Consolidated statement of claim re: Sunrise Propane explosion

3088.The circumstances of the Sunrise Companies being in the business of storingand supplying large quantities of propane and other industrial gases at a facilitylocated in close proximity to a residential neighbourhood are such that theSunrise Companies were under an obligation to be mindful of ihe safety of theplaintiffs and other class members when storing, distributing and supplyingpropane and other industrial gases This is especially true since the SunriseCompanies knew that if any of the propane or gases escaped, causing anexplosion and/or a fire, it was likely to cause damage to the class members'property and personal injury to the class members, including both physical injuryand psychological trauma89There was a sufficient degree of proximity between the plaintiffs and other classmembers and the Sunrise Companies to establish a duty of care because:(a)(b)(c)It was reasonable for the plaintiffs and other class membersto expect that the Sunrise Companies had implementedadequate safeguads to ensure that the storage, supply anddistribution of propane and other gases from the Facility wassafe;The nature of the Sunrise Companies' business, storing,supplying and distributing propane and other gases, had adirect causal connection to the explosions and fire thatcaused the plaintiffs and other class members to sufferdamages;The plaintiffs and other class members were vulnerable toany failure on the part of the Sunrise Companies to ensurethe safety of the Facility, as they had no way of ensuflngsufficient safety measures were taken, and no way ofprotecting themselves if sutficient measures were not taken.