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Alexander v. Demmer Corporation8/20/2002
previous job and moving on to the next one.
Q: Is it your recollection that there was any problem with the production process itself on the new Danly line at that time that resulted in a die change?
A: No.
Q: . . . . Is it your understanding that at the time Kay was injured that the interlock gate was open?
A: Yes.
Q: And that there were two employees inside the gated area cleaning the pinch rollers?
A: Yes.
Q: And that there was no lockout of the pinch rollers?
A: No.
Q: And is it also your understanding that as Mary and Kay were working on the pinch rollers they were set to rotate in forward rather than reverse?
A: Yeah, that's the only way that it could have happened. I mean--
Q: And that they were cleaning these rollers with rags in hand?
A: Yes.
Q: And that the procedure they were following, apparently, was jog, wipe, jog, wipe?
A: Yes.
Q: (BY MR. BOUGHTON) The crew cleaned the pinch rollers on this machine many times during that six-or eight-month period before Kay was injured?
A: Yes.
Q: And there would be a significant opportunity to watch their practices and procedures when they were doing that, correct?
MR. COLLINS: I am still going to object to the form, because I don't know who you are saying is watching them, and I don't know what significant opportunity is.
Q: (BY MR. BOUGHTON) You would have an opportunity to watch them during that period of time if you wanted to, correct?
A: Yes.
Q: And so would the foreman?
A: Yes.
Q: Did you ever make it your business to watch the practice that Mary and her crew used to clean the pinch rollers and levelers during the six-to eight- month period of time?
A: Yes.
Q: Did you ever have to give them any instructions about the practices and procedures that they were using during this period of time?
A: I don't recall ever giving them any. [Emphasis added.]
Q: Do you recall anybody being disciplined in any way before Kay for a practice or procedure used on cleaning these rollers?
A: I don't recall.
Q: So would it be fair to say that it was the practice of the crew to clean the pinch rollers with rag in hand during this period of time.
MR. COLLINS: What set of rollers are you talking about?
Q: (BY MR. BOUGHTON) The pinch rollers, yes.
A: Yes.
Q: Why isn't lockout used when cleaning the pinch rollers?
A: I am going to say that it was - it's a time, a time situation where it would take too long to lock it out, clean it, unlock it, clean it, unlock it. That's pretty much my thoughts on it. [Emphasis added.]
Collins' actual knowledge
Andrew Collins testified at deposition that he began employment at Demmer in August 1995, as Plant Manager, oversaw the plant's general operations and supervised all Demmer employees, directly or indirectly. Although Collins was not yet employed at Demmer when Eddie Williams was injured on the R-1062 in March 1995, or when the state investigated and cited Demmer for MIOSHA violations in July 1995, Collins testified that he was aware of Williams' injury and of MIOSHA's investigation and issuance of violations to Demmer, and that he was "somewhat" involved in the "abatement process" Demmer undertook to cure the 1995 MIOSHA violations. In October 1995, Collins and McKenna signed a "Safety Mission Statement" defendant submitted to MIOSH
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