An employer's duty of care to employees at foreseeable risk of psychiatric injury from occupational trauma does not extend to actively investigating or monitoring the employee's mental health where the employee is performing well, symptoms are equivocal, and the employee is accessing professional support. However, where an employee has unequivocally expressed inability to cope with trauma exposure, transferring that employee to a role inevitably involving further trauma exposure constitutes a breach of duty. Training, peer support and rotation policies are reasonable steps but their absence is not causative of injury where the employee would not have sought or been offered rotation in any event. Counterfactual findings about what would have occurred had an employer taken certain steps are evaluative assessments, not primary findings of fact, and are not subject to the heightened standard of appellate deference.
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