An employer like M&S owes a duty of care to its staff to ensure that they and their collegues are trained properly and any machinery is maintained. In one case an employee was using a scissor lift which was meant for goods only, got his foot trapped and part of his toe had to be amputated. M&S were aware of the use of the lift by staff and it was found that signage and risk assessments were inadequate. They received a substantial fine and the injured worker received over £31,000 for the injury