Claim No. [insert number]

In the County Court at [insert location]

Between

1. [Insert claimant name]        Claimant

1. and

1. [Insert defendant name]        Defendant

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Particulars of claim

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1. 1. 1

      The Claimant was at all material times employed by the Defendant as a [insert job title] at the Defendant’s [insert premises information] premises.

   1. 2

      At all material times the provisions of the Personal protective equipment at Work Regulations 1992 (“the Equipment Regulations”), the Workplace (Health, Safety and Welfare) Regulations 1992 (“the Workplace Regulations”) and the Control of Substances Hazardous to Health Regulations 2002 applied.

   1. 3

      In the course of his employment the Claimant handled/came into contact with compounds including [insert name of compounds] containing [insert name of salient ingredient]. This caused him injury.

   1. 4

      It is the Claimant’s case that at all relevant times the Defendant had or ought to have had knowledge that in the exposure posed a foreseeable risk of injury and that