Abstract: EMPLOYEE #1 WAS WORKING ATOP A MANUALLY PROPELLED MOBILE SCAFFOLD WHICH WAS 16 FEET, 8 INCHES HIGH. THE FLOOR WAS LITTERED WITH PLASTIC FLOOR COVERINGS, COVERING TWO 8 1/2 INCH DIAMETER FLOOR DRAINS AND NUMEROUS ELECTRICAL CONDUITS. EMPLOYEE #1 WAS PAINTING THE CEILING IN THE PLANT'S OPERATIONS BUILDING. HE WAS ATOP THE SCAFFOLD WHILE IT WAS BEING MOVED TO ANOTHER SECTION OF THE WORK AREA. A SCAFFOLD CASTER FELL INTO ONE OF THE FLOOR DRAIN HOLES, CAUSING THE SCAFFOLD TO TIP ONTO A RAISED SECTION OF THE FLOOR, 13 FEET, 8 INCHES BELOW. THE FLOOR WAS MADE OF FINISHED CONCRETE. EMPLOYEE #1 WAS DUMPED TO THE CONCRETE SURFACE, FRACTURING BOTH LEGS. A LADDER WAS NOT AFFIXED TO, OR BUILT INTO, THE SCAFFOLD, NOR WAS THE ELEVATED WORK PLATFORM FULLY PLANKED. THE EMPLOYEE WAS AN INEXPERIENCED PAINTER. NO FALL PROTECTION, (IE, SAFETY BELTS OR LIFE LINES) WAS PROVIDED.