An employer's non-delegable duty of care does not render the employer strictly liable for casual acts of negligence by employees of third-party contractors on a shared worksite. The employer must have actual or constructive knowledge of an unsafe system of work; mere reliance on a third party to provide warnings of overhead hazards does not constitute delegation of the duty of care. Where the established practice was that the employer would be forewarned of overhead crane lifts, and no prior lifts had occurred over the employer's work area, the employer is not in breach of its duty for failing to anticipate an unforeseeable departure from that practice.
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