Allison v London Underground Ltd [2008] EWCA Civ 71, [2008] All ER (D) 185 (Feb)
The test for the adequacy of training for the purposes of health and safety (under reg 9 of the Provision and Use of Work Equipment Regulations 1998 (SI 1998/2306)) is what training was needed in the light of what the employer ought to have known about the risks arising from the activities of his business.
To say that the training is adequate if it deals only with the risks which the employer knows about is to impose no greater a duty than exists at common law.
The statutory duty is higher and imposes on the employer a duty to investigate the risks inherent in his operations, taking professional advice where necessary (per Lady Justice Smith at para 55).
