Victor I recall a similar case some years back where the accused did an RA retrospectively, to cover their own back of course - which backfired as well. To what extent the IP was a 'health and safety ' manager I could not say. On the face of it his action looks rather foolhardy and will no doubt be taken into consideration via contributory negligence if he was to win a claim. As for his omissions, clearly the organisation should have RAs in place, but hands up everyone who does for all reasonably foreseeable risks? Providing a suitable RA may be the responsibility of the h&s manager, however the duty lies with the organisation. At worst the IP could be prosecuted pursuant to s7, but I doubt the HSE will bother.