Directors, managers and company secretaries can be personally liable for a failure to prepare or to implement a health and safety policy (Armour v Skeen [1977] IRLR 310). The director of roads for Strathclyde Regional Council was successfully prosecuted under s.37(1) (see page 7), on the grounds that the offences committed by the council were attributable to his neglect. He had failed to produce a written safety policy for his department despite the council requiring him to do so. The prosecution arose after a worker fell to his death while repairing a bridge.