What Do You Think?
Does violating a safety rule at work mean the resulting injury isn’t compensable? Sometimes. A case involving a maintenance man for a milk manufacturing company whose finger was partially amputated addresses how violating the rules may mean that the employee was acting outside the course and scope of employment.
One of the worker’s duties was to repair machines at his employer’s plant. One day, he was trying ro repair a hydraulic blow hold machine. The machine used immense force to shape plastic containers. He knew his employer’s safety rules required him to turn it off first. But he wanted to avoid the temporary work shutdown that would result. So, with the machine still running, he reached in and got his hand caught by one of the molds as it was closing. The machine crushed part of his right hand and partially amputated a finger.
The incident caused the shutdown of the plant for several hours. Turning off the machine would have shut it down for only a few minutes.
The employer argued that the Workers’ Compensation Commission erred in finding the injury compensable. Because the employer didn’t benefit from the claimant’s egregious violation of its rules, the claimant was not acting in the course and scope of his employment, the employer contended.
The court said that if a claimant knowingly violates a safety rule purely for his own personal benefit or convenience, his actions are outside the sphere of his employment, and he may not obtain compensation for the resulting injuries
Was the claimant injured in the course and scope of employment?
A. No. His rule violation didn’t benefit his employer. In fact, it caused a much longer work stoppage than if he had complied with the rules.
B. Yes. The claimant was doing his job and trying to avoid a work stoppage.
If you selected B, you agreed with the court in Prairie Farms Dairy v. Illinois Workers’ Compensation Commission, No. Appeal No. 4-25-0455WC (Ill. App. Ct. 04/09/26), which found the claimant was acting for his employer’s benefit.
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The court pointed out that if a claimant violates a safety rule while performing the duties for which he was hired, he is acting for his employer’s benefit. In that situation, his negligence does not bar him from recovering workers’ compensation. It does not matter how many rules he disobeys or how “egregious” his violation is.
Here, the claimant was injured while attempting to fix one of the employer’s machines, which was his job. Moreover, he violated the rule to avoid a temporary shutdown of production. There was no evidence that he received any personal benefit from violating the rule or that his motivation was to obtain such a benefit.
“[T]he claimant’s decision to work on the blow mold machine without turning it off, however misguided or negligent it may have been, was made in an effort to advance the employer’s interests,” the court said.
The court rejected the employer’s argument that it did not in fact receive any benefit from the safety violation because the incident shut down production for several hours instead of minutes. However, the only relevant question is whether the claimant was injured while performing his job duties rather than acting for his personal benefit. “ Whether the result of the claimant’s rule violation actually benefited the employer is irrelevant,” the court said
The court affirmed the Commission’s finding that the claim was compensable.
Lesson for employers: There was some evidence in this case that the employer may have pressured employees to avoid shutting down machines when repairing them. Creating written safety rules is not enough to protect workers from injury and employers from liability. Employers need to also support and motivate workers to comply with those rules. Failing to do so can lead to injuries, compensability, and greater work disruption.
