Can an employer recover damages from an employee for failing to provide a safe workplace?

[This] result turns really not upon any question of 'proximate cause,' 'assumption of risk' or 'contributory negligence,' but rather upon the employer's independent right to recover against the employee for the non-performance of a duty resulting in damage to the employer, which in effect offsets the employee's right to recover against the employer for failure to provide a safe place to work.

Dixon v. United States, 219 F.2d 10, 16-17 (2d Cir.1955). In applying the "primary duty" rule,