The charge alleges he “being self-employed within the meaning of the Health and Safety at Work Act failed to conduct his undertaking, namely as a contractor carrying out sound-prodding work at Pontins Brean Sands in such a way as to ensure so far as reasonably practicable that persons not being his employees and who may be affected thereby, namely members of the public, including Wendy Jones, were not exposed to risks to their health and safety, namely the risk posed by overloaded ductwork in the Fun Factory”.
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