Defence by an employer denying liability for their employee developing hand-arm vibration syndrome
Produced in partnership with Tom Pacey of 12KBW

The following PI & Clinical Negligence precedent produced in partnership with Tom Pacey of 12KBW provides comprehensive and up to date legal information covering:

  • Defence by an employer denying liability for their employee developing hand-arm vibration syndrome

Defence by an employer denying liability for their employee developing hand-arm vibration syndrome

IN THE COUNTY COURT AT [INSERT LOCATION]CLAIM NO. [INSERT NUMBER]

Between

  1. X Y        Claimant

  1. - and -

  1. A B        Defendant

    1. 1

      It is admitted that the Claimant started working for the Defendant as a [insert job title] on [insert date].

    1. 2

      On [insert date] the Claimant was issued with the Defendant’s Codes of Safe Working Practice which included working with various items of machinery. The content and purpose of the Codes was explained to him.

    1. 3

      On [insert date] the Claimant was given the Defendant’s Guide to Hand-Arm Vibration Syndrome. It contained written advice on the cause, identification, prevention and treatment of HAVS.

    1. 4

      Hand/arm vibration syndrome became well known by the end of the 1970s. The Claimant was well aware from the time he was given the above Guide of the risks of hand/arm vibration syndrome from the use of any vibrating tools in his work and what he should do in the event that he developed any symptoms.

    1. 5

      On [insert date] the Claimant completed a Health Surveillance Questionnaire. He reported blanching of his index fingers in winter [insert year] and tingling in his index fingers while working which he had noticed for a period of [insert time period].

    1. 6

      The medical evidence shows [give details of specific expert report(s)] that

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