CIVIL LITIGATION & EVIDENCE
UNIT 2 – SCOTT IVERSON INSTRUCTIONS
IN THE MATTER OF:
MR SCOTT IVERSON Proposed Claimant
-and-
AMAZON WOOD GROUP LIMITED Proposed Defendant
___________________________________
INSTRUCTIONS TO COUNSEL
___________________________________
Counsel will find herewith a proof of evidence taken from Mr Scott Iverson, the
proposed Claimant in this matter. Instructing Solicitors have only recently been
instructed by Mr Iverson and are concerned that any claim which Mr Iverson has
against AWG may be statute-barred. A letter has been sent to Mr Iverson’s GP
requesting the release of his medical records and a copy of these will be made
available to Counsel as soon as possible.
Counsel is instructed to advise by telephone as a matter of urgency.
5th September 2023
Berwick and Hardcastle LLP
5 Hungerford Place
Bristol
BS2 9LJ
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I, SCOTT IVERSON, of 19 Westminster Way, Oldbridge, will say as follows,
1. I was born on 21 November 1962 and am currently retired. Until my retirement
on 29 June 2021 I was employed as a woodcutter in AWG’s sawmill on the Old
Bridge North Industrial Estate which is on the outskirts of Oldbridge.
2. I have been employed by AWG (Amazon Wood Group) since 1992. Prior to that
date I was employed as a milkman, but when we moved to the Oldbridge area
in 1992 I was taken on at the sawmill. At first my role was a general
maintenance role, which involved cleaning workshop tools and machinery and
checking that equipment was regularly serviced. The company provided me
with onsite training and, although I do not have any formal qualifications, from
2002 I worked as a woodcutter.
3. There are a number of different woodcutting operations at the mill. By far the
largest is the manufacture of floorboards. AWG also manufactures staircases,
and door and window frames. I have always been involved in the manufacture
of floorboards, and have used both sawing machines and planers.
4. Sawmills are obviously quite dangerous places to work. Everyone knows that
the blades have to be guarded, but even though most of the cutting blades are
enclosed I know a number of men who have suffered quite serious injuries over
the years. I think that AWG have become much stricter about safety
requirements in recent years. About ten years ago they provided everyone with
protective masks and since about 2017 they have pretty much insisted that you
wear your mask. Before that whether I wore a mask depended on what sort of
job I was doing. I tended to wear a mask if I was working on the sawing
machines but not when I was working the planers. I suppose it also depended
on what the weather was like – in summer it could get quite stuffy in the sawmill
and most of us hated wearing masks when it was stuffy.
5. In about 2019 I started to suffer problems with breathlessness. I have never
smoked and when I was a younger man I was a well-regarded sprinter in this
part of the North. However, I injured my left ankle playing football about ten
years ago and as a result I stopped taking much exercise. Since the injury to my
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ankle I have gained weight. To be truthful, at first I thought that my weight gain
was probably causing my breathlessness.
6. But gradually my breathing problems became more severe and I developed a
cough which I couldn’t get rid of. I found that I was becoming breathless if I just
walked up the stairs. I experienced some episodes of extreme breathlessness
at work. I found these episodes quite frightening. My wife made me make an
appointment with my GP and he signed me off work in December 2019. I tried
to return to work in the New Year but the coughing and breathlessness were
much worse if I went into the sawmill. On 14 February 2020 my GP told me that
I was suffering from chronic asthma and that it was possible that this was
brought about by excessive inhalation of sawdust, but that he could not be
certain of this. He said that he would refer me to a specialist.
7. On 24 November 2020 I saw Mr Anderson at the Royal Bridge Infirmary. He is
a specialist in the treatment of pulmonary diseases. He told me that in his view I
have developed Chronic Obstructive Pulmonary Disease (COPD) and he
advised me that sawdust inhalation is the most likely cause of my illness. He
referred me for further tests at the Pulmonary Disease Clinic to confirm his
diagnosis, but he said that he expected them to confirm what he had told me.
By the time I saw Mr Anderson things had got quite a lot worse. I was regularly
having to use the inhaler which the GP had prescribed and being at work in the
sawmill definitely made things worse.
8. My brother-in-law is a shop steward and when I told him what Mr Anderson said
he suggested that I should take legal advice. I saw a solicitor the following
week. My solicitor informed me that it was possible that I might be able to bring
an action against AWG alleging negligence and/or breach of statutory duty
because they didn’t enforce the wearing of masks. That is the first time that
anyone told me that I might have a claim against AWG for my illness. However,
he said that it would be advisable to wait for the results of the further medical
tests before starting an action against AWG. He also said we’d need to get
some tests done to show exactly how the sawdust was affecting my lungs
before we could bring a claim.
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9. By January 2021 I found I could no longer be in the saw mill without suffering
from severe bouts of coughing. It was quite clear to me that my symptoms were
much worse when at work. I stopped going to work at the end of January 2021.
Following a number of meetings with AWG I retired on the grounds of ill-health
in June 2021.
10. I would like to bring proceedings against AWG.
Signed:
Scott Iverson
5 September 2023
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