Abstract: As part of his job as a steam cleaner, Employee #1 uses a hot water/high pressure cleaning unit to clean out truck-mounted tomato bins. He also cleans up spilled tomatoes that fall from a re-sort operation, shoveling waste into a forklift-mounted dump bin. When the bin is full, he drives the forklift to a large dumpster, raises the dump bin, and trips a lever on the dump bin. On the evening of September 11, 1994, Employee #1 raised the bin and dumped, but the forklift mast jammed. He borrowed a hammer and pry bar and got under the raised forks. When he freed a chain that was jammed in the forklift mast, the forks fell and hit him, causing a serious vertebra fracture.