Jeremy Souders v. Exxon Mobil Corporation

CourtCourt of Appeals of Texas
DecidedApril 2, 2024
Docket01-21-00593-CV
StatusPublished

This text of Jeremy Souders v. Exxon Mobil Corporation (Jeremy Souders v. Exxon Mobil Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeremy Souders v. Exxon Mobil Corporation, (Tex. Ct. App. 2024).

Opinion

Opinion issued April 2, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00593-CV ——————————— JEREMY SOUDERS, Appellant V. EXXON MOBIL CORPORATION, Appellee

On Appeal from the 80th District Court Harris County, Texas Trial Court Case No. 2018-51413

MEMORANDUM OPINION

Jeremy Souders sought damages from Exxon Mobil Corporation for personal

injuries he sustained while working at Exxon’s Baytown facility. During a routine

crane lift, Souders was pinned between two 30,000-pound heat exchanger bundles

and suffered extensive injuries. A jury awarded Souders $60,000 in damages for past loss of earning capacity. Both Souders and Exxon appealed. For the reasons

discussed below, we reverse the trial court’s judgment and render a take-nothing

judgment in favor of Exxon.

BACKGROUND

Exxon’s Baytown Facility and the Turnaround

Souders’s accident occurred while he was working at Exxon’s Baytown oil

refining facility during a “turnaround.” A turnaround is when Exxon shuts down

parts of the facility for major maintenance. Exxon hired JV Industrial Companies,

or JVIC, as an independent contractor to perform crane and rigging operations for

the turnaround. Souders was a JVIC employee and a certified advanced rigger.

During this turnaround, Exxon shut down and was repairing its flexicoker

unit. The flexicoker unit refines crude oil by converting it to lighter materials like

gasoline, diesel, and low butane gas. Inside the flexicoker unit are heat exchanger

bundles that transfer heat for either heating or cooling the oil. A heat exchanger

bundle is a 30,000-pound cylinder made of metal coils. Generally, during the

turnaround, the bundles were removed from the flexicoker unit, moved to an open

staging area called the 152 yard, and then moved to another open area called the

wash slab for high-pressure cleaning.

Exxon requires crane operators and riggers who work for its independent

contractors to be nationally certified in crane operation and rigging, respectively.

2 These certifications mean the crane and rigging crews already have the qualifications

and skills to perform crane lifts before working at Exxon’s facilities. Exxon also

requires site-specific safety training. Exxon’s safety guidelines do not train

independent contractors on how to operate cranes or rig loads for lifting but are

meant to reinforce safety guidelines the contractors already know as well as add site-

specific rules.

One set of Exxon’s site-specific safety guidelines is MWP 9080.1 MWP 9080

establishes minimum safety guidelines for crane lifts and provides a framework for

performing crane lifts safely. For instance, MWP 9080 requires a crew, before

performing a crane lift, to complete a lift plan checklist and to identify exclusion

zones. An exclusion zone is basically a zone of danger around a lift—it includes

areas around the load being lifted where a person could be struck or crushed by the

load. MWP 9080 also requires each crew to identify a lift director before each lift.

The lift director is a member of the crew who is responsible for making sure the lift

plan checklist is properly filled out before the lift, leading a pre-lift briefing to review

the lift plan checklist with the crew, and ensuring that the exclusion zones are

established and effectively managed.

MWP 9080 defines basic and complex crane lifts. A basic lift is any lift that

does not meet the definition of a complex lift. A complex lift is defined to include

1 MWP stands for “maintenance work practice.” 3 several types of lifts, like a lift using nonstandard rigging practices or special

equipment, a lift using 80% of the crane’s capacity, a lift weighing more than 50

tons, or a lift using two cranes. An Exxon site lift specialist must sign off on a

complex lift before an independent contractor crew can perform the lift.

When Souders was injured, Exxon was also in the process of implementing a

new set of site-specific safety guidelines, Tier 1 Best Practices or T1BP. Several

months earlier, an employee of an independent contractor was injured during a crane

lift—because the independent contractor was called Jacobs, this was known as the

Jacobs incident. As a result of the Jacobs incident, Exxon decided to implement

T1BP to improve safety among its contractors. By the time of Souders’s injury, some

contractors, like Souders, had received T1BP training, but others had not because

Exxon was still in the process of training all its contractors.

Like MWP 9080, T1BP also defines minimum safety requirements to prevent

injury during crane and rigging activities. T1BP generally requires crew members to

actively participate in pre-lift briefing, know the boundaries of the exclusion zones,

understand the items in lift plan checklists discussed during pre-lift briefing, and

sign the checklists. T1BP also requires that each lift have a lift director, and it

requires the lift director ensure that all lift plan checklists have been completed and

that all crew members participate in a pre-lift briefing that covers the plan for

managing exclusion zones.

4 Exxon’s safety guidelines like T1BP and MWP 9080 are only meant to

reinforce safety practices the crane and rigging crews should already know; Exxon

does not provide comprehensive training for crane rigging and operating. Neither

MWP 9080 nor T1BP explain how to perform crane and rigging operations.

Independent contractors, like JVIC, are responsible for the training and

qualifications of their crews.

When Souders was injured, Exxon knew that not all contractors had

completed T1BP training and that some of Exxon’s supervisors were not yet

knowledgeable about T1BP. After the Jacobs incident, Exxon conducted a T1BP

audit and found:

• Observations have indicated site rigging groups with gaps in their execution of the new Tier 1[;]

• Implementation has been taught in classroom setting and minimum field verification has been performed[;] • Majority of the review process has taken place in the form of desktop review of completed paperwork and in field only when clarification required it[;] • Lack of site Mechanical [supervisor]s being trained on the Tier 1 BP has [led] to a lack of knowledgeable oversight in the field[; and]

• Left unchecked, this lack of knowledge and oversight could provide an opening for a serious incident[.]

The Accident

On May 1, 2018, Souders and his JVIC crew were working the night shift. His

crew included Harold Bird, the crane operator, and Richard Hubbell and Raul Ortiz,

5 two riggers like Souders. Each member of the crew had NCCCO or NCCER

certifications. The crew was experienced: Bird had over 35 years’ experience, and

the two other riggers each had more than 15 years’ experience and were certified

riggers. Souders himself had been a certified rigger for more than five years and had

gone through T1BP training. Souders, however, was the only member who had

received T1BP training.

Souders’s crew started in the wash slab that evening, the open space where

equipment was cleaned.

Gerald Adams, Exxon’s acting supervisor over the 152 yard, was supervising

a crane disassembly in another part of the facility and was not supervising Souders’s

crew that night. After Adams spoke with Hubbell, he understood the crew would be

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