Evident signs of distress or vulnerability are not a precondition for establishing that psychiatric injury is reasonably foreseeable; they are one means by which foreseeability may be established. Koehler and Kozarov represent opposite ends of a single spectrum, not a divergence in principle. An employer contemplating a change to work practices that increases workload must consider the risk of psychiatric injury even absent individual complaints, particularly where the nature of the work involves physical risks and there are general warnings about the impact of the change. However, where the risk arises from an incremental increase in workload that is not inherently dangerous, and the employer offers reasonable alternative measures to address the risk, the employer may discharge its duty even if the employee rejects those measures.
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