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Court of Appeal underlines distinction between risk assessment and risk reduction

The Court of Appeal decision in Egan v Central Manchester and Manchester Children's University Hospitals NHS Trust [2008] EWCA (Civ) 1424 drew attention to the distinction - in the context of the 1992 manual handling Regulations - between an employer's duty to carry out a health and safety risk assessment and the separate requirement that risks be reduced to the lowest level reasonably practicable, irrespective of whether a risk assessment has been carried out.