Did Coles fail to take precautions against a risk of harm which a reasonable person in its position would have taken?
- There was no expert evidence called by either side to establish any accepted level of observance and cleaning in the fresh produce section of a busy supermarket.
- The question for consideration is whether, on the facts which I have found, would a reasonable person in the position of Coles have taken precautions beyond those actually taken? : Jackson v McDonald's Australia Limited [2014] NSWCA 162 at [89].
- It is not realistic to expect that every piece of vegetable matter which falls on the floor of a supermarket will be picked up instantly. Coles is not bound to ensure the absolute safety of entrants to its stores. It must take reasonable care.
- In the past such cases often turned upon whether or not a designated cleaner was checking and cleaning the floor at regular intervals - every 15 or 20 minutes was often held to be reasonable. See for example the apparent assumption to that effect made in Strong v Woolworths Limited [2012] HCA 5; (2012) 246 CLR 182 at [14], [36], [38].
- Coles put non-slip mats on the floor in the high risk areas - where grapes, lettuce, herb leaves and broccoli were displayed for sale in the long wall case area. That was reasonable care in those high risk areas. The Coles employees conceded that even strict observance of "Clean As You Go" policy would not have been sufficient in those areas; thus the mats were deployed.
- The grapes upon which the plaintiff slipped must have been dropped by a customer onto the floor in an area not covered by non-slip mats. That was not an unknown occurrence, but it was not a risk which was created constantly, like the risk created in the matted areas.
- Coles could not have been expected to ensure safety by, for example, having several staff in every aisle doing nothing but watching for dropped vegetable matter, or by allocating a staff member to "shadow" every customer as they walked around the store. Nor did the plaintiff submit that they should.
- Mr Stewart submitted that the Coles was negligent in that its cleaning system was "haphazard" and further that it failed in this instance to detect grapes which must have been on the floor for a long time. If that had been my factual finding, then his submission may have been made out.
- Mr Stewart also submitted that the grapes upon which the plaintiff slipped had probably been on the floor for some hours (Transcript 249/20 - 250/10). If I had found that the staff probably didn't follow the Coles "Clean As You Go" regime, that submission may have had some force. However I have found that Mr Batte, Mr Ralevski and Mr Dolce were all well trained and supervised, and personally conscientious.
- On the facts I have found, the plaintiff has failed to persuade me that the grapes were on the floor for quite a while, or that their presence on the floor was not detected by Coles staff for a long time.
- In the present case I have found that the Coles system of cleaning, reinforced by training and supervision, resulted in the floor of the fresh produce area being checked, and if necessary cleaned, at least every 10 minutes. I find that such steps were what a reasonable person in the position of the defendant should have taken. I find that the defendant exercised reasonable care.