This case involves the construction of a water treatment plant in Louisiana. The area where construction was taking place was surrounded by swampland, so transportation of men and materials to and from the construction site was a major issue. Thus, specialized vehicles were used for transportation, and wooden roadways were used to stabilize driving areas. One of the workers was operating a backhoe at the site, and was driving over a wooden roadway that had been laid down by the primary contractor. While driving over the roadway his vehicle overturned, causing him to sustain serious injuries. The roadways would occasionally shift due to changes in the water level, and it was alleged that the movement of the roadways was the direct cause of the accident.
Question(s) For Expert Witness
- 1. How often do you use wooden roadways at flooded construction sites?
- 2. What are the proper steps for maintaining these mats and making sure that they are steadily in place and safe for driving on?
Expert Witness Response E-100988
I have worked as a construction manager and engineer for the last 23 years, and have an additional 17 years of construction claims experience. I am familiar with the use of access road/work-space mud mats. I have used these mats for every project that I’ve worked on and have worked in flooded conditions as described in this case. Abuse, use, routine maintenance, weather, and poor installation are primary factors affecting the durability and continued safe use of any mat. All surfaces should be routinely inspected to verify compliance with manufacturer recommendations regarding application, installation, and maintenance thereof. From the description provided, I suspect that soil under the mat washed out, created a hole under the mat that caused the vehicle to flip over. I have reviewed several cases involving mats and personal injuries, and am capable of studying the application of these mats, manufacturer requirements, contractual requirements, and actual evidence in the field.
Expert Witness Response E-103064
I have over 13 years in heavy utility construction and am currently a utility division manager. In addition, I am OSHA 510 certified as well as MSHA (mining safety) certified. I use swamp matting from time to time, and believe that the weather and environmental conditions are important factors to consider. For example, I would put down plastic sheeting to stabilize flooded ground and would not utilize vehicles when water levels were not safe.