A chemical plant in Texas was due for a “turnaround”, a time when the plant shuts down production for regular equipment maintenance and deep cleaning. Coke, a sludgy byproduct when refining hydrocarbons, had built up within a vessel and it was time to clean and maintain the equipment. The plant hired two teams of contractors — the first would clean the vessel; the second would repair and maintain the hardware. However, in a deliberate move to save time and money, the plant cut corners and had both crews work simultaneously. The cleaning crew blasted away the coke using high-pressure water hoses, churning up the sludge and aerosolizing some of the flammable hydrocarbons. Suddenly, a static charge caused by the hydro-blaster ignited the fumes. Like a bomb detonating, flames ripped through the vessel. One of the maintenance contractors, a welder in his late 20s, had worked in chemical plants since high school and was very familiar with the equipment. He was awaiting his team’s turn to perform “hot work” once the cleaning crew finished. The explosion changed his life forever.

The blast literally knocked the young welder off his feet with such force that his steel-toed boots remained upright on the platform. The intense heat burned his clothes off his body, and the pressure flung him to the bottom floor. He slammed into the ground, fracturing both legs and injuring his neck and back. As he slowly woke up, bleeding profusely, plant first-responders put him in a wheelbarrow and carted him away from the area. From there, he was taken to an emergency room. The welder was covered in burns to his face, chest, stomach, and groin. He spent days in the burn unit, enduring a host of surgeries that foreshadowed a long recovery ahead.

Several days after the explosion, the welder’s frantic mother called attorney Muhammad “Mo” Aziz of Abraham, Watkins, Nichols, Agosto, Aziz & Stogner in Houston, Texas. She had found Mo through a client who was burned in a separate chemical explosion and who happened to have gone to the same high school as the young man. Mo, having worked with victims of chemical plant incidents, immediately accepted the case. He started compiling evidence of what happened, with the goal to understand why the explosion occurred.

Mo’s immediate concern was understanding how the explosion was triggered. What ignited the coke vapors? Knowing where the initial spark came from was crucial to supporting his case. The Defense pointed the finger at the welding crew for the heat that created the blast. But Mo felt the cause was something else. For one, no welding took place during the explosion. Mo brought on an arsenal of experts, including those specializing in liability, explosions, OSHA procedures, and the standard of care expected from contractors. The blast modeling expert demonstrated the force of the explosion; an air modeling expert proved that the air inside the vessel reached explosive levels; and ignition experts determined that static electricity from the water blaster sparked the massive blast. Slowly, they uncovered that the blast had nothing to do with the welders.

The chemical plant assembled an army of internal and external legal teams. They were ready for battle. Mo needed much more than an ignition source to attain justice for the injured welder. The Defense was sophisticated and had superior knowledge of the intricate, specialized, heavily regulated plant operations. They refused to take responsibility for the permitting errors that caused the welders to be onsite before they were needed. Their primary claim was the contractors didn’t properly monitor the interior atmosphere of the vessel. In fact, the Defense claimed that because the explosion was a workplace accident, the Plaintiff should deal with workers comp, not them.

With his argument taking shape, Mo still also had to illustrate the damages that his client suffered and the subsequent impact they would have on his life. He needed compelling visuals for his jury presentation. Knowing the quality of work that would depict the contractor’s internal and external damages, Mo contacted DK Global. Together, they created a visual presentation of the Plaintiff’s injuries, from his burns to his broken bones.

The presentation began by showing the second-degree burns to the welder’s head, neck, trunk, bilateral upper extremities, genitalia, and lower extremities. Next, the animation revealed internal damage, beginning with bilateral tympanic membrane perforations in his ear. From there, a skeleton animation showed his central disc herniation at C3-C4, C4-C5, and C5-C6 areas. Then, mild atrophy of the teres minor was displayed, followed by an anterior labral tear. The animations went on to display the ligament sprain, supraspinatus tear, hepatic laceration, anterior spleen laceration, hemorrhage, numerous fractures, hematomas, open wounds, meniscus tear, and myriad fractures. Finally, the video animation showed the skull fracture — with a 3D animation of the victim’s exterior and interior parts of his head where it occurred.  Seven other separate animations were created to demonstrate the surgeries that took place for the fractures and other injuries. They included a detailed look at what surgical procedures took place to fix this young man as best as possible.

Mo and his team were ready to present the DK Global presentation to a jury, but first, he showed the animations to the Defense at mediation. With the detailed clips of what the Plaintiff endured, the Defense couldn’t come up with much to counter. Right before a jury was to be selected, the plant’s Defense team offered to settle for an amount in the high-eight-figures. Mo and the Plaintiff accepted. It was life-changing for the victim and his family, bringing closure to a harrowing ordeal. Though he’ll live with the devastating injuries for the rest of his life, he’d be able to afford future medical treatments and care for his family.

Muhammad “Mo” Aziz has been a Partner at Abraham, Watkins, Nichols, Agosto, Aziz & Stogner in Houston, Texas since 2012. He specializes in personal injury trial law. Currently, he represents over 5,000 veterans and active service members. Mo is known for his attention to detail in each case, which has resulted in multimillion-dollar outcomes.