In Facchine v. Workers' Compensation Appeal Board (Pure Carbon Co. and PMA Group), 883 A.2d 720 (Pa. Cmwlth. 2005) the Court held that an oral agreement to settle a workers' compensation claim was unenforceable because at the time the injured employee died the statutory conditions for approval had not been satisfied. There, Sylvio Facchine (Facchine) contracted chronic obstructive pulmonary disease while working for the Pure Carbon Company (Pure Carbon). About 10 years later, Facchine and Pure Carbon entered into an oral agreement to settle. Pure Carbon's attorney confirmed the agreement in two letters and petitioned for approval of the proposed compromise and release agreement. Before the hearing, Facchine died. At the time of his death, Facchine neither executed a C&R Agreement form (LIBC-755) nor testified at an approval hearing. The petition of Barbara Spinda (Executrix) was denied. On appeal, Executrix argued that Facchine had "substantially complied" with the requirements of Section 449 of the Act, 77 P.S. 1000.5, because Facchine understood the factual and legal significance of the Agreement, and the parties confirmed the agreement in writing. The Court agreed with the workers' compensation judge and Board that the statutory requirements had not been satisfied despite the existence of an oral agreement. "The Act specifically mandates 'every' such agreement be in writing signed by the parties. The plain terms of the Act admit of no exceptions, not even for an understanding claimant." Facchine, 883 A.2d at 723.