(dissenting):
I respectfully dissent. I would affirm the trial court’s determination that Montgomery failed to present sufficient evidence to survive summary judgment on any of his three theories of CSX’s alleged negligence under FELA.
A FELA action in state court is controlled by federal substantive law.1 I agree that, under the federal FELA standard, a plaintiff in a FELA case need only show that the “employer’s negligence played any part, even the slightest, in producing the injury.”2 Nevertheless, although the quantum *551of evidence sufficient to present a jury question of causation in a FELA case is less than that required in a common law tort case, the plaintiff must still demonstrate some causal connection between the defendant’s negligence and the alleged injury.3 As the South Carolina Supreme Court has recognized, “ ‘the FELA ... is not to be interpreted as a workers’ compensation statute.’ ”4
In support of his argument that sufficient evidence was presented of CSX’s failure to provide sufficient help with the repair of the S-line, Montgomery points to the affidavit of Don A. Bowden, a railroad safety consultant, who stated as follows:
5. Under common industry practice, this job should not be done by one man alone. Mr. Montgomery was assigned to the monumental task of repairing the track by himself. While it is not uncommon for one man to be assigned a task in inspecting a track, it is unreasonably hazardous to require one man to not only inspect the track, but also perform the actual track maintenance himself. A prudent and reasonable railroad would assign a gang of men to do this type of job. To do otherwise, in my opinion, subjects the employee to an unsafe workplace in the railroad industry because an accident is bound to happen.
I agree with the trial court that, because the dispute here did not involve a task that required more than one worker, such as dragging a heavy object, assigning additional employees would mean only that the job would be finished more quickly.5 Indeed, it was acknowledged by Montgomery him*552self that CSX imposed no time limits or quotas for the work Montgomery was performing at the time of his injury.6 Moreover, Bowden did not explain why the task assigned to Montgomery was unreasonably dangerous without additional help or how Montgomery’s accident was “bound to happen” as a result of this circumstance.7
In addition, Montgomery cites Forcino v. National Railroad Passenger Corp.8 in support of his argument that an unreasonable work assignment from CSX proximately caused his injuries. I agree with CSX that this reliance is misplaced.
In Forcino, the plaintiff, while repairing a track that had been damaged by a derailment, allegedly injured himself as a result of the strain and fatigue of the heavy work. Unlike Montgomery, however, Forcino was performing a task outside his regularly assigned duties when he was injured, had been told to rush to finish the job to which he had been reassigned, and had worked without taking his normal afternoon break. In contrast, at the time of his injury, Montgomery was doing the same tasks that he had been performing for at least the previous month, had never claimed to be affected by fatigue, and by his own admission was instructed to go only as far as he was able to work at his own speed.
Montgomery further challenges the trial court’s determination that “[t]he lack of any time requirement precludes a claim *553that defendant exposed plaintiff in a ‘fatigued and exhausted condition to unreasonable peril’ so that defendant could be found negligent in doing so.” Assuming without deciding that Montgomery is correct that the trial court should not have made this finding, this error is of no consequence. Montgomery never specifically argued on appeal that he was suffering from fatigue or exhaustion on the day he was injured.
Montgomery further contends that the practical considerations of the burdens imposed by CSX could yield the inference that he felt pressure to maintain more bolts than could be reasonably expected of an employee in his situation. This argument lacks merit.
Montgomery first points out that, had he tightened only as many bolts as his supervisor agreed was reasonable during a normal workday, he would have taken almost eight years to complete his assignment.9 He further argues that testimony from his supervisor that CSX would lose profits when a rail is in disrepair gives rise to an inference that CSX would look unfavorably on his performance unless he worked at a faster than normal pace. There was no evidence, however, that Montgomery himself was aware of any financial concerns of CSX.
Similarly, Montgomery cites the threat of a shutdown of the S-line by the Federal Railroad Administration as additional evidence of an internal time pressure imposed by CSX. He testified in his deposition that there had been “some talks ... that ... [the] ‘S’ line was in bad shape, that something had to be done or they were talking about shutting the railroads down.” I agree with CSX, however, that this evidence was hearsay and therefore properly rejected by the trial court.10
*554Similarly, I find no merit to Montgomery’s argument that he had presented sufficient evidence to support a finding that CSX was negligent in providing him with only a manual track tool.
Under FELA, employers .are under a duty to exercise ordinary care to supply machinery and appliances reasonably safe and suitable for the use of their employees; however, employers are not required to furnish the latest, best, and safest appliances, or discard standard appliances upon the discovery of later improvements, provided those in use are reasonably safe and suitable.11 It is undisputed that the track wrench Montgomery was using when he fell was not defective and was similar to other track wrenches he had used for the past twenty years.
The focus of this controversy comes down to whether CSX should have provided a bolt-tightening machine in view of expert testimony suggesting that a manual track wrench, although not defective, was unreasonably dangerous for Montgomery’s assignment.12
Bowden provided a statement acknowledging that, although a manual track tool was safe and suitable for sporadic tightening and untightening of bolts, the Andrews subdivision “was in such a state of disrepair that the use of a track wrench was not only impracticable, it unreasonably increased the likelihood of injury to Mr. Montgomery.” Bowden further noted that, as the S-line “had been neglected by CSX for a long period of time,” “CSX should have known that the bolts were very likely to be ‘rusted on,’ making them very difficult to remove and/or tighten.” Similarly, Tyler A. Kress, an industrial engineer, stated in an affidavit that “when an employee is forced to use a manual track wrench all day long on rusted and poorly tended nuts and bolts, the risk of injury increases with each repetitive use.”
*555I would hold the trial court correctly concluded that the expert opinions offered in response to CSX’s summary judgment motion do not give rise to an inference that a manual track wrench was not reasonably safe for the work that was assigned to Montgomery. There was no admissible evidence supporting a finding that Montgomery was subject to any pressure with respect to the amount of work he had to complete in any given time period. Furthermore, the record is devoid of any suggestion that Montgomery was suffering from fatigue or other ill effects of repetitive motion.13
Finally, citing Blair v. Baltimore & Ohio Railroad Co.,14 Montgomery argues he presented sufficient evidence of negligence on the part of CSX through the combined effect of its failure to provide him with the necessary help and its refusal to give him proper equipment. I disagree.
In Blair, the Supreme Court, in reinstating an award under FELA, held there was sufficient evidence of the railroad defendant’s negligence to have the issue determined by a jury. In so holding, the Supreme Court stated as follows:
The negligence of the employer may be determined by viewing its conduct as a whole. And especially is this true in a case such as this, where the several elements from which negligence might be inferred are so closely interwoven as to form a single pattern, and where each imparts character to the others.15
*556Further reading of the opinion, however, indicates that the cumulative impact of the “several elements from which negligence might be inferred” was not the deciding factor in the decision. Rather, it is evident from the text immediately following what is quoted above that the Supreme Court had already accepted the premise that the railroad employer was negligent in several respects, any one of which would have been actionable in its own right, and the relationship between all of these undisputed manifestations of negligence only enhanced an already meritorious action:
The nature of the duty which the petitioner was commanded to undertake, the dangers of moving a greased, 1000 pound steel tube, 30 feet in length, on a 5 foot truck, the area over which that truck was compelled to be moved, the suitableness of the tools used in an extraordinary manner to accomplish a novel purpose, the number of men assigned to assist him, their experience in such work and their ability to perform the duties and the manner in which they performed those duties — all of these raised questions appropriate for a jury to appraise in considering whether or not the injury was the result of negligence as alleged in the complaint. We cannot say as a matter of law that the railroad complied with its duties in a reasonably careful manner under the circumstances here, nor that the conduct which the jury might have found to be negligent did not contribute to petitioner’s injury “in whole or in part.” Consequently, we think the jury, and not the court should finally determine these issues.16
In contrast, none of the specifications of negligence alleged in the present case had sufficient evidentiary support to withstand CSX’s summary judgment motion. Blair therefore is easily distinguishable from the present case.
I would affirm the grant of summary judgment to CSX.
. Norton v. Norfolk S. Ry., 350 S.C. 473, 476, 567 S.E.2d 851, 853 (2002).
. Rogers v. Mo. Pac. R.R., 352 U.S. 500, 506, 77 S.Ct. 443, 1 L.Ed.2d 493 (1957).
. Norton, 350 S.C. at 480 n. 5, 567 S.E.2d at 855 n. 5 (quoting Hernandez v. Trawler Miss Vertie Mae, Inc., 187 F.3d 432, 436-37 (4th Cir.1999)).
. See Frazier v. Norfolk & W. Ry. Co., 996 F.2d 922, 923 (7th Cir.1993) (concerning a plaintiff who was injured while unloading 11,600-pound double-axle wheel assemblies from a trailer); S. Ry. Co. v. Welch, 247 F.2d 340, 341 (6th Cir.1957) (noting "circumstances of particular difficulty" warranting assigning additional personnel to assist in a particular task); McKennon v. CSX Transp., 897 F.Supp. 1024, 1027 (M.D.Tenn.1995) (holding in a summary judgment case that “the fact that Plaintiff’s job would have been easier if there had been more workers does not constitute negligence on the part of Defendant, nor does it create an unreasonably unsafe work environment”).
. Montgomery testified in his deposition as follows: "I was supposed to go on as far as, you know, my work time would allow me to and you know, get off.”
. See Lujan v. Nat’l Wildlife Fed’n, 497 U.S. 871, 888, 110 S.Ct. 3177, 111 L.Ed.2d 695 (1990) ("The object of [Rule 56] is not to replace conclusory allegations of the complaint or answer with conclusory allegations of an affidavit.”); Lavender v. Kurn, 327 U.S. 645, 66 S.Ct. 740, 90 L.Ed. 916 (1946) (stating speculation and conjecture are not a substitute for probative facts); Zarecki v. Nat’l R.R. Passenger Corp., 914 F.Supp. 1566, 1574 (N.D.Ill.1996) ("An affidavit that does not set forth the facts and reasoning used in making a conclusion amounts to nothing more than a denial of the adverse party's pleading.”); E.T. Barwick Indus. v. Walter Heller & Co., 692 F.Supp. 1331, 1347 (N.D.Ga. 1987) ("Theoretical speculations, unsupported assumptions, and conclusory allegations advanced by an expert ... are [not] entitled to any weight when raised in opposition to a motion for summary judgment.”) (citations omitted), aff'd, 891 F.2d 906 (11th Cir.1989).
. 671 So.2d 888 (Fla.Dist.Ct.App.1996).
. Montgomery notes in his brief that one of the supervisors testified that a track worker with only manual equipment would be expected to tighten only 24 bolts during a normal workday.
. See Hall v. Fedor, 349 S.C. 169, 175, 561 S.E.2d 654, 657 (Ct.App. 2002) (holding hearsay evidence presented in response to summary judgment motion did not create a genuine issue of material fact because ”[o]ur appellate courts have interpreted Rule 56(e) to mean materials used to support or refute a motion for summary judgment must be admissible in evidence”).
. Chicago & N.W. Ry. v. Bower, 241 U.S. 470, 473-74, 36 S.Ct. 624, 60 L.Ed. 1107(1916).
. See McKennon, 897 F.Supp. at 1027 ("Under FELA, the proper inquiry is whether the method prescribed by the employer was reasonably safe, not whether the employer could have employed a safer alternative method for performing the task.”).
. See Mayhew v. Bell S.S. Co., 917 F.2d 961, 963 (6th Cir.1990) (stating that although “relaxed standards applied in FELA and Jones Act suits" do not require a medical expert “to articulate to a ‘reasonable degree of medical certainty,’ ... a medical expert must be able to articulate that it is likely that the defendant’s negligence, or more than possible that the defendant's negligence, had a causal relationship with the injury and disability for which the plaintiff seeks damages”); Moody v. Me. Cent. R.R. Co., 823 F.2d 693, 695 (1st Cir.1987) ("[Ajlthough a plaintiff need not make a showing that the employer's negligence was the sole cause, there must be a sufficient showing (i.e., more than a possibility) that a causal relation existed.”); Collier v. Varco-Pruden Bldgs., 911 F.Supp. 189, 192 (D.S.C.1995) (finding an expert’s affidavit "amount[ed] to nothing more than his speculation as to what ‘most likely' happened, and has no support in the record”).
. 323 U.S. 600, 65 S.Ct. 545, 89 L.Ed. 490 (1945).
. Id. at 604, 65 S.Ct. 545 (citations omitted).
. Id. at 604-05, 65 S.Ct. 545 (emphasis added).