legal watch - health & safety - issue 3
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Legal Watch:Health & SafetyAugust 2014
Issue: 003
In This Issue:
• Introduction
• Health & Safety at Work Act over 40 years
• Greenwoods and Plexus Law successes
• Round-up of cases dealt with
• Round-up of other developments
• Round-up of significant fines over the last
three months
• The combining of the resources of Plexus and
Greenwoods’ Health and Safety teams
IntroductionWhere to now for health and safety in the light of the amendment
to the Health & Safety at Work Act brought about by section
69 of the Enterprise and Reform Act in October 2013? It is still
too early to analyse the full effects of this clause and whether
it has stopped the march of the “health and safety gone mad”
brigade.
Health and safety remains of critical importance to any
business – ensuring that there is a responsible approach to safe
working practices. Nevertheless, there is a lingering concern
that health and safety requirements have been transposed
from the work environment to volunteer activity and there is
perhaps a real question mark as to what extent health and
safety laws apply/should apply to activities undertaken in the
spare time, or voluntarily.
03
Health & Safety at Work Act over 40 years
The Health and Safety at Work etc. Act 1974 – 40 years onThis is a summary of an article previously published in the
Solicitors Journal.
At aged 40 the Health and Safety at Work etc. Act 1974
(HSWA) remains the cornerstone of UK health and safety
regulation, despite the rapid development of new industries
and spectacular advances in technology.
Historically, health and safety regulation in Britain had
been prescriptive and industry-specific. Inconsistencies
developed, there was no requirement for employee
participation and some industries escaped regulation
altogether. By the 1960s, the need for a new approach to
tackle fundamental issues of workplace safety had been
recognised by trade unions and government.
HSWA provides general principles for the management of
health and safety at work. Its provisions and the duties it
creates for employers and others are less prescriptive than
preceding legislation. They are more goal-based, adopting
principles of self-regulation by industry.
Employers must ensure, so far as is reasonably practicable,
the health and safety of employees and others, including
the general public, who may be affected by work being
carried out. The provisions are widely drafted and capture
employers throughout industry and commerce.
HSWA also enables the creation of further regulations
dealing with specific areas of work and risk. This has become
the principal means for compliance with the European
Health and Safety Framework Directive 89/391 EEC. The
Framework Directive resulted in the creation of the so-called
“six pack” of regulations, which impose strict duties upon
employers concerning the use and maintenance of work
equipment, manual handling and the assessment of risks
associated with work.
HSWA also created the Health and Safety Executive
(HSE) and the Health and Safety Commission, to oversee
and enforce health and safety in the UK. These bodies
merged in 2008. The HSE continues to enforce HSWA and
its regulations. The HSE issues Codes of Practice, which
provide industry guidance on compliance with specific
regulations and compiles statistics recording, amongst
other things, the number of fatalities, injuries and dangerous
occurrences reported by duty holders annually.
HSWA has been the subject of significant legal argument in
the Higher Courts, hardly surprising considering its broad,
goal-based approach and a non-prescriptive model of
regulation.
The general duties imposed upon employers are not
strict. They are qualified by a reasonable practicability test
determined by factors, including the nature and extent of
the risk. Once the prosecution has established, beyond
a reasonable doubt, that an employee or non-employee
has been exposed to risk, the burden of proof shifts to the
defendant to establish that, on the balance of probability, it
has taken all reasonably practical steps to control that risk
(section 40). In Davies v HSE 2002, the Court of Appeal held
that the requirement to prove all reasonably practical steps
had been taken and the reversal of the burden of proof were
compliant with ECHR Article 6(2) and did not interfere with
the presumption of innocence. The Court of Appeal noted
that the reverse burden applied to regulatory offences and
not criminal offences punishable by imprisonment.
The European Commission challenged the reasonable
practicability qualification, arguing it was not compatible
with its Framework Directive, which allows member states
to incorporate a defence where an occurrence was due to
unusual and unforeseen circumstances beyond the control
of an employer. The European Court of Justice found that
the provisions of HSWA and, specifically, the reasonable
practicability qualification did comply with the directive
(Commission v UK 2007 – Case C127/05).
04
Today government is focussed on deregulation and reducing
burdens upon business. Following several reports, including
those of Lord Young and Professor Löfsted, and the
launch of its own red tape challenge, the government has
committed to streamlining the health and safety framework.
Nonetheless, HSWA has escaped serious censure and is
still considered fit for purpose. Its underlying principle, that
those who create risks from work activity are best placed
to protect employees and the public, is still considered
relevant.
HSWA has been used to prosecute duty holders in
circumstances probably originally unforeseen by parliament.
Increasingly it is used to prosecute following accidents that
occur outside traditional workplaces involving the general
public. The HSE now investigates and prosecutes those
supplying and operating leisure activities to the public in the
event of accidents.
The police and emergency services are also coming under
increasing scrutiny. The Metropolitan Police was prosecuted
for health and safety offences under section 3 following the
shooting of John Charles De Menezes in 2005. The Greater
Manchester Police, through its Chief Constable, is currently
being prosecuted for the same offence following the
shooting of Anthony Grainger in 2012. Both prosecutions
were brought by the CPS rather than the HSE, a further
departure from longstanding practice.
The very generality of HSWA’s provisions and its non-
prescriptive nature have allowed it to remain relevant today
despite a very different social and working landscape from
that in 1974. There is no reason why it should not remain the
mainstay of health and safety regulation for the foreseeable
future.
For further details contact:
Peter James
E: peter.james@plexuslaw.co.uk
T: 0844 245 5319
Leisure and the Health & Safety At Work, etc Act 1974The Health & Safety Executive has recently launched a
campaign to highlight the extent to which health & safety law
applies to volunteer organisations, such as sports clubs and
other similar unincorporated associations. This includes a
section of the HSE website dedicated to health and safety in
leisure activities. It does not provide information on activities
covered by The Adventure Activities Licensing Authority
but it is otherwise wide ranging and includes swimming,
organised sporting activities, leisure centres, countryside
visits, children’s play and motorised leisure pursuits, as well
as adventurous, thrill-seeking activities like bungee jumping.
The site makes it clear that while health and safety law does
not, generally, impose duties upon someone who is not an
employer, self-employed or an employee, anyone (including
volunteers) with control of non-domestic premises like a
school or community hall has legal responsibilities to make
the premises and any equipment or substances provided
for their use there, safe, so far as is ‘reasonably practicable’.
However, in our view it is not as simple as that and it may
depend on whether there is any work activity taking place
and the extent of the club’s undertaking.
As a number of recent cases have shown, the courts are
drawing a clear distinction between unsafe premises and
equipment; potentially dangerous activity where there is a
degree of organisation and compulsion to participate; and
those cases where the injured party uses safe premises or
equipment on an entirely voluntary basis.
Cases where the premises or equipment are inherently
unsafe speak for themselves but the other two concepts
can best be illustrated.
In Uren (2013) the claimant was taking part in a ‘fun day’
organised by the RAF. The court found that a competent
risk assessment would have concluded that a game, which
involved competitors getting in and out of a shallow pool,
carried a risk of serious injury which could not be justified
in the light of the social value of the game. The organisers
should have banned head-first entry to the pool which would
05
have prevented the claimant’s injury. Crucially however, the
claim was pursued against the claimant’s employer and
therefore there was a work connection.
In Wilson (2013) the failure of an instructor at an adventure
activity centre properly to explain or demonstrate the
technique for negotiating part of an obstacle course, as
required by the centre’s own risk assessment procedure
and instructor training notes, constituted a breach of duty
of care which was causative of an accident suffered by the
claimant. The claimant was a scout leader who no doubt felt
that he should set an example to his troop by attempting
the course.
However, in Risk (2013), Cockbill (2013) and Grimes (2011)
where the claimants were all injured as the result of diving
into a swimming pool or paddling pools, it was found that
their acts had been entirely voluntary and the hosts of the
events they were attending had no liability. The pools as
such were entirely safe and the claimants were under no
pressure or compulsion to act as they did.
Plexus Law represented the defendant in Risk. At an annual
event run by the student union on the defendant’s land, the
21-year-old claimant had run and dived head-first into a
small inflatable pool. He seriously injured his neck and was
now tetraplegic.
He submitted that the defendant owed a duty of care to
take appropriate steps to prevent him from injuring himself,
which arose as a result of (1) the particular circumstances
and the relationship between a college and its students; (2)
alternatively, the defendant’s assumption of responsibility
in the particular circumstances, including knowledge of the
risks it had acquired from previous years.
Dismissing the claim, the High Court judge held that
although the defendant accepted it owed the claimant a
general duty of care under S2(2) Occupiers’ Liability Act
1957, the question was whether it owed a particular duty
to protect him from the risk he had taken. The issue was
not as to the existence of a duty but its particular scope. A
duty to protect against obvious risks or self-inflicted harm
existed only in cases in which the potential victim had no
genuine and informed choice or lacked capacity. In the
absence of some particular assumption of responsibility,
where the victim was of full age and capacity, was not under
the protective wing of an occupier with control over what
he might do, and had a genuine and informed choice, the
occupier had no duty to protect him from an obvious risk
which he created himself. Tomlinson v Congleton BC (2003)
was cited. By acting as he did, the claimant had created
an obvious and serious risk which would not otherwise
have existed. Whether he would have responded to advice
or warnings from the defendant and regardless of whether
there was adequate supervision, he did exercise a genuine
and informed choice at the critical moment.
Assumption of responsibility required an examination of the
responsibility which the defendant did in fact assume, not
what it should have assumed. Knowledge of the risk was
irrelevant to that issue, although it would become a relevant
consideration in relation to the issue of breach. The claimant
fell a long way short of establishing the necessary ingredients
of an assumption of responsibility. What would be required
was evidence of the very matters he denied: namely,
affirmative steps by the defendant to ensure that proper risk
assessments were taken and all relevant control measures
enforced; or, at the very least, affirmative statements and
representations by the defendant that those specific steps
would be taken. Moreover, in such a case an element of
reliance by the claimant was a pre-requisite of a duty of
care arising on that suggested basis and here reliance was
singularly lacking. In the absence of any indication that the
defendant would safeguard the students in any respect, still
less from their own actions in the face of obvious risks, it
should not be found to have assumed responsibility for the
very matters which the law would otherwise have said lay
within the claimant’s personal sphere.
Plexus Law was successful also in Lu v The Royal Russell
Preparatory School Trust (2013). On 30th September 2011
the claimant, a Chinese pupil at the defendant’s school,
was undertaking her third trampolining lesson under the
supervision of a PE teacher when she over rotated whilst
trying to complete a back drop as a result of which her knee
impacted with her face causing serious injury to her vision
06
considered likely to be permanent. The claimant claimed
the trampolining lessons were poorly structured and
inadequately supervised. This was denied and the case was
defended at a liability only trial in the Central London County
Court where the trial judge dismissed the claim and ordered
the claimant and her litigation friend to pay the defendant’s
costs.
Cases such as these may, in the future, be affected by the
provisions of the Social Action Responsibility and Heroism
Bill, should it become law. In particular, the courts will be
directed to ‘have regard to whether the alleged negligence
or breach of statutory duty occurred when the person was
acting for the benefit of society or any of its members’.
If so ‘the court must have regard to whether the person,
in carrying out the activity in the course of which the
alleged negligence or breach of statutory duty occurred,
demonstrated a generally responsible approach towards
protecting the safety or other interests of others.’
The latest guidance from the HSE is not helpful and
continues to blur the lines between when a volunteer club
may be caught by the HSWA and when it may not. Sadly it
is not as simple as saying the Act will apply to certain clubs
but not others. In truth it could depend on the facts of each
case.
Polyflor Ltd v HSE (2014) EWCA Crim 1522The appellant/defendant’s employee had been injured when
his arm had been caught in machinery while he was checking
it. The machinery normally ran with guards attached but,
when it became blocked, the employee obtained a permit
to work to run the machine without guards. Permission was
given and the employee put a spanner in the belt to find the
point where the belt was rubbing. The spanner got caught in
the machinery, he could not let go of it in time and he broke
his arm. A similar accident had occurred at the defendant’s
premises four years earlier. The jury heard evidence from
the employee who accepted that he had been foolish. An
expert for the prosecution gave evidence that “if someone’s
going to do something stupid, you cannot stop them”. The
defendant made a submission of no case to answer on the
basis that the evidence did not support the prosecution’s
case that the accident was caused by its breach of duty and
that the nature of the accident was proof of the existence of
a risk attributable to the system of work. The judge found
that there was a case to answer based on the existence of
risk arising from the unguarded use of the machine.
The defendant appealed submitting that the judge erred in
rejecting the submission of no case to answer as there was
no evidence of a breach of duty by it and the judge used the
wrong test. It argued that a risk would only materialise if an
employee did something very foolish, which this employee
accepted he did, and that was not sufficient.
Rejecting the appeal, the Court of Appeal held that for
the case to go to the jury, the prosecution had only to
adduce some evidence of exposure to risk. Once that was
established the onus shifted to the defendant to show on
the balance of probabilities that it did all that was reasonably
practicable to ensure that its employee was not exposed
to such risk. The prosecution did not have to prove that
a particular accident was foreseeable. Causation was not
an element of an offence under S2(1) Health and Safety at
Work, etc Act 1974. The creation of a material risk by the
carelessness, including gross carelessness, of an employee
remained a material risk for the purpose of the offence.
The defendant’s employees had been exposed to a clear,
obvious and material risk to their health and safety by the
removal of guards on the machinery so that a maintenance
operation could be performed while the machine was still in
operation. Such an activity was permitted by the defendant
under a permit to work system such that there was in place
a system whereby employees were exposed to a clear risk.
That was sufficient for the evidential threshold to be met.
07
Greenwoods and Plexus Law successes
Health & Safety Executive v X.The prosecution arose out of an accident on 11 September
2012. The victim was a special needs pupil at a school
opened by our client (a charity) just six days previously. Our
client had contracted for all the doors on the new premises
to be fitted with hinge guards but the victim trapped his
left index finger in an unguarded hinge and suffered an
amputation. Despite the fact that there were no guards on
the school’s previous premises, no similar accident had
occurred.
Our client pleaded guilty to breach of S3 of the HSWA. In
its plea in mitigation it accepted that an aggravating factor
was the impact of the injury on the young victim, for which a
claim for compensation had already been made.
In mitigation the court was asked to take into account
how recently the school had opened and the fact that
steps had been taken to design out the very risk that had
occurred. However, the building contractors had failed to
complete the works on time, so that the school had become
operational immediately the works were completed and
they and the supervising architect had failed to ensure that
all guards were fitted as stipulated in the building plans.
Following the accident senior figures involved with the
school had immediately become involved and had ensured
that remedial works were carried out.
Credit was also claimed for the prompt guilty please; the
charity’s lack of previous convictions and the impact on its
finances of any financial penalty.
The outcome was a conditional discharge for our client.
In essence although our client was in breach of the Act
the court accepted the mitigation that this was a case in
which a responsible dutyholder had been badly let down
by its specialist advisers/contractors and therefore this
was reflected in the sentence of conditional discharge. The
court also had in mind, no doubt, the charitable status of
the defendant and any fine would directly impact on the
valuable services that it provides to the children in it care.
Although a conditional discharge is almost unheard of in
health and safety cases, it is important to keep all options
under review, gauge the “mood” of the sentencing tribunal
and be prepared to be bold in the right case.
08
Round-up of cases dealt with
HSE v HMT and anotherWe were instructed on behalf of HMT who were prosecuted
by the HSE under Section 3(1) of the Health & Safety at Work
etc Act 1974 following the death of an elderly resident who
suffered from dementia whilst in their care. Whilst building
works were being undertaken at the care home the elderly
resident wandered into one of the rooms into which the works
were being undertaken. A fire door had been removed and
left leant against a wall. Unfortunately the resident pulled it
on top of her and sustained a broken hip. She died a month
later. A guilty plea was entered at the first opportunity but
submissions to the magistrates for the matter to remain in
the Magistrates’ Court failed and the matter was referred to
the Crown Court for sentence. Ultimately a fine of £20,000
was imposed after detailed written submissions had been
made in mitigation.
HSE v JMWe acted for the defendant who was prosecuted under
Section 3(1)(a) of the Management of Health & Safety at
Work Regulations 1999 for failing to make a suitable and
sufficient assessment of the risks to the health and safety of
his employees and under Regulation 17(1) of the Workplace
(Health, Safety & Welfare) Regulations 1992 in failing to
organise the workplace in such a way that pedestrians and
vehicles could circuit in a safe manner.
The prosecution was brought following the death of one of
the defendant’s employees when he was struck by a vehicle
in the defendant’s yard.
A fine of £20,000 was imposed in respect of each offence.
The magistrates retained jurisdiction.
09
Round-up of other developmentsThere are a number of ongoing consultations but the most
relevant to health and safety generally relates to proposals
to exempt self-employed persons from S3(2) HASWA
except those undertaking activities on a prescribed list.
The proposal stems from a recommendation made by
Professor Löfstedt in his report ‘Reclaiming health and
safety for all: an independent review of health and safety
legislation.’
010
Round-up of significant fines over the last three monthsMay 2014
Stonyhurst College
Breach/Circumstances: A historic private school in Clitheroe
has been fined £100,000 over health and safety failings after
one of its stonemasons developed a potentially fatal lung
disease.
Stonyhurst pleaded guilty to a breach of the Health and
Safety at Work etc Act 1974 by failing to ensure the health
and safety of its employees.
Plea: Guilty.
Sentence: Fined £100,000 and ordered to pay £31,547.78 in
prosecution costs.
Angus Group Ltd , Scotland
Breach/Circumstances: A specialist asbestos removal
company has been fined after it exposed workers to
dangerous fibres during demolition of a former school
building.
Angus Group Ltd was found guilty of eight breaches of the
Control of Asbestos Regulations 2006.
Sentence: Fined a total of £109,000 and ordered to pay a
further £42,100 in costs.
Habitat Construction LLP
Breach/Circumstances: A Southwark construction company
has been ordered to pay more than £126,000 in fines and
costs after a worker was left paralysed from the waist down
when he fell eight metres from an unguarded window space
into a basement.
Habitat Construction LLP pleaded guilty to breaching
Section 2(1) of the Health and Safety at Work etc Act 1974.
Plea: Guilty.
Sentence: Fined £110,000 and ordered to pay £16,620 in
costs.
Refresco Gerber UK Ltd
Breach/Circumstances: An international smoothie and fruit
juice company has been sentenced for safety failings after
an engineer was killed by falling pipework during work to
decommission a former factory in South Wales.
Refresco Gerber UK Ltd pleaded guilty to a breach of
Section 2(1) of the Health and Safety at Work &c. Act 1974.
Plea: Guilty.
Sentence: Fined £80,000 and ordered to pay £75,000 costs.
AAK UK Ltd
Breach/Circumstances: A sauces manufacturer has been
fined £140,000 after a forklift truck driver was killed at a
factory in Runcorn.
Michael Moran was using his forklift truck to load a lorry
trailer outside the factory on the Astmoor Industrial Estate
on 18 April 2011 when another lorry reversed into the side
of his vehicle. The forklift overturned, killing him instantly.
Company pleaded guilty to a breach of the Health and
Safety at Work etc Act 1974.
Plea: Guilty.
Sentence: Fined £140,000 and ordered to pay £22,657 in
prosecution costs.
011
Kemble Air Services Ltd
Breach/Circumstances: Kemble Air Services Ltd, the
operator of Cotswold Airfield, has been fined for safety
failings after an experienced fire-fighter was killed while
moving a pressurised gas cylinder. Mr Mills was attempting
to move a large freestanding cylinder weighing 65kg when
the gas in the cylinder discharged very rapidly. This caused
the cylinder to spin round violently striking Mr Mills on his
head and body leaving him with fatal injuries.
Kemble Air Services Ltd, of Cotswold Airfield, Kemble Nr
Cirencester was found guilty of two breaches of Regulation
3(1) of the management of Health and Safety at Work
Regulations 1999.
Sentence: Fined £75,000 and ordered to pay £98,000 in
costs.
T Lea Sherwin Ltd
Breach/Circumstances: A farming company in Middlewich
has been fined £50,000 after a father-of-one suffered fatal
injuries when a 1.5 tonne concrete panel fell on him.
The court was told the firm failed to carry out a proper
assessment of the risks, or to make sure a safe system of
work was in place. As they lifted the panel, which was six
by one metres in diameter, the bolts attached to the lifting
chains snapped and the panel fell onto Mr Bennett.
T Lea Sherwin Ltd, pleaded guilty to a breach of the Health
and Safety at Work etc Act 1974 on 12 May 2014.
Plea: Guilty.
Sentence: Fined £50,000 and ordered to pay £28,585 in
prosecution costs.
April 2014
Castlebeck Care (Teesdale) Ltd
Breach/Circumstances: Care provider Castlebeck Care
(Teesdale) Ltd has been fined £100,000 after a patient died
while being restrained using an unauthorised technique at a
Nottinghamshire mental health hospital.
Castlebeck Care (Teesdale) Ltd, now in administration was
found guilty of breaching Sections 2(1) and 3(1) of the Health
and Safety at Work etc Act 1974.
Sentence: Fined £100,000.
Mid Staffordshire NHS Foundation Trust
Breach/Circumstances: A vulnerable diabetic patient died
because a hospital trust failed to implement basic handover
procedures and ensure essential record-keeping, a court
has heard.
Mid Staffordshire NHS Foundation Trust was prosecuted by
HSE and pleaded guilty to an offence under the Health and
Safety at Work etc Act at Stafford Crown Court.
Plea: Guilty.
Sentence: Fined £200,000 and ordered to pay £27,049
costs.
March 2014
Gaspack Services Ltd
Breach/Circumstances: A worker filling gas cylinders had
his leg severed below the knee when a faulty cylinder he was
filling exploded at Guardian Gas Ltd, Brynmenyn Industrial
Estate, Bridgend.
HSE’s investigation found the failed cylinder was one of a
batch of cylinders which Guardian Gas had sent to Gaspack,
a certified cylinder inspection body, for inspection, testing
and certification to prove their safety for a further 10 years.
The cylinders had been returned to Guardian Gas certified
as safe to use.
012
Gaspack Services Ltd of Gellihirion Industrial Estate,
Pontypridd, pleaded guilty to a breach of Section 3(1) of the
Health and Safety at Work Act 1974.
Plea: Guilty
Sentence: Fined £30,000 and ordered to pay £60,000 in
costs.
Roberts-Gordon Europe Ltd
Breach/Circumstances: A Wednesbury-based heating,
ventilation and air conditioning manufacturer has been fined
£150,000 after a worker was crushed to death while working
in its warehouse.
Ronald Meese, 58, of Bilston, a production supervisor for
Roberts-Gordon Europe Ltd, had been stacking three-
metre-long metal tubes in the warehouse in Darlaston Road,
Wednesbury, when the incident happened on 27 July 2011.
With the aid of a forklift truck, he had created several stacks,
but as he left his cab to set down timber pieces for the next
bundle of tubes to rest on, one of the stacks, weighing a
tonne, collapsed onto him. Paramedics were called but Mr
Meese was pronounced dead at the scene.
Roberts-Gordon Europe Ltd, of Kings Hill Business Park
pleaded guilty to breaching Section 2(1) of the Health and
Safety at Work etc Act 1974.
Plea: Guilty.
Sentence: Fined £200,000 and ordered to pay £27,049
costs.
EMC Contracts Ltd
Faraday Court in Fulwood
Breach/Circumstances: A Preston-based building firm has
been fined £130,000 over the death of a worker outside a
cinema in Ashton-on-Ribble.
The Health and Safety Executive (HSE) prosecuted EMC
Contracts Ltd after father-of-one Carl Green was struck by
a reversing van in a paved area outside the entrance to the
Odeon Cinema on 27 July 2010.
The 45-year-old painter from Chorley had been working on
a project to fit out a new coffee shop in the cinema when
the incident happened. He died from his injuries on the way
to hospital.
EMC Contracts Ltd, which has been put into voluntary
liquidation, was found guilty of two breaches of the Health
and Safety at Work etc Act 1974. The company, of Faraday
Court in Fulwood, was fined.
Sentence: Faraday fined £130,000 and ordered to pay
£52,790 in prosecution costs.
The information and opinions contained in this document are not intended to be a comprehensive study, nor to provide legal advice, and should not be relied on or treated as a substitute for specific advice concerning individual situations. This document speaks as of its date and does not reflect any changes in law or practice after that date. Plexus Law and Greenwoods Solicitors are trading names of Parabis Law LLP, a Limited Liability Partnership incorporated in England & Wales. Reg No: OC315763. Registered office: 8 Bedford Park, Croydon, Surrey CR0 2AP. Parabis Law LLP is authorised and regulated by the SRA.
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Contact UsFor more information please contact:
Peter James, Partner
T: 0844 245 5319
E: peter.james@plexuslaw.co.uk
Philip Tracey, Partner
T: 0207 079 4658
E: pbt@greenwoods-solicitors.com
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T: 0844 693 5648
E: anthony.bushell@plexus-law.co.uk
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