Non-adiabatic decay rates for a radio-frequency dressed magnetic trap are calculated using Fermis Golden Rule: that is, we examine the probability for a single atom to make transitions out of the dressed trap and into a continuum in the adiabatic limit, where perturbation theory can be applied. This approach can be compared to the semi-classical Landau-Zener theory of a resonant dressed atom trap, and it is found that, when carefully implemented, the Landau-Zener theory overestimates the rate of non-adiabatic spin flip transitions in the adiabatic limit. This indicates that care is needed when determining requirements on trap Rabi frequency and magnetic field gradient in practical atom traps.