Examines the consequences of a the case Six Continents Ltd vs Carford Catering. Here, Carford, (a firm of project managers) had been employed to manage the design and installation of kitchen equipment. A fire later occurred at the restaurant and the owners sued Carford for losses caused by the fire as the manufacturing instructions made it clear that under no circumstances should a unit be fitted directly onto a heat sensitive surface. Carford responded by arguing that during an inspection its engineer had made a constructive recommendation in a warning letter that may have prevented the fire. In the CA the judge noted that it was very difficult to see how such a letter could rescue Carford as their contract required them to take steps to prevent fire not simply to warn about its risks. The CA approach was influenced by Fairchild vs Glenhaven Funeral services Ltd ([2002] UKHL 22, Abs 65719) where a worker had contracted an industrial disease through inhaling asbestos dust and the HL had concluded that both the employers were liable allowing the client to receive damages