A Port Arthur plant worker claims an industrial cleaning company left behind a mess that caused her to fall down the stairs, permanently injuring her knee.
Sharon Kirk claims she was working as a fire watch for JV Industrial at the Lyondall Chemical Co. plant in Jefferson County.
At the same time, defendant Veolia Environmental Services was performing sand-blasting work and industrial cleaning operations at the Lyondall facility.
Kirk claims Veolia caused a build-up of water, sand and grease to accumulate near stairs where she was working, according to the complaint filed May 13 in Jefferson County District Court.
When Kirk attempted to descend the narrow iron stairs that led to the inside of tank where Kirk was assigned to work on May 31, 2008, she slipped on the accumulated gunk on the stairs outside the tank, the suit states.
"Plaintiffs feet went out from under her and she fell, seriously injuring herself," the complaint says.
"Plaintiff injured her knee. She also sustained injuries to her low back as well as a concussion. The most serious injury, however, is the injury to her knee which prevents her from returning to the job that she was doing and also prevents her from doing the other jobs that she has done in her life."
For example, before she earned $16 per hour working as a fire watch, Kirk worked as a nurse's aide, she claims. But after her fall, Kirk could no longer kneel or climb and was restricted from crouching on a repetitive basis, according to the complaint.
"The problem is that eliminates Plaintiff's ability to perform the duties of a Fire Watch," the suit states. "It also eliminates Plaintiff's ability to return to her previous occupation as a Nurse's Aide. Additionally, Plaintiff has suffered significant psychological problems as the result of her injury and has been required to seek the services of a psycho-therapist."
Kirk blames Veolia for causing her fall, saying workers for the company negligently failed to clean up after themselves, failed to warn of hazardous conditions, created a dangerous condition on metal stairs, failed to barricade the area impacted by its sand-blasting and failed to inspect its work to discover the hazardous condition that it created.
Kirk is seeking an unspecified judgment, plus pre- and post-judgment interest, costs and other relief to which she may be entitled.
Steven C. Barkley of Beaumont will be representing her.
Jefferson County District Court case number: E186-856.