This approach was followed in McGhee v National Coal Board [1973] 1 WLR 1 (HL) where the plaintiff had contracted dermatitis as a result of exposure to brick dust. The plaintiff worked with brick dust during his working hours and there was no breach in relation to this exposure (i.e. it was non-tortious). His employers, however, were in breach of duty for failing to provide washing facilities for him to wash the brick dust off his skin at the end of the working day. As a result the brick dust was on his skin for an extended amount of time including his cycle journey home. Again, the plaintiff would not have contracted dermatitis but for the exposure to brick dust. The medical experts could not state with certainty whether the dermatitis was caused by the exposure during the working day (non-tortious) or through the extended time that the dust remained on his skin (tortious). The House of Lords again imposed liability on the defendant on the basis that their breach had materially increased the risk of the claimant’s injury. It seems that despite a difference in terminology there is no practical difference between materially contributing to the risk and materially increasing the risk in that case.