The standard of care owed by an employer to an employee is that stated in Bankstown Foundry v Braistina — it is 'not a low one' and reflects modern community expectations of accident prevention. The standard applicable to public authorities managing large recreational areas or nature reserves (Nagle, Romeo) is not applicable to the employer-employee relationship and cannot be used to dilute the employer's duty. Where an employer has implemented a precaution after an accident, this is evidence that the precaution was reasonably available before the accident, and the onus is on the employer to establish impracticability.
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