State ex rel. Grunau Fire Protection Systems, Inc. v. Industrial Commission

The parties agree that the fixation and maintenance of the ladder did not comply with Ohio Adm.Code 4121:l-3-ll(E)(l), which states in part:

*322“Fixed ladders shall be provided and maintained in place until temporary or permanent stairways are ready for use.”

A YSSR, however, requires more than a showing of violation and proximate cause. It also demands that the claimant’s employer be the party that violated the specific safety requirement. State ex rel. Lyburn Constr. Co. v. Indus. Comm. (1985), 18 Ohio St.3d 277, 18 OBR 329, 480 N.E.2d 1109. Failure to satisfy the latter dictates a finding that…