Litigation Experience

John has served as an expert witness for the plaintiff and defense in safety related injury cases. John has trial, arbitration, and deposition experience. His defense/plaintiff ratio is presently 49/51. He has testified at trial twice for the plaintiff getting awards of 1.8M and 1.3M and once for the defense resulting in no award.

Accident Investigation Experience

Investigated hundreds of industrial/construction accident sites involving industrial vehicles, equipment malfunctions, equipment modifications, operator error, equipment design, and more.

Experience:
30+ years with Ford, General Motors, Chrysler, and more.
Deposition Experience (Plaintiff or Defendant)

Work Experience

Since my retirement from Chrysler I have has been actively involved in pursuing a career assisting firms with plaintiff and defense litigation cases. I am also an active safety consultant.

Chrysler: March 1996 to January 1, 2008

I have been the Safety Supervisor in three different Daimler Chrysler plants and was a corporate safety advisor. The plants have ranged in size from 1.1 to 2.5 million square feet. All three have had over 2,000 employees. Of the three, one was an assembly plant, one stamping, and one machining. I typically supervise several employees working in both safety and medical.

In this capacity I am responsible for the safety and ergonomic design of all new equipment. As new models are developed it is not uncommon to install several hundred million dollars in new equipment, in any given year. In addition to ensuring new equipment meets all applicable regulations, I was responsible for the safety upgrades and safe operations of approximately 1,000 pieces of preexisting equipment. The corporation has several safety programs that must be followed. In addition to these programs, I have fostered several projects to heighten safety awareness and reduce hazards in the workplace.

Fostered accident reduction by designing a plant safety program called “ZAPP”. “ZAPP” stands for “Zero Accident Plant Plan”. In short the plan calls for the identification of an area “Safety Champion” and an area safety team. The team has representatives from production (hourly and salary) maintenance, and engineering, as well as the champion. The main focus of the team is to increase employee awareness and moral. To increase moral the team focused on employee concerns.

Designed a ventilation system that would be capable of reducing particulate air mist from levels between 1.5 and 3.5 mg/mm3 to 1mg/mm3 or less. The concept consisted of five separate systems on five existing machining lines covering approximately 15,000 square feet of floor space.

Conduct weekly safety tours with upper management and union leadership. The tours focus on two major areas: 1) Building and equipment hazards. 2) Behavioral habits of employees. Approximately 90% of our injuries are the result of poor behavior. During these meeting we focus on year to date rates ( incident, severity, and lost work day), previous week’s incident experience, and new developments.

Conduct monthly meetings with all floor supervisors (production, material handling, quality, and maintenance). During these meetings we focus on year to date rates (incident, severity, and lost work day), previous month’s incident experience, and new developments.

Developed and maintain graphs depicting injuries in all departments. Each department is tracked, and graphed, according to month of injury, employment classification of injured employee, type of injury, and body part involved. This information is shared with all plant supervisors, plant management, and union leadership on a monthly basis, or sooner if requested. Floor supervisors are given colored graphs depicting their respective department’s experience. This information is compared to earlier performance, area performance, and plant performance.

Initiated a “Safety Cross” program in all departments. Supervisors are given monthly diagrams, in the shape of a cross. This cross is divided into 31 equal sections with each section divided into three. Each section is numbered, to represent the day of the month, and each day is divided into three sections, each section represents a different shift (first, second, and third). A shift without an accident is colored green, a shift with a near miss is colored yellow, and a shift with a recordable injury is colored red. Of course, the goal is to have the entire cross colored green.

Developed a near miss program. Employees involved fill out a near miss form that asks them four questions. 1) What was their job assignment? 2) What were they doing? 3) If they were injured, what kind of injury was it? 4) What corrective measures could be taken to prevent this from happening again? Areas of the plant are then compared via rate, using the same formula for incident rate, to determine where the highest potential for injury is. This data is shared with the safety and ergonomic committee and applicable management personnel. High risk jobs are identified and corrective action initiated. All work station changes are reviewed with operators, on all shifts, prior to implementation. Operator recommended modifications are included.

Host corporate safety meetings with safety engineers from local Daimler Chrysler plants to compare process. During these meetings we share what works for us and help each other tailor programs to meet their specific needs.

Identified a high risk area for industrial vehicle accidents. To address this I developed a signal guided vehicle (SGV) project designed to reduce industrial vehicle traffic. The project consisted of 15 SGV’s and two automatic storage and retrieval systems (ASRS). The SGV’s are self-operated and stop when anything approaches them. An SGV picks up a rack of parts and takes it to one of ASRS’s where it is stored according to part number. When the assembly line calls for a specific part number the ASRS removes the part and deposits it on an empty SGV. The SGV delivers the part to the appropriate work station and removes the empty container. Use of the SGV’s would eliminate 80% of the fork truck traffic in the targeted area.

Improved the confined space program to include independent teams on all three shifts. Teams compete between themselves, conduct regular practice rescues, and maintain the rescue equipment. Plans include the establishment of corporate confined space rescue competition.

Developed a return to work program for employees with work restrictions resulting from work related injuries. In the first year the program saved over one million dollars in worker compensation costs. Not only did the program save the worker compensation costs but it also improved the moral of the injured employees by letting them know that if they were hurt they would not suffer financially. This encouraged the early reporting of injuries, reducing injury severity in many cases.

Developed a job rotation program. This is significant because union represented plant employees have protected seniority rights stating employees have the right to bid for jobs. High seniority employees do not have to work jobs lesser seniority employees can perform. This program started with small scattered groups and is growing to include more and more employees. New jobs, requiring several employees to operate, are starting out using the job rotation concept.

Coordinated efforts between engineering and finance to remove all product containers from the floor. There are many work stations designed with ergonomic hazards resulting from poor part presentation. The ergonomic committee has purchased, and installed, hundreds of lift/tilt tables. Our goal was, and continues to be, to eliminate the reaching and bending required to remove/place parts from/into a container.

Developed a new hire orientation program. This program addresses all aspects of plant safety and touches on and off-the-job safety. Our program addresses off-the-job safety because we realize safety has to become second nature and practiced all the time.

Implemented an energy control lock-out placard program. The placards identify all energy sources that must be neutralized for safe maintenance of all pieces of equipment. Program included engineering work to identify lock-out points, graphics, quality checks, and training.

Monitor the construction standards for all construction workers, both Daimler Chrysler employees and contract employees. I meet with outside contractors to make sure they are aware of company specific standards and follow applicable OSHA standards.

Perform air quality and noise level mapping for the plant. Results are transferred onto plant layouts and posted throughout the plant. Employees are introduced to the layouts through use of the plant newspaper and captive television station. Make recommendations on how to improve existing ventilation systems. Work with vendors on the design and installation of same.

Write weekly/monthly safety talks that are specific to the plant. Topics are determined by present concerns (accidents, near misses, weather conditions, etc.) The safety talks are distributed to all management and supervisor level employees for presentation to subordinates. Managers are required to keep signature records.

Designed an excavation and tornado shelter area program. This required the identification of assembly/shelter areas, both inside and outside the facility. After identification of the areas was completed, a plan was developed and communicated to all employees. There have been several practice soundings of the three evacuation / shelter signals with a practice plant evacuation planned.

Improved the prescription safety glasses program. This resulted in better frames and a reduction of delivery time from six to two weeks.

Coordinated efforts between plant medical and training to improve the respirator and industrial vehicle licensing programs. The new process has greatly improved record keeping capabilities. The improved record keeping process allows us to track due dates for refresher training and reoccurring medical examinations.

Developed a corporate training program designed to prepare eligible safety engineers to become certified through the Board of Certified Safety Professionals, by taking the ASP and CSP safety examinations. This included all initial contacts with instructors and safety engineers.

Ford: May 1994 to March 1996

The Ford plant I worked at is a 2.5 million square foot facility. The main operations were machining, assembly, and painting. About 3,500 people are employed at that location. In this capacity I supervised the plant safety committee and the plant ergonomic committee. I was responsible for the safety and ergonomic design of all new equipment. Additionally, I was responsible for the safe maintenance of all existing equipment. There are approximately 2,000
stand alone machines and 40 machining lines in the plant.

Performed air quality monitoring for the plant. Made recommendation on how to improve existing ventilation systems. Worked with vendors on the design and installation of same. Results were transferred onto plant layouts and posted though-out the plant. Noise and mist level results were transferred onto plant layouts and posted through-out the plant. Employees were introduced to the layouts through use of the plant newspaper and “5 Minute Safety Talks”.

Performed noise surveys of the plant upon request and implemented sound abatement procedures if the sound level was above 85db. Administered the safety glasses program, both prescription and non-prescription. Directed the industrial vehicle driver’s license program and the respirator issuing process.

Administered the weekly plant safety tour. The tour took several hours to cover the 2.5 million square foot facility. During the tour pictures were taken of recognized safety hazards and notes taken to describe the conditions. If an employee was found to be performing an unsafe act they were immediately confronted. Conversely if an individual was conducting themselves admirably, for example using proper lock-out procedures, they were praised. All findings were discussed at weekly meeting attended by all plant superintendents.

Coordinated a weekly safety meeting centering on accident investigation and follow-up of old business unfinished from previous meetings.

Spearheaded a corporate drive to get safety engineers certified through the Board of Certified Safety Professionals. This included all contacts with preparatory class instructors and organization of study groups. We experienced an 80% pass ratio on the exams.

Monitored compliance with all construction standards, both MIOSHA and Ford. The plant had a 35 person construction crew that performed all aspects of building construction.

Developed a new hire orientation program. This program addressed all aspects of plant safety and touched on off-the-job safety. Our program touched on off-the-job safety because we realized safety had to become second nature and practiced all the time.

Implemented an energy control lock-out placard program. The placards identify all energy sources that must be neutralized for safety maintenance of all pieces of equipment. Program included engineering work to identify lock-out points, graphics designs, quality checks, and training.

Wrote monthly safety talks that were specific to the plant. Topics were determined by present concerns (accidents, near misses, weather conditions, etc.). The safety talks were distributed to all management and supervisor level employees for presentation to their employees. Managers were required to keep signature records.

Developed a return to work program. This is significant because the plant is a union plant with protected seniority rights stating employees have the right to bid for jobs. High seniority employees do not have to work jobs lesser seniority employees can perform. This program started with small scattered groups and grew to include more and more employees. New jobs, requiring several employees to operate, were then staffed using the job rotation concept.

Designed a presentation format for accident tracking. This was updated monthly with incident, severity, and lost work day case rate, by department and shift. Data included type of injury, body part involved, classification of employee, and date of injury. This data was tracked against a 10% reduction goal and presented to plant management and union leadership on a monthly basis.

Aeroquip: August 1990 to May 1994

In this position I was the staff corporate safety engineer responsible for 14 plants in seven states. The primary work was plastic molding. The types of molding used were injection, excursion, and blow molding. In addition, some plants engaged in paint and assembly operations. Communication was a key factor in the success of all the programs, plans, and processes implemented. I used many different forms of communication (monthly accident reports detailing accidents at all plants so they could learn from mistakes made at other locations, monthly safety talk topics, plant vs. corporate accident rate and injury analysis, computerized safety training programs, corporate safety meeting, verbal, and plant visits).

Established training programs to address any hazard that was recognized, or that was requested by any of the plants. A very effective method I used was safety workshops. I hosted semi-annual safety workshops. Representatives from all plants under my responsibility, as well as other corporate locations that I did not work directly with, were invited. The meetings followed different formats, as required to address the subjects. A very popular format was to have each plant discuss: 1) Problems they ere unable to find solutions for. 2) Problems they successfully solved. The presentations were accompanied by video tapes to enhance the audience’s understanding of the situation.

Invited local physicians, to the workshops, to discuss cumulative trauma illnesses, their symptoms, corrective and preventive actions, and return to work hardening programs. MIOSHA Education and Training instructors participated through discussions covering several OSHA standards.

Introduced computerized training programs. The training programs were of the interactive type using a laser disc player and a computer. I knew all of the plants were not able to provide accurate and consistent training, to all employees on all shifts, and decided this training platform would provide the necessary training and documentation needed. To establish the program it was necessary that I research the computer hardware and software market to purchase the necessary components, to make the program successful. Ultimately, the plants had access to a corporate training library, annual training schedule, and were able to request nice to have training topics.

Wrote a 132 page corporate safety manual. This manual was distributed to plants and provided them with safety programs for all required OSHA topics. The manual was presented at the semi-annual safety meeting. Training was provided on all subjects. This allowed the plant representatives to take the training programs to their home plant, with the ability to implement them. All plants were provided with a hard copy of the book. In addition they were provided software programs, with the flexibility to make “plant specific” changes as desired.

Developed a book containing 80 “5 Minute Safety Talks”, under a single cover. This was presented to all of the plants. It formed the basis for the corporate “5 Minute Safety Talk” program. Plants were responsible for safety talk presentation and to keep applicable documentation.

Designed and implemented a safety eye glasses program, behavior management process, and functional ergonomic and safety committees. When I started working for Aeroquip most of the 14 plants, I was responsible for, did not have a safety committee and none had an ergonomic committee. I worked directly with the corporate upper management staff to gain their support, allowing the plants to form efficient working safety and ergonomic committees. I assisted the committees in their early stages and directed them on how to hold productive meetings and explained what was expected of them. In this manner, I established contacts in all of the plants that I could interact with on all matters associated with safety. I did this because I knew I would not be able to establish any long term changes without being in the plant all of the time. I wanted the plants to be safe on their own, and not use me as a crutch.

Wrote an ergonomic training program. The program was a 12 hour class that addressed the most relevant aspects of ergonomics and associated preventative actions. I instructed this program to the ergonomic committees in all my plants. The ergonomic committees were given individual text books and a copy of the presentation. This allowed them a better opportunity to review the data and pass it along to others.

Performed air quality and noise level mapping for the plants. Results were transferred onto plant layouts and posted through out the plant. Employees were introduced to the layouts through use of safety meetings. Made recommendations on how to improve existing ventilation systems. Worked with suppliers on the design and installation of same.

Developed a behavior modification process. This approach was used because a very high percentage of injuries were behavior based. Research showed that to change the way people worked (short cuts, day dreaming, carelessness, etc.) their attitude had to change. This process was designed to do just that. At the time I left it was in operation the three of the plants and doing very well.

Hawthorne Metal Products: September 1987 to August 1990

Hawthorne is a unionized 350 person sheet metal stamping plant operating on three shifts. Initially there was not an active safety or ergonomic committee. Accordingly, I established both committees and worked closely with them to make them productive and efficient teams.

Established various programs to address safety hazards identified. These methods included the use of OSHA training consultants, requested OSHA on site inspections, development of safety and ergonomic committees, and poster awareness programs. The ergonomic awareness program was my most effective program. I contracted an independent ergonomist to work with me in the plant performing individual job analysis. In the process we trained various individuals in ergonomics. I purchased a computer analysis program that allowed me to evaluate the stress put on several joints (ankle, lower back, shoulder, knee, etc.) and determine if the average person should have the muscle capacity to perform the job as designed. If not, I was able to modify the job, in the computer, until it was correct and make recommendations on how to modify the affected workstation.

Identified work stations with potential safety hazards. Through use of the computerized ergonomic analysis program mentioned above, and individual job analysis, modifications were put in place to address these conditions. They primarily included reducing bending and twisting along with a reduction of wrist deflection. The lifting and twisting was addressed by raising containers off the floor and positioning them in more convenient locations (proper work station set-up). I addressed the wrist hazards through use of improved tool design and work station design. I started an awareness education program aimed at informing the employees of the dangers of poor work station design and how it could affect their muscular skeletal system. Job rotation was implemented as an administrative way of reducing exposure.

Conducted accident investigations and reported to upper management on accident and lost work day case rates. My accident investigations consisted of conversations with the injured employee, witnesses, area supervisor, and often the area superintendent. I visited the accident scene and took pictures when appropriate. The information gained through my investigations was shared with the affected employee and their supervisor. All plant management was briefed on the accidents in an effort to minimize the possibility of reoccurrence. Corrective action, as required, was implemented. Monthly accident rate graphs were presented to upper management showing present rates as compared to the previous 12 months. All of this information was shared with the safety / ergonomic committees in weekly meetings. When available a member of the safety committee would join me in the accident investigations and report to the rest of the committee. The results of the investigations were often the subject of weekly safety talks to the general work force.

Performed noise analysis for the plant and implemented sound abatement processes as needed. Established confined space training program and insured all confined spaces were identified and properly labeled. Conducted air quality analysis for total particulates and initiated containment processes as required.

General Motors: April 1977 t October 1985

While at General Motors I worked as a production supervisor, industrial engineer, and in die design. As a supervisor I was responsible for scheduling, production, and the safety of all those in my department. As an industrial engineer I was assigned to a manpower evaluation project matching the amount of work assigned to available work hours. In the die design department I was responsible to train die designers how to design using CAD, instead of drafting boards.

US Air Force Reserves: May 1984 to May 1996

As an officer, in a United States Air Force Reserves Civil Engineering Squadron, I was responsible for compliance with construction standards, building safety for the construction trade work shops, and on the job safety for facilities under construction or being remolded.

Developed monthly safety talk program. Safety talk subjects varied each month. Conducted safety training programs covering subjects like shop safety, construction site safety, heat stress, and off-the-job safety.

Developed safety teams within each skilled trade’s discipline. This team accompanied me on inspections and performed inspections on their own. Team members received on the job safety

training as well as classroom training conducted by myself or a senior member of the trade.

Conducted monthly inspections of all skilled trades work shops. The shops (carpenter, plumbing, electrical, heating and air conditioning, and heavy equipment) were located in several buildings. Inspection of the shops included building safety, safety operating practices, and equipment safety. Results of the inspections were immediately reviewed with the individual in charge. Corrective actions were tracked on a matrix, with the conditions having the most potential for injury taking priority.

Conducted work site safety evaluations at all new build and remodeling sites. Several of these sites were in third world countries and required compliance with local regulations, as well as standard regulations. The third world county construction sites usually involved design and construction of a sanitation system. Depending on the soil conditions and site, this ranged from a simple drain field to a complicated engineered system requiring complicated pumping calculations with extensive soil removal and replacement with sand, gravel, and pea rock.

Evaluated the United States Air Force Civil Engineering Wartime Tasking School curriculum. The purpose of this school is to teach military personnel how to react to the dangers associated with chemical, nuclear, biological, and conventional attacks. There was an existing program that had to be evaluated for conformance to military standards and the current threat. After determining conformance to regulations it was necessary to determine if the present method, used to protect against chemical attacks, was sufficient.

Considerable research and extensive meetings with instructors and experts in the field was required to determine the best way to protect people from these hazards. Ultimately, 12 volumes of procedures, one for each job classification, were written outlining the safety procedures to be taken during a chemical or conventional attack. My suggestions were implemented into the curriculum at Eglin Air Force Base, Florida and at a new United States Military school in Japan.

The curriculum, addressed above, was not only for individual protection but covered all aspects of chemical exposure and control. I addressed procedures used to determine if someone, or something, was contaminated, as well as how to decontaminate individuals and equipment, water purification techniques, personal protective equipment (proper wear and care of it), and procedures used to determine the duration of contamination.

US Air Force: Active Duty March 1973 to October 1976

I was a pilot assigned to a C-130 squadron. My additional duty was “Squadron Safety Officer”. In this capacity I was a member of the base safety team. The team conducted safety inspection of all base facilities and runways conditions. We participated in annual rotations to Europe and Central America. When deployed, I retained the responsibility to conduct safety inspections of the facilities we were involved with, as well as my flying duties. My flying duties took me to 48 of the 50 states, to many European countries, North Africa, the Middle East, and the Caribbean and Middle America.