This case involves injuries that were sustained by a construction worker who was part of a crew responsible for clearing the foundation of a skyscraper that was under construction from intruding groundwater. As a part of this function, the man was charged with assisting a team of riggers who were bringing in heavy duty pumping equipment into the base of the foundation via a pulley system. The bottom of the foundation was more than 70 feet below sea level, and at the time of the incident in question was covered with a thick layer of grime and water, which made it hard to walk. On this occasion, the man was part of a crew tasked with receiving one of the larger pieces of pumping equipment. The area was dark, and the crew had to provide illumination with headlamps and other small light sources. Eventually, the piece of equipment slipped, falling on the man’s feet and causing massive damage. It was alleged that there were multiple lapses in common safety protocols.
Question(s) For Expert Witness
- 1. Please discuss on your safety supervisory experience.
- 2. What is the extent of your rigging experience as it pertains to the types of lifting mechanisms employed during "dewatering"?
- 3. What are some of the safety protocols in "dewatering" as described in the summary?
Expert Witness Response E-007339
I have been supervising construction for over 15 years, with a majority of that time directly related to safety. I have obtained several credentials in the field from several training institutes, which allow me to have a specific understanding of not only the OSHA 1926, and 1910 regulations, but a great understanding of Best Management Practices (BMPs). I have worked along with the Occupation Health & Safety Advisory Services OHSAS 18001 standards for occupational health that is becoming more adapted throughout the nation and international communities. As for my rigging experience, I have authored several critical lift plans which exceed the minimum OSHA 1926 standards for demanding EH&S clients such as the USACE, I have been the lift supervisor on several technical and critical lifts. I am a certified Rigger, and I instruct rigging classes that are used in the petro-chemical industry for turnaround work for refineries. I have conducted, and supervised lifts from a 1.5 ton chain fall to a 500 ton, double luffing jib, with 380 feet of lattice boom.
This expert has over 15 years of experience as a construction and safety manager, managing all phases of building construction, demolition, and environmental remediation. He is Certified as a Construction Health and Safety Technician, a Construction Quality Control Manager, and a Construction Reviewer, while he has completed numerous OSHA safety courses. This expert has extensive experience with the New York Department of Transportation, the New York Department of Environment Protection, as well as the New York Department of Buildings. As a Site Safety Health Officer for the Dover Air Force Base, 50,000 man hours were logged with zero loss time incidents under his supervision. As a Safety Manager for MWHC Global, he developed, planned, and managed specific environmental health and safety programs including Fall Prevention Protection, Critical Lift (crane), Excavation and Trenching, and Scaffolding and Raised Platform, all in compliance with OSHA 1910, 1926, and EM 385 1-1. Currently, this expert is the Owner and Principal of an environmental and construction health and safety consulting firm, where he is regularly contracted as a Safety Manager/Coordinator for various construction projects.