Abstract: On November 30, 2000, Employee #1 was operating a mobile scissor-lift on uneven terrain when the lift fell over, causing fatal injuries. Employee #1 had been with the company for 4 working days (including the day of the accident) and was 61 years old. He had been working in the steel erection industry for approximately 30 years (confirmed only via fellow employees). Employee #1 was trained to operate a scissor-lift by his previous employer (verified through previous employer), but not certified as trained by his current employer. Employee #1 was a member of the local steelworkers union and received most of his training through that organization. The current employer conducted no training. Employee #1 was hired to assist in steel erection activities. Specifically, at the time of the accident, he was placing bolts into steel joists to complete their installation. Employee #1 was using a scissor-lift to position himself so that he could reach the steel joists or beams and insert the missing bolts. The joists were approximately 30 feet from the ground. The scissor-lift was extended to 24 feet (approximate measurement) at the time of the accident. Employee #1 appeared to be moving the scissor-lift into a position perpendicular to the joist he was preparing to work on when the front tires of the lift entered a ditch, located directly below the steel joist. The ditch ran the length of the building. It was created when the footings for the building were poured. The ditch dropped approximately 1.5 feet from grade or the adjacent ground. This drop took place over 4 feet (an angle of 1.5 to 4). As the employee drove the lift closer to the beam in which he needed to work, the front tires entered the ditch and the lift fell forward throwing Employee #1 to the ground. Employee suffered fatal injuries because of the fall. At the time of the accident, the steel erection company was the only sub-contractor at the site. The general contractor had a superintendent at the site. The skeleton of the building was in the process of being erected. The perimeter of the building had been erected and most of the roof joists had been placed. Employee #1 was accomplishing the follow-up work at the time of the accident. Employees would place the beams and install enough bolts to keep the beams in place. Employee #1 was the "finisher." He would move around the site in the scissor-lift and install any bolts that had not been installed at the time the beam was placed. The building, a warehouse, was having steel siding and roofing installed. The scissor-lift was a rental unit that was procured approximately 2 weeks prior to the incident. The operators manual, safety manual, and Manual of Responsibilities were all with the lift at the time it was delivered. These manuals were in the possession of the employer on the day of the accident. The employer did not require the employees to review the manuals despite the warning in the manuals. The manuals discuss operating and surface conditions when operating the unit. It clearly stated that the scissor-lift should only be operated on level ground. The scissor-lift had a telescoping platform that allowed the user to extend the platform an additional 36 inches. The platform had been extended at the time of the accident. This placed the operator in front of the front wheels of the unit and created an unbalanced work platform, accentuated by operating the unit in an area that was not level.