A lesson the Hampshire Constabulary found out the hard way:
Chief Constable of the Hampshire Police v Taylor, 
EWCA Civ 496. Police Constable Taylor was engaged in dismantling a
grow op, and had been issued a pair of latex gloves for the
purpose. The house in question was poorly ventilated and PC Taylor
felt 'nauseous as a result of the unpleasant smell of
cannabis' which pervaded it (not a universal reaction, that;
although too much of anything may be unpleasant). She pushed at a
window to let in some air, not realising that the occupants of the
house had sealed all the windows. She broke the glass and received
a cut on her thumb from the breaking pane. PC Taylor sued her
employer, the Hampshire Constabulary, for failing to provide gloves
that were thick enough to prevent her injury. The police countered
with the argument that uprooting cannabis plants wasn't likely
to require anything thicker, as there are no sharp edges on a
The trial judge found for the police officer, awarding damages
of just under ₤5,000. The Constabulary was in breach of
regulations related to personal protective equipment in the
workplace, which required the employer to provide suitable
equipment where there is more than minimal risk of injury.
Dismantling a grow op involves more than pulling up plants: there
is ductwork that needs to be removed, which might expose the
dismantler to sharp edges. The risk of injury was not so slight as
to be trivial, even if it was relatively low. The English Court of
Appeal has dismissed the police force's appeal. The employer
had failed to provide equipment necessary to prevent injuries that
might reasonably arise from the range of tasks to be performed in
the course of the activity. It would not be realistic to make a
'fine analysis' of each specific task the worker might
perform and classify them individually as exposing him or her to
pointy things or non-pointy things. The appellant did not raise
remoteness of damage or argue that the regs simply didn't apply
to the activities in question: 'potentially interesting
questions' but about which there was nothing to say on the
appeal as argued.
Unfortunately, reasonable accommodation for employees in the workplace continues to be the source of significant litigation and even today we continue to see outrageous examples of employers behaving badly.
We are now beginning to see reported cases involving charges and subsequent fines laid against employers for failing to provide information, instruction and supervision to protect a worker from workplace violence.
On October 13, 2016, the Supreme Court of Canada denied leave to appeal an Ontario Court of Appeal decision which ordered an employer to pay a former employee 37 months of salary and benefits following termination.
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