Bartonshill Coal Company V Reid Skidmore V Dartford Gravesham NHS Trust hope this helps

Bob new one from Northern Ireland, not sure if citation is available yet so this is how it was reported on www.safetynews.co.uk Northern Ireland Company and safety adviser fined An employee of Miskelly Brothers Ltd, block makers at Ballygowan, was killed in an industrial accident in September 2009, crushed as he made adjustments to a block strapping machine. Miskelly Brothers Limited pleaded guilty to breaching Article 4(2)(a) and Article 4(2)(c) of the Health and Safety at Work Order 1978 and r.3(1)(a) of the Management of Health and Safety at Work Regulations (NI) 2000 and was fined £50,000. Its safety consultant, engaged to carry out risk assessments on the equipment involved in the incident, pleaded guilty to a breach of Article 34(1) of the Health and Safety at Work Order 1978 and was fined £4,000. An HSE inspector described the accident as preventable. She believed the adjustments to the machine were poorly planned, saying: "This case sends out a clear message to all employers who use health and safety consultants to ensure that they are competent and accredited to undertake the work required. This is the first time in Northern Ireland that a health and safety consultant has been convicted for a breach of health and safety legislation. HSENI wants to send out a strong message that it will not hesitate to pursue through the courts any consultant who fails in his or her duty of care." 13th June 2011

HSE have recently published a quite informative research report (RR877) "Routes to competence in the construction sector. May be of interest. Should be available as free pdf from wwwSite