The scope of an employer's non-delegable duty of care does not extend to the state of premises, plant or equipment of a third party where the employer had no opportunity to inspect the premises, no knowledge of the danger, and no capacity to shield the employee. A direction by a third party's employee to use particular equipment is a casual act of negligence, not part of a system of work, and does not engage the employer's non-delegable duty. General safety training will not establish causation where the specific risk was not foreseeable and the employee could not have detected the defect prior to the accident.
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