The Law Commission's 1996 report on involuntary manslaughter found that the gross negligence formula overcomes the problems of having to find one particular officer who has the "mens rea" for the offence and allows emphasis to be placed on the company's attitude to safety. This question would only arise where the company has chosen to enter a field of activity that carries a risk to others, such as transport, manufacture or medical care. The steps the company has taken to discharge the "duty of safety" and the systems devised for running its business, will be directly relevant. Although only expressed as a provisional view, it is significant that the Law Commission echoes here the recognition of corporate safety systems voiced in the Seaboard case. Thus, a real tension is exposed between the paradigm of criminal culpability based on individual responsibility and the increasing recognition of the potential for harm inherent in large scale corporate activity.