1069 - 1782

A Door Opens Wider

Spencer Franks v Kellogg Brown & Root Ltd 2008 SLT 675

Aberdeen is a fertile place from an agricultural and oil and gas point of view and also as a source of cases for the House of Lords to consider. Following hot on the heels of the Robb v Salamis (2007 SC (HL) 71) case in which an offshore worker fell out of his bunk bed we have the Lords considering the case of Spencer Franks v Kelloggs Brown & Root Limited (2008 SLT 675) which involved a dangerous door closer on an oilrig. The Lords found the operators of the oilrig liable to Mr Spencer Franks and in doing so disapproved of the approach taken by the Court of Appeal in Hammond v Commissioner for Police of the Metropolis (2004 EWCA Civ 830). As many of you may recall the Hammond case suggested that the Provision & Use of Work Equipment Regulations 1998 (PUWER) do not apply to things being worked on but rather to things being worked with, the so called 'tools of the trade' distinction.

Although the Spencer Franks case may be seen as specific to the somewhat unusual nature of oilrigs the Lords in disapproving of Hammond have opened up again the question of the extent to which employers are liable under PUWER for injuries caused to employees by equipment they have not provided. This is a particular concern because a number of the PUWER Regulations are strict liability.

Mr Spencer Franks was sent by his employers to an oilrig where he was asked to repair a door closer. He suffered facial injuries when the door closer sprang back suddenly whilst he was working on it. A case was brought against both his employers and the operators of the oilrig under PUWER. It was argued on behalf of Mr Spencer Franks that the door closer was work equipment, that it was not fit for purpose and that as a result both his employers and the operators of the rig were strictly liable.

The case was initially heard at Aberdeen Sheriff Court where the sheriff dismissed it insofar as it related to Mr Spencer Franks' employers on the basis that they had not "provided" the door closer for his use in terms of Regulation 3. He however allowed the case against the rig operators to proceed as he felt they had control over the door closer in terms of the Regulations.

Both sides appealed to the Court of Session and the Judges in the Inner House, following Hammond, dismissed the case in its entirety on the basis that the door closer could not be work equipment as it was the item being worked on rather than a 'tool of the trade' .

Mr Spencer Franks appealed further to the House of Lords who found unanimously in his favour. Although the Lords took fairly individual approaches to the case broadly speaking they seem to accept that the tools of the trade restriction applied in the Hammond case is an artificial one. The suggestion from Hammond that the van in question could be tools of the trade for the dog handler who drove it but not for the mechanic employed by the Metropolitan Police who repaired it did not appeal to the Lords. Their view was that if something fulfilled the definition of work equipment it was work equipment for all. They suggested that the starting point was to ask what is the piece of equipment actually used for? If it was used for work then it was work equipment.

In the Spencer Franks' case the Lords had no difficulty in accepting that the door was work equipment as it was the only means of access/egress to the oilrig's control room. The fact that the door closer was attached to the door didn't seem to the Lords as any reason for it not also to be seen as work equipment. Having unanimously held that the door closer was work equipment the Lords had no difficulty in finding the operators of the oilrig had control over it and therefore in terms of Regulation 3 were strictly liable to Mr Spencer Franks.

Unfortunately they did not have to consider the more difficult question of whether Mr Spencer Franks' employers would have been liable under PUWER because by the operation of an indemnity if the operators of the rig were liable the employers would have to pick up the tab.

The Lords recognised that by disapproving of Hammond they were opening up the question of the application of the Regulations again and Lord Rodger gave perhaps the most consideration to the possible implications for employers. Lord Rodger recognised that the definition of work equipment was wide and asked whether there were any restrictions elsewhere in the Regulations. He looked at Regulation 3 and the terms in relation to employers of equipment provided for use or used by employees at work. He recognised that this could apply to pretty much anything an employee touched during the working day whether provided by his employer or not. Appreciating this would be a cause for concern he suggested that a way forwards might be to ask the question of 'whether the piece of equipment performed a useful, practical function in relation to the purpose of the undertaking.'

Lord Rodger's approach also found favour with Lord Mance but he, along with the other Lords accepted that 'the difficult exercise of identifying the outer parameters of these Regulations application requires further thought and more detailed submissions on another occasion.'

We will be looking for the next decision on this matter which we hope will come quickly and will clarify what is a complex question.

To illustrate the problem with the interpretation of the Regulations at present consider the following scenario. If James Bond had a puncture whilst driving his original Aston Martin and took it to the local garage for repair, would the garage operator be liable under PUWER if a mechanic cut his hand on the diamond tipped spinners inserted in the wheels? If the courts take a literal interpretation of the term "use" from PUWER then the answer might be yes. Alternatively if Lord Rodger's suggestion of a limitation based upon whether the item performs a useful practical function in relation to the purpose of the undertaking's business then the answer would probably be no.

Although the decision in Spencer Franks is clearly important it is perhaps a situation of one step forward and two steps back.

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