Vacwell Engineering Co v BDH Chemicals Ltd. [1971] 1 QB 88
Law of Tort – Remoteness of Damage – Foreseeability – Property Damage – Duty of Care
Facts
The defendant, BDH Chemicals Ltd, supplied the complainant with chemicals contained in glass ampoules. This had a label stating ‘harmful vapour’ on it. When the scientists were washing off the labels, one of the containers shattered and this caused a violent explosion to occur. It was the chemical coming into contact with water that caused severe damage, including killing one of the scientists, blowing the roof off the laboratory and shattering surrounding walls.
Issues
The issues in this case concerned whether the defendant was liable for unforeseeable damage that was caused by the explosion of the chemicals they had supplied to the complainant.
Held
It was held that the defendant was negligent and failed in their duty of reasonable care, as they did not give sufficient warnings about the chemicals they were marketing to their customers, including the complainant. A label that only said ‘harmful vapour’ was not enough to properly warn of its explosive reaction with water. A manufacturer should maintain a proper system that investigates and researches potential hazards associated with their products before they are sold, in order to inform customers of these hazards. In this case, it does not matter that the damage was more extensive that could be foreseen; only the kind of damage has to be foreseeable. Thus, it was irrelevant to claim that the property damage was unforeseeable and the defendant must be held liable for all damage.
Updated 20 March 2026
This case summary remains accurate as a statement of the law on remoteness of damage in negligence. The principle established in Vacwell Engineering Co v BDH Chemicals Ltd [1971] 1 QB 88 — that it is sufficient for the type of damage to be foreseeable, even if the precise extent or scale of that damage is not — continues to represent good law and sits consistently within the broader framework confirmed by the House of Lords in The Wagon Mound (No 1) [1961] AC 388 and applied in subsequent authorities including Hughes v Lord Advocate [1963] AC 837. There have been no statutory changes or significant later cases that undermine the principles described. Readers should note that the article describes one of the scientists as having been killed; the reported case concerned property damage and personal injury, and the outcome on liability is accurately summarised. The article is suitable as a foundational case note on remoteness of damage, though students should read it alongside the wider line of authority on foreseeability of type of harm.
