This case involves a warehouse employee who suffered permanent and debilitating injuries due to an allegedly defective loading dock design. On the date of the incident in question, the worker had been tasked with unloading a trailer full of avocados that had recently arrived at the warehouse facility. When the worker and his crew had finished unloading the truck, he stepped outside and positioned himself between the truck and the loading dock in order to retrieve a dropped tool. Suddenly, the truck rolled backwards while the driver attempted to pull away, pinning the man between the trailer and the loading dock. As a result of the accident, the man incurred significant medical expenses and is unable to work.
Question(s) For Expert Witness
- 1. Please describe your background in designing loading docks.
- 2. What protocols or parameters are typically in place to safeguard against structural safety issues in safety docks?
Expert Witness Response E-120204
I have extensive technical and practical experience in conducting safety investigations and conducting accident reconstruction analysis. I have personally conducted investigations and analyzed more than 2,500 accident cases in the past 12 years, several of those have been at loading docks. Additionally, as a safety engineer, I am familiar with roadway design, including the design and practical application of loading docks. Although it is permissible for loading docks to have an adjacent driveway slope (if the loading dock has a low grade), it should be a slope of 3-5%, and not exceed 6%. The regulations that govern Loading Docks (loading and unloading) are covered in OSHA (29 CFR 1910). I have analyzed several cases involving tractor trailers, loading docks and vehicle vs. pedestrian collisions.
Expert Witness Response E-010652
What is described sounds like a typical depressed dock where the driveway is sloped toward the building so that the trailer bed is relatively even with the dock floor. This occurs with or without levelers. The slope of the drive should not exceed 10% and the trucker must always chock their wheels. Using a forklift in and out of the truck can cause it to creep as well, though it is unclear if that was the case here. When a truck is in position at the dock, no one should be at the bottom of the ramp behind the truck. That’s an OSHA/procedural issue. I would also check to see if there was a leveler malfunction, wrong type of leveler or poor maintenance. I have inspected numerous warehouses for acquisition for clients.