Ryan, J.
In this case we are required to determine the effect of the doctrine of comparative negligence1 on our decisions in Funk v General [38]*38Motors Corp, 392 Mich 91; 220 NW2d 641 (1974), and Tulkku v Mackworth Rees Division of Avis Industries, Inc, 406 Mich 615; 281 NW2d 291 (1979).2 Since the defense of comparative negligence serves not to undermine but to enhance safety in the workplace, we are of the view that comparative negligence is available as a defense in those cases where Funk and Tulkku formerly prohibited the application of the contributory negligence defense. We conclude that negligence in the failure to provide an "adequate safety device” in the workplace is therefore subject to the comparative negligence defense, assuming that any evidence of the plaintiff’s negligence exists. The verdict in favor of the defendants is reversed and the cause remanded for retrial under the principles of comparative negligence. Placek v Sterling Heights, 405 Mich 638; 275 NW2d 511 (1979).
I
The facts of this case are set forth in full and accurate detail in Justice Moody’s opinion, to which reference is invited. The plaintiff-appellant argues that the jury should not have been instructed that contributory negligence was a defense to the claim that the defendant construction contractors negligently installed or maintained safety devices for the protection of construction workers at the work site.
Although the precise limits of this Court’s opinion in Funk, supra, are unclear,3 we concur with [39]*39the result reached by Justice Moody in parts I-III of his opinion. Under Funk, the defense of contributory negligence is unavailable when a construction worker alleges negligence in the failure to provide adequate safety devices on the job. The plaintiff in this case presented sufficient, albeit weak, evidence upon which the jury might have concluded that the plywood sheets covering the openings in the roof were "safety devices” which were negligently installed or maintained. Absent a reconsideration of the Funk doctrine, the plaintiff would be entitled to a new trial on the negligence claim, without the defense of contributory negligence.4
However, the defense of contributory negligence as a total bar to recovery would be unavailable upon retrial in any event in light of Placek, supra. We must therefore decide whether the Funk policy of promoting safety in the workplace would be undermined or enhanced by the application of the principles of comparative negligence.
II
In Funk, this Court found the total bar of contributory negligence to be inconsistent with the public policy of promoting safety in the workplace. The Court refused to allow a . general contractor and a landowner to "avoid” liability "by pointing to the concurrent negligence of the injured worker [40]*40in using the [unsafe] equipment”. Funk, 113-114, quoting Koenig v Patrick Construction Corp, 298 NY 313, 318-319; 83 NE2d 133 (1948). Before Funk, the contractor could entirely avoid liability by convincing the finder of fact that the plaintiff was even 1% negligent. Apparently it was feared that some contractors might succumb to the temptation of employing skilled defense counsel instead of adequate safety devices. As the Court noted in Tulkku, 622:
"To allow defendants in this case to invoke the protection of the contributory negligence doctrine would be tantamount to subverting the very safety concerns that the Koenig and Funk courts extolled as of paramount importance. Such a position might allow a manufacturer to escape its duty of due care * * *:
" 'It would be anomalous to hold that defendant has a duty to install safety devices but a breach of that duty results in no liability for the very injury the duty was meant to protect against.’ ” Quoting Bexiga v Havir Mfg Corp, 60 NJ 402, 412; 290 A2d 281 (1972). (Emphasis added.)
In stark contrast, the defense of comparative negligence never allows a contractor to entirely "avoid” liability and thus "escape” the duty of due care. Under Placek, the defendant must pay the full percentage of damages caused by his negligence. We do not find this partial defense "anomalous” as does our brother; quite the contrary, it would be "anomalous” to hold a defendant liable for damages in excess of the amount causally related to his negligence.5 The comparative negli[41]*41gence defense does not provide a strong financial incentive for contractors to breach the duty to undertake reasonable safety precautions.
Our colleague asserts that a worker’s recovery should not be reduced by his own comparative negligence when he works under dangerous conditions, since "considering the current state of the economy” it "would be unrealistic to conclude that workers have a choice not to work”. Unfortunately, some workers are faced with the ultimatum "[i]f you don’t want to work up in the steel, go home”. Funk, 113. If a worker, acting reasonably under all the circumstances, would continue to work under the dangerous conditions, then the trier of fact could not conclude that the worker’s recovery should be reduced, since the worker by definition was not negligent. On the other hand, at some point a worker must be charged with some responsibility for his own safety-related behavior. If a worker continues to work under extremely unsafe conditions when a reasonable worker under all the facts and circumstances would "take a walk”, the trier of fact might appropriately reduce the plaintiffs recovery under comparative negligence. Comparative negligence enhances the goal of safety in the workplace under these conditions, since it gives the worker some financial incentive to act in a reasonable and prudent fashion.
The comparative negligence rule also enhances safety in the workplace by rewarding safety-conscious contractors. Undoubtedly, some contractors allow workers to refuse to work without fear of [42]*42reprisal until dangerous conditions are reported and corrected.6 Yet our colleague’s approach treats such a "safe” company identically with an "unsafe” company and prevents the safe company from reducing its damages despite a plaintiff’s flagrant violation of company safety policy. The irrebuttable presumption that all contractors force workers to work under hazardous conditions might well become a grim self-fulfilling prophecy if we refuse to encourage safety-conscious contractors under the doctrine of comparative negligence.
Much the same response is appropriate to the comment that workers often become conditioned to working in dangers and deal with them prudently: continuing to work under those conditions would not constitute negligence on the part of the worker. Further, the contractor-defendant has little incentive to prove that the conditions were so dangerous that the plaintiff should have refused to work, since such an approach will probably increase rather than decrease the defendant’s liability under comparative negligence. This is in contrast to the contributory negligence rule, which encouraged such a defense strategy.
In Tulkku,
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Ryan, J.
In this case we are required to determine the effect of the doctrine of comparative negligence1 on our decisions in Funk v General [38]*38Motors Corp, 392 Mich 91; 220 NW2d 641 (1974), and Tulkku v Mackworth Rees Division of Avis Industries, Inc, 406 Mich 615; 281 NW2d 291 (1979).2 Since the defense of comparative negligence serves not to undermine but to enhance safety in the workplace, we are of the view that comparative negligence is available as a defense in those cases where Funk and Tulkku formerly prohibited the application of the contributory negligence defense. We conclude that negligence in the failure to provide an "adequate safety device” in the workplace is therefore subject to the comparative negligence defense, assuming that any evidence of the plaintiff’s negligence exists. The verdict in favor of the defendants is reversed and the cause remanded for retrial under the principles of comparative negligence. Placek v Sterling Heights, 405 Mich 638; 275 NW2d 511 (1979).
I
The facts of this case are set forth in full and accurate detail in Justice Moody’s opinion, to which reference is invited. The plaintiff-appellant argues that the jury should not have been instructed that contributory negligence was a defense to the claim that the defendant construction contractors negligently installed or maintained safety devices for the protection of construction workers at the work site.
Although the precise limits of this Court’s opinion in Funk, supra, are unclear,3 we concur with [39]*39the result reached by Justice Moody in parts I-III of his opinion. Under Funk, the defense of contributory negligence is unavailable when a construction worker alleges negligence in the failure to provide adequate safety devices on the job. The plaintiff in this case presented sufficient, albeit weak, evidence upon which the jury might have concluded that the plywood sheets covering the openings in the roof were "safety devices” which were negligently installed or maintained. Absent a reconsideration of the Funk doctrine, the plaintiff would be entitled to a new trial on the negligence claim, without the defense of contributory negligence.4
However, the defense of contributory negligence as a total bar to recovery would be unavailable upon retrial in any event in light of Placek, supra. We must therefore decide whether the Funk policy of promoting safety in the workplace would be undermined or enhanced by the application of the principles of comparative negligence.
II
In Funk, this Court found the total bar of contributory negligence to be inconsistent with the public policy of promoting safety in the workplace. The Court refused to allow a . general contractor and a landowner to "avoid” liability "by pointing to the concurrent negligence of the injured worker [40]*40in using the [unsafe] equipment”. Funk, 113-114, quoting Koenig v Patrick Construction Corp, 298 NY 313, 318-319; 83 NE2d 133 (1948). Before Funk, the contractor could entirely avoid liability by convincing the finder of fact that the plaintiff was even 1% negligent. Apparently it was feared that some contractors might succumb to the temptation of employing skilled defense counsel instead of adequate safety devices. As the Court noted in Tulkku, 622:
"To allow defendants in this case to invoke the protection of the contributory negligence doctrine would be tantamount to subverting the very safety concerns that the Koenig and Funk courts extolled as of paramount importance. Such a position might allow a manufacturer to escape its duty of due care * * *:
" 'It would be anomalous to hold that defendant has a duty to install safety devices but a breach of that duty results in no liability for the very injury the duty was meant to protect against.’ ” Quoting Bexiga v Havir Mfg Corp, 60 NJ 402, 412; 290 A2d 281 (1972). (Emphasis added.)
In stark contrast, the defense of comparative negligence never allows a contractor to entirely "avoid” liability and thus "escape” the duty of due care. Under Placek, the defendant must pay the full percentage of damages caused by his negligence. We do not find this partial defense "anomalous” as does our brother; quite the contrary, it would be "anomalous” to hold a defendant liable for damages in excess of the amount causally related to his negligence.5 The comparative negli[41]*41gence defense does not provide a strong financial incentive for contractors to breach the duty to undertake reasonable safety precautions.
Our colleague asserts that a worker’s recovery should not be reduced by his own comparative negligence when he works under dangerous conditions, since "considering the current state of the economy” it "would be unrealistic to conclude that workers have a choice not to work”. Unfortunately, some workers are faced with the ultimatum "[i]f you don’t want to work up in the steel, go home”. Funk, 113. If a worker, acting reasonably under all the circumstances, would continue to work under the dangerous conditions, then the trier of fact could not conclude that the worker’s recovery should be reduced, since the worker by definition was not negligent. On the other hand, at some point a worker must be charged with some responsibility for his own safety-related behavior. If a worker continues to work under extremely unsafe conditions when a reasonable worker under all the facts and circumstances would "take a walk”, the trier of fact might appropriately reduce the plaintiffs recovery under comparative negligence. Comparative negligence enhances the goal of safety in the workplace under these conditions, since it gives the worker some financial incentive to act in a reasonable and prudent fashion.
The comparative negligence rule also enhances safety in the workplace by rewarding safety-conscious contractors. Undoubtedly, some contractors allow workers to refuse to work without fear of [42]*42reprisal until dangerous conditions are reported and corrected.6 Yet our colleague’s approach treats such a "safe” company identically with an "unsafe” company and prevents the safe company from reducing its damages despite a plaintiff’s flagrant violation of company safety policy. The irrebuttable presumption that all contractors force workers to work under hazardous conditions might well become a grim self-fulfilling prophecy if we refuse to encourage safety-conscious contractors under the doctrine of comparative negligence.
Much the same response is appropriate to the comment that workers often become conditioned to working in dangers and deal with them prudently: continuing to work under those conditions would not constitute negligence on the part of the worker. Further, the contractor-defendant has little incentive to prove that the conditions were so dangerous that the plaintiff should have refused to work, since such an approach will probably increase rather than decrease the defendant’s liability under comparative negligence. This is in contrast to the contributory negligence rule, which encouraged such a defense strategy.
In Tulkku, we noted that many workers rely on the effectiveness of what appears to be adequate safety equipment. In that case, the worker relied upon a four-palm-button switch that proved to be defective. Such reasonable reliance, absent proof that reasonably prudent press workers do not rely on the device, is not evidence of negligence; thus, no contributory negligence instruction should have been given in Tulkku because the defendant presented no evidence of the plaintiff’s negligence. The Tulkku result would therefore remain the [43]*43same even after the adoption of comparative negligence, since the worker "cannot and should not be required to temper his or her behavior because of a defect about which the [worker] has no awareness”. Tulkku, 622. Suppose, however, that the press in Tulkku cycled after only three buttons were pushed, but no one was injured. A worker continuing to use the machine and receiving injuries the second time the switch fails should be answerable for his or her negligent behavior because the worker is fully aware of the defect. Yet our brother’s opinion would hold exactly the opposite; the defense of comparative negligence would be unavailable in that situation because the worker has not "wilfully” removed a safety device.
Next, our colleague argues that a worker’s recovery should not be reduced because of his or her "ordinary inadvertence”. To the extent that the plaintiff’s behavior conforms to that of a reasonably prudent worker under all the circumstances (even reasonably prudent workers act as plaintiff did because of job pressures, monotony, and attention to details of their work), the trier of fact is free to find the plaintiff free from negligence. To the extent, however, that "ordinary inadvertence” is merely a euphemism for a worker’s negligence, it should reduce a worker’s recovery. Until today, the notion that "mere inadvertence” should absolve persons from the effects of their negligence has been wholly foreign to our jurisprudence.7 We see no logical reason why it should immunize this [44]*44particular class of plaintiffs from the defense of comparative negligence even if, as appears to be the case, we are observing the genesis of a new jurisprudence to be called "safety device” law.
Finally, it is argued that "in most instances” the worker’s negligence will occur later than the defendant’s negligence, making it "difficult” for the jury to accurately arrive at the correct percentage of relative fault. First, no empirical data supports the speculation that in "most” workplace accidents the worker’s negligence happens last and understandably no authority is cited for it. Intuitively, it would seem that in "most” cases, as in Funk and Tulkku, the contractor’s failure to provide an adequate safety device is probably a continuing omission which is concurrent with the employee’s conduct that produces the injury. Secondly, our brother’s opinion would abolish comparative negligence even in those cases where the contractor’s negligence is "last” and the worker’s negligence is the more distant in time.8 Thirdly, the idea that juries are not competent to make difficult allocations of proportional fault under comparative negligence is simply erroneous.9 Finally, on the basis of the speculation that the jury will reach the wrong allocation of fault, our colleague’s approach guarantees that recovery will not be in proportion to [45]*45fault, since if the defendant is negligent at all he pays 100% of plaintiffs damages. Truly this is a case of the cure being worse than the illness. As this Court acknowledged in Placek:10
" 'What pure comparative negligence does is hold a person fully responsible for his or her acts and to the full extent to which they cause injury. That is justice.’ ” 405 Mich 661.
Our colleague’s approach today would hold these defendants responsible for their acts above and beyond the extent to which they cause injury. That is injustice.
Ill
We also agree with the analysis and conclusion in part VII of Justice Moody’s opinion which rejects plaintiff’s claim that retrial should be limited to the issue of damages. While a poll of the jury revealed that five of the six jurors found all defendants to have been negligent, we do not know whether defendants’ negligence was the failure to provide adequate "safety devices” or some other negligent act or omission such as the alleged failure to "adequately supervise and coordinate the activities of workmen on the roof’. Since the failure to adequately supervise was "ordinary negligence” and not "safety device negligence”, under our brother’s analysis the contributory negligence instruction would have been proper as to this claim; similarly, on retrial, comparative negligence will be available as a defense to this claim.
[46]*46However, as noted, we do not limit the defense of comparative negligence to negligence not involving "safety devices”. While that ambiguous and abstruse term was utilized in Funk and again in Tulkku, nothing in either opinion suggests a compelling reason why this apparently new subspecies of negligence should be treated differently than any other type of negligence. Indeed, in Funk, the Court noted that the defendants failed to give the plaintiff a "safety indoctrination”; yet that omission can hardly be forced into the category of failing to provide a "safety device”. The misguided emphasis on the magic words "safety device” has already begun to lead to absurd, confusing, and therefore unfair results. As to non-safety device negligence, it appears that ordinary negligence and comparative negligence principles will apply. As to safety device negligence, ordinary negligence evidently applies as to liability, but a special comparative negligence instruction is required under my brother’s analysis if the plaintiff "wilfully” removed a safety device.11
The confusion perpetuated by that approach in this case is both unsound and unnecessary. By reinventing the comparative negligence wheel [47]*47with "wilful removal of a safety device” language, our colleague would create a two-tier tort system, general negligence versus "safety device” negligence, each with its own set of instructions. As discussed above, the application of comparative negligence to all workplace negligence satisfies the Funk policies as well as encourages safer behavior by both contractors and workers. We prefer a unitary approach to negligence12 under which both the plaintiff and defendant are charged with the duty to act reasonably under all the circumstances.
IV
Since the issue is likely to arise upon retrial, we must also consider the appropriate instructions under MCL 408.853; MSA 17.49(3), since repealed. We agree that sufficient evidence was presented to justify an instruction under the statute. We also agree that under Zeni v Anderson, 397 Mich 117, 143; 243 NW2d 270 (1976), the trial court should instruct that violation of the statute constitutes a prima facie case of negligence, rather than negligence as a matter of law.
We disagree with the wisdom or necessity of [48]*48adopting, at this appellate remove, our colleague’s definition, or any definition, of the word "wilfully” as used in the since-repealed statute. Neither party requested a definitional instruction in the trial court or objected to the judge’s failure to define the term sua sponte. We leave it to the trial court to decide in the first instance which of the parties’ proposed instructions accurately represents the law on this point.
V
As to defendant J & L Roofing Company’s cross-appeal that the trial court erred in denying its motions for directed verdict, we agree fully with the result and reasoning of Justice Moody in part VI of his opinion. The case is therefore remanded for trial on defendant Leonard Construction Company’s claim for indemnification.
The decision of the Court of Appeals is reversed.
Coleman, C.J., and Kavanagh and Fitzgerald, JJ., concurred with Ryan, J.