. They went through our personnel records looking for information about the employees who had been working that morning and for anything that might help them understand what had happened.
And suddenly, all of that miserable, monotonous HR paperwork wasn’t paperwork anymore.
It was evidence.
I’ve spent the rest of my career thinking about that day.
Not because I believe ordinary HR compliance is a matter of life and death. Almost always, it isn’t. And certainly not because I believe perfect paperwork can prevent every terrible thing from happening. It can’t.
But I learned something very early in my career that has never left me:
You rarely know which ordinary HR decision will become important later.
When we were making those verification calls, we didn’t know anyone would ever examine our work. We weren’t expecting the FBI. We were trying to get people hired while following a process that was slow, frustrating and inconvenient.
That’s what most HR compliance looks like before something happens.
The I-9 that seems like paperwork. The manager’s documentation of an employee problem. The wage calculation somebody wants to “just fix next payroll.” The background screening step delaying a desperately needed hire. The investigation notes you’re tempted not to write down.
Most days, nobody is looking.
And then one day, somebody is.
For most employers, that scrutiny will thankfully never look anything like what happened in my HR office on September 11.
It may be an employee complaint. A workplace accident. A wage claim. A discrimination charge. A lawsuit. An audit. Or simply an attorney asking you six months later to explain why a particular employment decision was made.
That’s when the boring work becomes very interesting.
You want to be able to open the file and see what happened. You want to know your HR compliance held up. You want your records to support what you remember rather than contradict it.
Most of all, you don’t want to sit there wondering whether somebody took a shortcut because doing it correctly seemed inconvenient at the time.
I have thought many times about what it would feel like today if we had taken shortcuts—if we’d skipped a verification, found a loophole or decided that getting somebody hired quickly mattered more than getting it right.
I genuinely don’t know how I would live with that.
Following the HR compliance process didn’t prevent September 11. Nothing my HR department could have done would have changed what happened aboard Flight 11. But when law enforcement walked into my office and began opening our files, I didn’t have to wonder whether we had done what we were supposed to do.
We had.
Nothing about that made September 11 less horrific. It didn’t change what happened to the passengers and crew of Flight 11, the people in the World Trade Center or the thousands of families whose lives changed that morning.
But it allowed me to live with my own very small part of an enormous and terrible day.
And it taught me a lesson I have carried through every HR job I’ve held since:
Do the boring work when nobody is looking.
Someday, someone may be.