A Norfolk Southern Railway Company employee has filed suit against the railroad, alleging he sustained injuries because of his work for it.

Miguel Luciano claims he began working for Norfolk Southern Railway Company in August 1976 as a trackman. Throughout his work for the company, Luciano was required to use a variety of hand and power tools to repair and install wooden cross ties, to replace track, to secure rails and to place switches and fogs, according to the complaint filed Feb. 11 in St. Clair County Circuit Court.

Because of his use of the tools and the nature of the work, Luciano was exposed to excessive vibration, the suit states.

"Plaintiff routinely and repetitively walked on uneven surfaces and ballast, often carrying tools weighing in excess of 50 pounds for long distances," the complaint says. "Plaintiff routinely did bending and stooping while gathering materials, pulling and hammering spikes, and spreading ballast. Plaintiff routinely squatted while adjusting bolts, switches, or track gauge, and unloading ballast. Plaintiff routinely crouched while measuring track, setting jacks, or using hand tools. Plaintiff routinely knelt while replacing switches, frogs, tie plates, and track bolts. Plaintiff routinely had to climb up embankments or up into truck to load materials. Plaintiff routinely had to carry and lift his tools, frequently carrying such tools over long distances."

Luciano claims his repetitive stress injuries grew even more serious over time after he was forced to work overtime to finish jobs.

Because of his work, Luciano suffered injuries to his neck, back, spine, shoulders, elbows, knees, feet, hands, fingers and ankles ; incurred pain and suffering; will be forced to endure surgeries; suffered psychological and emotional injury, mental anguish and anxiety; and incurred medical costs, according to the complaint. In addition, he lost wages and benefits, the suit states.

Norfolk Southern negligently failed to provide Luciano with a safe place to work and with safe work conditions; failed to provide Luciano with safe equipment, safe methods and adequate manpower; failed to take action to reduce the amount of cumulative trauma to which employees were exposed; failed to test employees for the physical effects of cumulative trauma; failed to warn Luciano of the dangers to which he was being exposed; allowed Luciano to be exposed to dangerous amounts of cumulative trauma; and failed to inspect the amount of cumulative trauma to which employees were exposed, the complaint says.

In his complaint, Luciano is seeking a judgment of more than $50,000, plus costs.

Roger C. Denton and Julia M. Kerr of Schlichter, Bogard and Denton in St. Louis will be representing him.

St. Clair County Circuit Court case number: 10-L-59.

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