Here are some thoughts about a safety cross examination when the defendant has failed to take steps to prevent hazards, injury or death to others. The evaluation process involves at least some of the following in this outline

EVALUATING THE COST AND EFFORT INVOLVED TO ELIMINATE OR MINIMIZE THE HAZARD

1. Isn't it true that:

   Any risk of serious bodily injury or death is always unacceptable if reasonable means could have been used to minimize or eliminate  the danger?

2. Agree that "it's better to be safe then sorry?"

3. Agree that in evaluating what was reasonable to have eliminated, prevented or minimized the chance of this death we should consider:

   (1)    Is the proposed accident prevention action possible to do?
            (a) Wasn't it possible to do?

   (2)    Is it a known and accepted accident prevention method? - used by others?
            (a)  It's true that this was a known and accepted practice?

   (3)    What would it cost?
            (a)   Isn't true this would have cost only $_______?
            (b)   Isn't it better and costs less to prevent accidents then to do nothing to prevent them?

   (4)   How much time does it take?
            (a)   Isn't true it would have taken only ________to have taken steps to prevent?

   (5)    How difficult is it to do? - what effort is required?
            (a)   It's true this would have only taken __________ to do had the company chosen to do it?