In this matter, the principal causative factors related to this incident were (a) the presence of a wet floor surface due to a recent wet mopping, (b) the lack of precautions to prevent exposure of pedestrians to the wet floor surface, (c) the failure of defendants to properly train their employees in the causes and prevention of slip-type falls and the safe performance of their work tasks, and primarily, (d) the failure to develop, implement, and monitor a proper floor maintenance program/protocol that will effectively eliminate or minimize exposure to wet floor surfaces and prevent slip-type fall incidents such as occurred in this matter, to include the practice of dry mopping to remove moisture from the floor (rather than letting it air dry/evaporate over time), and the effective use of warning signs, barricades, and verbal warnings to inform pedestrians of the hazardous condition.
Defendants knew or undeniably should have known of their responsibility to exercise reasonable care to perform their contracted housekeeping services in a competent and safe manner to prevent the creation of hazards likely to cause serious physical harm, and ultimately failed in their responsibilities.
In summary, defendants failed to perform their contracted housekeeping services in a safe manner to prevent the leading cause of injury to the public, which are fall-type incidents. That is, the failures discussed in this report by defendants created an unreasonable risk of harm that ultimately caused plaintiff to slip and fall during the performance of her work duties. Further, defendants knew or should have known of such danger, and yet failed to make the condition safe, or at the very least, adequately warn of such condition.
The expert has been a professional engineering consultant since 1999, primarily consulting in the field of safety engineering, including workplace safety, premises safety, product safety, safety management, and human factors/ergonomics.