Dow Chem. Co. v. Bright
In Dow Chem. Co. v. Bright, 89 S.W.3d 602, 606-07 (Tex. 2002), the Court held that the premises owner did not exercise actual control when it had a safety representative on site who could have stopped the independent contractor's employee from working had it known of the safety hazard on its premises. Bright, 89 S.W.3d at 608.
The Court concluded that neither the presence of Dow's safety representative at the jobsite nor Dow's "safe work permit" system constituted evidence that Dow controlled the method of the independent contractor's work or its details. Id. at 608-09.