This case involves a construction worker in Connecticut who suffered serious injuries after he was partially run over by a construction vehicle while on the job. On the date of the incident in question, the man was working as a surveyor on a construction site for a large office park development. The construction site was experiencing a particularly high level of vehicle traffic due to the fact that a large amount of concrete was being poured that day. The plaintiff was working with his back to the main access road when he was suddenly struck by a concrete truck, which ran over the lower half of both of his legs. As a result of his injuries the man required a number of surgeries, as well as physical therapy, and was unable to return to his previous occupation. It was alleged that the managers of the construction site failed to safely plant the flow of vehicle traffic through the construction site.
Question(s) For Expert Witness
- 1. Please describe your experience supervising construction sites that involve trucking or vehicle movement.
- 2. What standards or protocols should drivers follow when operating a truck to avoid such injuries?
Expert Witness Response E-008566
I have been involved as a construction safety professional for over 30 years. During that time I have visited and worked on thousands of sites representing insurance carriers, general and trade contractors, owners, and others. It would be the rare site that did not have regular and routine truck traffic providing for the delivery of materials and supplies, including concrete delivery trucks. The management of the flow of traffic is a critical part of ensuring the maintenance of a safe work site. Regulatory standards, such as those promulgated and enforced by OSHA, as well as consensus standards and custom and practice in the industry all dictate that proper procedures and controls be in place to ensure the safe movement of traffic in and around construction sites. Critical attention must be paid to minimizing vehicles operating in reverse and ensuring that appropriate controls are in place when this is necessary. I have addressed traffic issues on numerous sites during my long career in construction safety.