Breach of an employer's duty of care in manual handling cases must be assessed prospectively by reference to the system of work (including the heaviest loads employees may be required to lift), not retrospectively by reference to the particular load lifted on the occasion of injury. However, an employee must adduce expert evidence establishing that the system of work posed a real risk of injury; qualitative statements about the dangers of lifting and twisting do not suffice where quantitative analysis suggests the loads were within safe limits. In single-incident lifting cases, causation may independently fail where the only precaution that would have prevented the injury was prohibiting all lifting.
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