In Page v Freight Hire (Tank Haulage) Ltd [1981] IRLR 13 EAT, the EAT held that the employer was protected by the Sex Discrimination Act 1975, section 51(1) because refusing to allow the employee to transport dimethyl formamide was necessary to comply with the employer's duty under the Health and Safety at Work etc Act 1974 and was not an act of excessive caution.