An entrepreneur does not owe an employer-like duty to provide a safe system of work to a skilled independent contractor who controls his own work methods, where any co-ordination is rudimentary and performed by the contractor, and there is no evidence that safety equipment would have been refused if requested. The contractor's failure to request safety equipment, combined with expertise sufficient to identify the need for it, negates a finding of vulnerability in the Rockdale Beef sense. The different formulations of the duty in Stevens v Brodribb (Mason J's employer-like duty, Wilson and Dawson JJ's lesser duty, and Brennan J's reasonable care standard) may yield different results depending on the facts.
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