Consolidated statement of claim re: Sunrise Propane explosion

32(k)They failed to provide necessary facilities, equipment orprocedures to ensure that any explosion or fire at the Facilitywas contained and did not cause damage to the sunoundingproperties, including the properties of the class members;(l) They failed to ensure that an adequate number ofthose emptoyees who did operate the Facility were properlyqualified, properly trained and properly superuised;(m)(n)(o)(p)(q)(r)(s)(t)They failed to ensure that customers accessing the Facilityfor the supply of propane and other gases were properlysupervised;They failed to operate the Facility in reasonably safe andprudent mannenThey failed to monitor or inspect the Facility in a reasonablysafe and prudent mannefiThey failed to comply with Section 14 of the EnvironmentalProtection Act, RS.O 1990 c.E-'19 by discharging orpermitting the discharge of contaminants into the naturalenvironment, causing an adverse affect,They failed to comply with Section 13 of O Reg' 214rc1,regulation to the Technicalsfandards and Safety Act 2040,S.O 2000 c,16, as they failed to ensure the safe operatingcondition of equipment used in the handling of a compressedgas, specifi cally proPane;They perpetuated a culture of lack of safety at the Facility;They failed to respond in an adequate and timely manner tothe explosions and fire.They breached the Occupier's Liability Act, R.S.O. 1990'c.,O-Z as pa rticu I anzed below,91. The Sunrise Companies are also occupiers within the meaning of the OccupiefsLiabiility Acf, R S.O. 1990, c. A-2, and owe a duty of care to the plaintiffs and