Prevention of Future Deaths reports · 2014

Hywel Hughes

Regulation 28 report to prevent future deaths, reference 2014-0311, written 2 Jul 2014. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report2 Jul 2014
Reference2014-0311
DeceasedHywel Hughes
CoronerKaron Monaghan
Coroner areaNorth West Wales
CategoryPolice related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text recovered by OCR from a scanned PDF. OCR is imperfect: check anything you rely on against the source PDF. Reproduced verbatim, including the scan's own layout.

REGULATION 28: REPORT TO PREVENT FUTURE DEATHS

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS

THIS REPORT IS BEING SENT TO:

1. The Chief Constable of the North Wales Constabulary
2. The Security Industry Authority
3. The Secretary of State for the Home Department

CORONER

| am Karon Monaghan QC, Assistant Coroner, for the Coroner area of
North West Wales

CORONER’S LEGAL POWERS

| make this report under paragraph 7, Schedule 5, of the Coroners and
Justice Act 2009 and regulations 28 and 29 of the Coroners
(Investigations) Regulations 2013.

INVESTIGATION and INQUEST

An investigation into the death of Mr Hywel LLewelyn Hughes (date of
birth 11 January 1971) concluded at the end of the Inquest on 26 June
2014. The conclusion of the inquest was that: (i) the medical cause of
death was traumatic asphyxia; (ii) the actions of police officers attached
to the North Wales police force on coming upon Mr Hughes were not
appropriate and (iii) it is more probable than not that the actions of the
police officers more than minimally contributed to the death of Mr
Hughes.

CIRCUMSTANCES OF THE DEATH

On 2 May 2003, Mr Hywel LLewelyn Hughes was forcibly removed from
Joops nightclub, Bangor, by employed members of the door staff at about
23.10. After a struggle with two members of the door staff between
approximately 23.10 and 23.18, he was restrained by them in a face
down position on the road. During the period of this restraint, he was
unable to breathe and suffered injuries which ultimately caused his death.
Two police officers attached to the North Wales police force arrived on
the scene at approximately 23.18 and transported Mr Hughes to
Caemarfon police station from where he was conveyed to Ysbyty
Gwynedd, arriving at approximately 00.30. Mr Hughes was declared

deceased at Ysbyty Gwynedd at 19.30 hours on 3 May 2003.

CORONER’S CONCERNS

During the course of the inquest the evidence revealed matters giving rise
to concern. In my opinion there is a risk that future deaths will occur
unless action is taken. In the circumstances it is my statutory duty to
report to you.

The MATTERS OF CONCERN are as follows. —

(1) The training on positional asphyxia presently provided to police
officers by the North Wales Police Force does not include
guidance on the significance of ‘snoring’ and in particular that it is
not inconsistent with deep unconsciousness and obstruction to
breathing.

(2) The design of the ‘bubble cars’ in existence at the time of Mr
Hughes’ death and apparently still in use pending their phasing
out, is such that the condition of a detainee held in the rear of the
vehicle may not be easily monitored (because of the presence of a
Perspex screen that may affect the ability to see and hear a
detainee).

(3) The design of the new ‘bubble cars’ may impede an officer's ability
to hear a detainee (and thus identify irregularities or difficulties in
breathing) because of the presence of a (albeit smaller) Perspex
screen.

(4) Twenty deaths apparently related to and/or following restraint by
door supervisors have occurred since the introduction in 2004 of
(rolled out) compulsory licensing of door supervisors, by the
Security Industry Authority (“SIA”) (established by the Private
Security Act 2001, in 2003). There have been four restraint related
deaths involving twelve door supervisors (all of whom have been
charged with either murder or manslaughter) since April 2013, that
is, following the introduction (in February 2013) of mandatory
training as a condition for the awarding (or renewal) of a licence to
work as a door supervisor anywhere in the UK.

(5) The SIA does not undertake any review or inquiry into those
deaths indicated by Inquest or criminal findings to be related to
restraint by door supervisors to determine whether there are any
lessons to be learmt in so far as their licensing or other
responsibilities are concerned.

(6) The SIA’s standards of conduct, training and levels of supervision
issued pursuant to their statutory responsibilities under section
1(2)(e) of the 2001 Act, namely the “Specification for Leaming and
Qualifications for Door Supervisors” (Feb 2010) and the
“Specifications for Learning and Qualifications for Physical
Intervention Skills’ (Aug 2010), do not include a requirement for
training or knowledge on the dangers inherent in restraint, specific
modes of restraint, positional asphyxia or traumatic asphyxia.

7) The SIA does not audit the training provided to door supervisors b

accredited training providers, particularly on issues of restraint and |

asphyxia (traumatic and positional).

(8) The mandatory training that door supervisors are required to
undertake as a condition of the award of a licence by the SIA does
not integrate training on asphyxia into the training on restraint (it is
addressed by a limited and discrete element).

(9) The licensing requirements for door supervisors do not include a
requirement for a first aid qualification.

(10) lt is not clear that all persons presently working as door
supervisors have yet undertaken physical intervention training (it
appears that those who already have a licence will only be
required to undertake ‘top training’ when they seek renewal of a
licence).

(11) There have already been four ‘Rule 43’ reports to the SIA
by Coroners conceming the training of door supervisors on
restraint and asphyxia.

:

In my opinion action should be taken to prevent future deaths and |
believe you have the power to take such action.
7

taken, setting out the timetable for action. Otherwise you must expl

ACTION SHOULD BE TAKEN

YOUR RESPONSE |

You are under a duty to respond to this report within 56 days of the date

of this report, namely by 26 August 2014. |, the Assistant Coroner, may

extend the period.

Your response must contain details of action taken or proposed to be
jain

why no action is proposed. :

COPIES and PUBLICATION

| have sent a copy of my report to the Chief Coroner and to the following
Interested Persons:

A PON>

| have also sent it to HM Coroner for North West Wales and to the British
Security industry Association who may find it useful or of interest.

| am also under a duty to send the Chief Coroner a copy of your
response.

The Chief Coroner may publish either or both in a complete or redacted

or summary form. He may send a copy of this report to any person who
he believes may find it useful or of interest. You may make
representations to me, the Coroner, at the time of your response, about
the release or the publication of your response by the Chief C:

2 July 2014

Karon Monaghan QC

Responses

1 response published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from North Wales Police (PDF)
Gareth Pritchard MA 
Dirprwy Brif Gwnstabl / Deputy Chief Constable 

Our ref: DCC/ND/HHCorInqFinal14 

21st August 2014 

Email:

Dear Madam  

Hywel Llewelyn Hughes  

We refer to your Schedule 5, Regulation 28 report to prevent future deaths dated 2 July 2014 and in particular the 
parts addressed to North Wales Police (“NWP”).   

We reply as follows:- 

a)  Snoring  

NWP agree that in the light of the evidence/findings arising from this inquest that snoring should be including in 
the training on positional asphyxia.   

Therefore, NWP have:-  

•  Amended their first aid, personal safety and tasar training materials and training package to add snoring 

as a symptom of positional asphyxia.  

•  Added an exercise in which a violent person stops breathing after being dealt with by officers to the tasar 

and personal safety training to demonstrate the dangers of such medical emergencies.  

The  NWP  amendments  on  snoring  have  been  recommended  to  the  organisations  below  to  bring  about 
improvement to material/training at a national level for police forces.  

o  College of Policing  
o  The  National  Secretary  and  Regional  Representative  for  the  Self  Defence  Arrest  and  Restraint 

section of the Association of Chief Police Officers (“ACPO”) 

o  The North West Regional Firearms Group  

www.heddlu-gogledd-cymru.police.uk 

Swyddfa’r Dirpwy Prif Gwnstabl  
Pencadlys yr Heddlu, Glan-y-Don, 
Bae Colwyn LL29 8AW 
Ffôn (Cymraeg): 
L.U.: 

www.north-wales.police.uk 

Deputy Chief Constable’s Office 
Police Headquarters, Glan-y-Don, 
Colwyn Bay LL29 8AW 

Tel (English):

Direct Dial: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 b)  Bubble Cars 

NWP  consider  that  police  officers  can  effectively  monitor  detainees  irrespective  of  the  issues  highlighted  over 
sight  and  hearing  connected  to  the  protective  screens  in  the  existing  double  compartment  bubble  car  or 
proposed  single  compartment  bubble  car  when  transporting  detainees.  Monitoring  is  achievable  to  acceptable 
levels if officers pay sufficient attention to the task and abide by their detainee risk assessments and force policies 
when transporting detainees. However, NWP are considering improvements to assist with monitoring as set out 
below. 

Bubble cars are general purpose police vehicles lawfully modified to utilise a containment cell for prisoners within 
the  vehicle.  The  protective  screen  in  bubble  cars’  containment  cells  (between  the  detainee  and  the 
driver/passenger police officer) are made of polycarbonate not perspex.  The protective screens were designed as 
part of the containment cell arrangement to achieve a sensible balance between health and safety concerns for 
the police officers and the detainees whilst providing an acceptable capacity for monitoring detainees.   

NWP operate in a large rural area, utilising three designated custody suites in convenient locations within their 
force area.  NWP consider bubble cars as a preferable alternative to police vans for transporting detainees for a 
number  of  reasons.  The  force  are  presently  evaluating  changing  the  containment  cell  from  a  double  one  to  a 
single  cell,  however,  a  final  decision  on  whether  this  goes  ahead  will  be  dealt  with  after  testing  and  further 
consideration is concluded.  It is not correct to suggest that the double cell bubble cars are being “phased out”.   

The  screen  is  not  scratch  resistant  but  a  sharp  instrument  would  be  needed  to  scratch  it.    Bubble  cars  are  the 
subject  of  a  vehicle  user  check  for  each  day  by  the  police  officer  utilising  the  vehicle  and  a  weekly  check  by  a 
supervising sergeant.  The user check includes the protective screen. Defects are reported to fleet services which 
result  in  repairs  being  undertaken  in  a  timely  fashion,  which  include  scratches  on  the  protective  screen.  NWP 
have assessed the protective screen as adequate to hear a detainee within the containment cell.  

The bubble cars used over the years have altered because of fleet services procurement requirements.  The latest 
vehicle being utilised was the Ford Focus, which due to manufacturer redesigns resulted in less cabin space due to 
the  area  occupied  by  the  compartment  cell.  This  lack  of  space  resulted  in  complaints  from  taller  officers  that 
there  was  insufficient  room  for  the  front  seats  to  be  put  back  sufficiently.    There  was  also  concern  about  a 
number of incidents in which violent detainees had kicked out the rear nearside and offside windows and with 
drunken detainees slumping across the rear seats, making monitoring more problematical.  Accordingly, to assist 
with  these  problems,  NWP  have  designed  a  single  cell  compartment  bubble  car  in  conjunction  with  the 
manufacturer  and  are  testing  the  single  cell  compartment,  which  appears  so  far  to  present  significant 
improvements  to  the  existing  double  cell  compartment  arrangement.  It  allows  better  monitoring  as  the  police 
officer is closer to the detainee from visual and auditory perspectives. 

Proposed auditory Improvements 
NWP are considering the following:- 

•  Scoping an automated intercom solution with a view to identifying an appropriate product to  be tested 

on a demonstrator vehicle for use in the bubble containment cell;  

•  Undertaking enquiries as to the possibility of having a hole in the protective screen to see if that improves 
ability to monitor detainees (and does not compromise the integrity of the protective screen or provide 
health and safety implications for the police officers/detainees). 

Finally,  the  Police  and  Crime  Commissioner  (“PCC”),  Winston  Roddick  QC  wishes  to  make  it  clear  that  he  will 
scrutinise NWP’s response to your report by examining its revised training programme to satisfy himself that the 
revisions  have  been  adopted  and  the  training  is  being  carried  out  in  accordance  with  those  revisions.    He 
proposes to make unannounced visits to force training sessions to verify their adequacy.  

 
 
 
 
 
 
 
 
 
 
 
 Similarly,  the  PCC  will  satisfy  himself  that  NWP’s  use  of  the  bubble  car,  whether  in  a  double  or  single 
compartment,  including  any  improvements  to  the  polycarbonate  screen  and/or  intercom  arrangements,  are 
adequate.  

Yours faithfully 

Deputy Chief Constable

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