• The UK Act uses the phrase ‘so far as is reasonably practicable’ and Occupational Safety
and Health Act 1994 uses the words ‘so far as is practicable’. In Occupational Safety and
Health Act 1994 the word ‘reasonable’ is not included. The issue arises on whether both
sentences have the same meaning. The meaning of these sentences has been decided in
the case of Marshall v. Gotham Co. Ltd [1954] AC 360 (pg71)(see Appendix).