Introduction: In this personal injury case, truck drivers from two different contract companies had an unfortunate interface when one became pinned between their vehicles during a routine parking maneuver. We were asked to identify the responsibilities for the incident, which required our review of regulations, industry standards, and safe work practices. Baker & O’Brien presented our opinions in an expert report supporting the dispute resolution.

The mobilization or demobilization of a drilling rig from a wellsite typically involves simultaneous activities. Numerous coordinated and parallel activities involve a lot of movement of equipment and personnel. Dismantling a rig requires the use of manual tools and heavy lifts by high-capacity cranes. Safety procedures are established and known to the workers to help prevent the undesirable intersection of people and heavy equipment.

A wellsite operator had three contracts with 1) a drill rig’s owner, 2) a hydro-excavation (hydro-vac) truck, and 3) a transport truck service provider. The hydro-vac truck collected drilling fluids and wastewater from the wellsite and transferred those to the transport truck driver for disposal. After the hydro-vac operator transferred three loads to the transport truck, its driver would depart the site for disposal.

Before conducting a heavy lift of equipment from the rig, the two truck operators were directed to move their transport trucks to another location away from the rig for a short duration. While parked at the temporary location, unbeknownst to the transport truck operator, the hydro-vac driver had parked at the rear of one of the transport trucks to transfer a load. Upon maneuvering for a return to the rig, the transport truck reversed and pinned the hydro-vac driver between the two vehicles.

Baker & O’Brien was engaged to identify responsibilities at the wellsite during demobilization pursuant to contractual obligations and industry standards. We identified the relevant regulations, industry standards, and contractual responsibilities for independent contractors, and presented our opinions in an expert report.