usually as part of a combined liability policy. The scale of potential liability is illustrated by cases such as those involving Mercedes-Benz for unstable vehicles and Perrier for benzene contamination, but the full list covers pharmaceuticals and medical devices, asbestos, tobacco, recreational equipment, mechanical and electrical products, chemicals and pesticides, agricultural products and equipment, food contamination, and all other major product classes. Employers and workers compensation Laws regarding workers compensation, which compensate an employee, vary by country, but the Workers’ Accident Insurance system put into place by Otto von Bismarck in 1881 is often cited as a model for Europe and later the United States. In many legal jurisdictions workers compensation is compulsory depending upon the business, including the United Kingdom and many states of the United States with the notable exception of Texas as of 2018. Regardless of compulsory requirements, businesses may purchase insurance voluntarily, and in the United States policies typically include Part One for compulsory coverage and Part Two for non-compulsory coverage. Original jurisdiction over workers' compensation claims has been diverted in much of the United States to administrative proceedings outside of the federal and state courts. They operate as no-fault schemes in which the employee need not prove the employer's fault; it is sufficient for the employee to prove that the injury occurred in the course of employment. If a third party other than the employer actually caused the injury, then the workers' compensation insurer (or self-insured employer) who is ordered to pay an employee's claim is usually entitled to initiate a subrogation action in the regular court system against the third party. In turn, workers' compensation insurance is regulated and underwritten separately from liability insurance. Just as the Insurance Services Office develops standard liability insurance forms and obtains approval for them from state insurance commissioners, the National Council on Compensation Insurance (NCCI) and various state rating bureaus provide similar services in the workers' compensation context. U.S. workers' compensation insurance generally covers only bodily injury to and death of employees, but it does not always cover other persons who may suffer injury as a direct result of such bodily injury or death. U.S. employers often carry Employers' Liability coverage (which is not necessarily compulsory) to protect themselves from lawsuits from such persons who would still have the right to sue them in the courts, such as an employee's spouse who claims loss of consortium as a