An employer's duty of care in relation to manual handling work must be assessed holistically rather than by breaking it into separate components (risk assessment, system of work, training). An employer cannot assume that correct manual handling techniques are common knowledge in the absence of evidence that the worker has undergone relevant instruction. Where a course of allegedly tortious conduct continues over a period of time with a single defendant, the plaintiff may establish a single injury for the purposes of the Workers Compensation Act thresholds, whether or not separate causes of action were pleaded.
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