This case involves a construction worker who was severely and permanently injured after falling from scaffolding. On the date of the incident in question, the man was working as a stonemason on the restoration of an historic building in Maryland. The man was on scaffolding more than 30 feet from the ground assisting with the replacement of stone embellishment on the building’s exterior. Suddenly, a loose tarp was caught by a particularly strong wind and came loose, striking the man and causing him to fall from the scaffolding. The worker survived after an extended hospital stay, but was left profoundly and permanently injured. It was alleged that the general contractor in charge of the project failed to maintain a safe working environment.
Question(s) For Expert Witness
- 1. Please explain your experience with construction management?
- 2. Are you familiar with the proper scaffolding arrangement and tarp installment?
Expert Witness Response E-008566
Over the course of the past 30 years, I have visited thousands of active construction sites and worked with numerous contractors and project management teams to address the controls necessary to ensure the maintenance of a safe work site. This routinely involves coordination of efforts among the individual employees and contractors, general contractor, construction management team, and the owner. The standard of care in each instance is dependent upon compliance with governmental standards such as those promulgated by OSHA and the U.S. Army Corps of Engineers, applicable ANSI and ISO standards, custom and practice in the industry, and contractual requirements. I have been directly involved in the supervision of the erection, inspection, and maintenance of a wide variety of scaffolding types in a multitude of applications. This includes the use of tarping and other materials. Many of the cases in which I have served as an expert witness are directly related to the responsibilities of the various parties involved, including the general contractor, construction manager, and/or property owner. In each instance, the responsibilities of each party are a significant consideration, addressing contractual requirements and site-specific expectations.