Prevention of Future Deaths reports · 2016

Keenan Walsh

Regulation 28 report to prevent future deaths, reference 2016-0202, written 27 May 2016. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report27 May 2016
Reference2016-0202
DeceasedKeenan Walsh
CoronerElizabeth Earland
Coroner areaExeter and Greater Devon
CategoryChild Death (from 2015)
Sourcejudiciary.uk record · original PDF
Responses published2

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.

ANNEX A

REGULATION 28: REPORT TO PREVENT FUTURE DEATHS (1)

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS
THIS REPORT IS BEING SENT TO:

4. The County Solicitor
Devon County Council
Room G26
County Hall
Topsham Road
Exeter

2. The Managing Director
North Devon Council
PO Box 379
Barnstaple
EX32 2GR

1

| CORONER

| am Dr Elizabeth Ann Earland, Senior Coroner for the coroner area of Exeter and
Greater Devon.

2 | 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.

3 | INVESTIGATION and INQUEST 7

On 16 September 2013 | commenced an investigation into the death of Keenan John
WALSH, aged 4 years. The investigation concluded at the end of the Inquest on
Wednesday 25 May 2016. The conclusion of the Inquest was a Narrative Conclusion,
details as follows:

“Keenan, a non-swimmer, died as a result of a tragic drowning accident in the 9 foot
deep end of a heated swimming pool at Bicclescombe Grace, Kingsley Avenue,
Ifracombe, whilst attending a large family party.

Sometime between 17:45 hours and 18:17 hours 23 August 2013, Keenan submerged in
the deep end of the pool whilst inadequately supervised in company of a permutation of
42 children jumping in and out and two adults, neither of whom were available to rescue
him. The slope of the deep end was a factor. Vision was obscured by large numbers of
inflatables.

Immediate attempts at resuscitation and subsequent transfer to North Devon District
Hospital, then Paediatric Intensive Care Unit at Bristol Children’s Hospital, failed to avert
his subsequent death from la. Complications of near-drowning.”

4 | CIRCUMSTANCES OF THE DEATH

See 3 above.

5 | 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) At the time of the incident private holiday lets with swimming pools were not
regulated by the Health and Safety Department of Local Authority Environmental
Health, despitg o“ ve a aa ei part of local economy. See recording
of evidence of Environmental Health Officer (North Devon
Council).

(2) Although there was a limited amount of signage the profile of the swimming pool
fell outside accepted standards and presented a significant hazard to non-
swimmers approaching a sharp slope to the deep end.

(3) The ratio of competent adults to children was one adult to anything up to 12
children at the time of this incident. This ratio was against the advice of the
proprietors but unenforceable. Responsibility lay with adult family members.

6 | ACTION SHOULD BE TAKEN

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

| refer you to the advice received in Evidence from EEE Environmental
Health Officer in her report.

. “Pool Profile

The gradient of the swimming pool in water depths of 1.5m and 1.35m had been
calculated as approximately 1 in 3.7. This means that the pool does not comply with
either the new European Standard BS EN 15288-2.2008 or the standard outlined in HSG
479 these being 1 in 10 and 1 in 15 respectively. The Officers have strongly
recommended that the owners consider re-profiling the floor of the pool to a gradient

which meets the requirements of those standards.
In the meantime Officers recommended that:

a) a diagram showing pool depth and profile should be displayed poolside.

b) The sides of the pool should be clearly marked at areas of steep gradient with
signs erected warning of the sudden change in depth.

c) To consider the possibility of introducing a physical barrier between the changes of
water depth. This could include the provision of floating buoys, for example.

d) Consider clearly marking the areas of steep gradient with coloured pool tank
markings.

° Signage
a) Clear, water depth signs should be provided which are clearly visible to the
bathers, when they are both on the pool surrounds and in the water.

2

b) Signs indicating general ‘do’s’ and ‘don'ts’ should be placed prominently poolside.
Warning signs such as ‘No Diving’, etc., should be displayed in a pictorial format to
comply with the Health & Safety (Safety Signs & Signals) Regulations 1996.

° Access to Pool

a) A high handle, ‘out of reach’ of younger children should be provided on the main
entrance door to the poo! hall.

b) Access to the pool hall is located close to deep water. Bathers may enter the water
at the first entry point without checking that the water depth is appropriate — a

articular problem for children and inexperienced swimmers.
EEE sugested that a physical barrier such as a guard-rail could be

provided.
Under the circumstances we would agree that a guard-rail and warning signs would
be appropriate.”

Further to this she stated in Evidence that it had recently been decided by the Legal
Department that such holiday lets would fall to be included with the provisions of Section
3 Health and Safety at Work Act 1974 (the proprietors being self-employed). If this is so
| invite you to clarify this point with all involved in the tourist industry in the county and
take such action as is felt necessary.

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report,
namely by 22 July 2016. 1, the Senior Coroner, may extend the period.

Your response must contain details of action taken or proposed to be taken, setting out
the timetable for action. Otherwise you must explain 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, who may find it useful or of interest.

FP (Father of Deceased)
EE Mother of Deceased)

| 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 Coroner.

mB &

Dr Elizabeth A. Earland
HM Senior Coroner

Dated this 27" day of May 2016

Responses

2 responses 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 Devon County Council (PDF)
County Council

: County Solicitor
HM Senior Coroner for the County of Devon Legal Services & Communications

Exeter and Greater Devon District . County Hall
Room 226 Topsham Road
Devon County Hall Exeter
Topsham Road EX2 4QD
Exeter DX 744970 Exeter 31

Fax: 01392 382286
Our Ref:

Your Ref: P|

22 July 2016

Dear Dr Earland

Re: Regulation 28 Report into the death of Kennan John WALSH ~ DOD 24.08.2013
Inquest 23 — 25 May 2016

We write further to your Regulation 28 Report sent on’27 May 2016, your letter of 20 June
2016 and your letter of 4 July 2016.

You helpfully explained that the purpose of a Regulation 28 Report is to identify those
authorities who have the power to make changes to improve practice which may prevent
further deaths and to bring the relevant circumstances to their attention.

We note the content of North Devon Council’s response and agree with them that the
responsibility for enforcing health and safety in holiday lets sits with District Councils
across Devon. In light of this Devon County Council has no power to make changes to
improve practice as that power is in the hands of the District Councils.

Devon County Council no jonger undertakes tourism operational activities as these are in
the process of being transferred out to the ‘Visit Devon Community Interest Company’
however, Devon County Council shall raise the issue with this organisation so that it may
raise awareness of the issue across Devon.

For the County Solicitor
Response from North Devon Council (PDF)
Report to Dr Elizabeth A Earland
H.M. Senior Coroner

North Devon Council’s response to your Regulation 28 Report to
prevent future deaths.

Keenan John WALSH Deceased
Inquest: 23 - 25 May 2016, Devon County Hall, Topsham Road, Exeter

North Devon Council’s (NDC) responsibilities for enforcing health and
safety.

NDC is an authority responsible for enforcing health and safety by virtue of
$18 Health and Safety at Work etc Act 1974.

The Health and Safety (Enforcing Authority) Regulations 1998 allocate
responsibility for the enforcement of health and safety in holiday lets to local
authorities where temporary or permanent accommodation is provided for
more than 20 weeks.

In May 2013 HSE published the National Local Authority Enforcement Code
(the Code). The Code was developed in response to the recommendation in
“Reclaiming health and safety for all: an independent review of health and
safety legislation” by Professor Ragnar Léfstedt for HSE to be given a
stronger role in directing Local Authority (LA) health and safety inspection and
enforcement activity and as an outcome of the Red Tape Challenge on health
and safety.

The Code is designed to ensure that LA health and safety regulators take a
more consistent and proportionate approach to their regulatory interventions.
It sets out the Government expectations of a risk based approach to targeting.

In May 2016 the HSE issued Local Authority Circular (LAC 67/2 (rev 5)) to
provide guidance and tools for priority planning and targeting these
interventions to enable them to meet the requirements of the Enforcement
Code.

The LAC identifies 10 activities/sectors where it is appropriate for local
authorities to carry out proactive inspections. These are based on national
priorities. This list does not include managing safety in swimming pools.

The LAC also allows for the development of local intervention plans which are
based on a regional/district needs assessment. For a number of years
swimming pool safety has been identified as a local priority in NDC’s
intervention plan.

NDC’s performance in enforcing swimming pool safety

NDC’s performance in relation to the proactive inspection of swimming pools
is set out in Appendix 1.

While there are no swimming pool specific health and safety laws, officers
require operators to comply with the general duties under the HSWA 74 and
associated regulations.

Officers refer to and promote the guidance, issued by the HSE entitled
‘Managing health and safety in swimming pools’. This is available at
www.hse.gov.uk/pubns/books/hsq179.htm

There is no requirement to register/licence a swimming pool and this makes it
more challenging for regulators such as NDC to maintain an up to date data
base.

NDC’s enforcement of health and safety at Bicclescombe Grange, Score
View, Ilfracombe, EX34 8ET.

The operator has complied with the works the investigating officer set out in
relation to health and safety contraventions regarding signage and access to
the swimming pool. The operator has given a commitment to re profile the
pool before the end of September 2016. This control was set out as a
recommendation.

The Council is seeking counsel's opinion so that it can better advise its
enforcement officers on the scope of $3(2) Health and Safety at Work etc Act
1974 (duties of self employed persons to persons other than their employees).

This opinion will be shared with the other local enforcing authorities in Devon
via the Chief Environmental Health Officers Health and Safety Sub Group.

This will inform the development of all Local Authority intervention plans
across Devon and the tourist industry in the county will be advised
accordingly.

Summary

NDC will continue to invest resources in enforcing swimming pool safety, this
is a local priority. NDC will share the outcome of this inquest and counsel’s
opinion with other health and safety local authority regulators in Devon, with a
view to enhancing the effectiveness and consistency of all local authority
intervention plans,in the region.

Mike Mansell

Chief Executive
North Devon Council
28th June 2016

Related reports

Other reports by Elizabeth Earland

See all →

More reports categorised “Child Death (from 2015)”

See all →

Track Child Death (from 2015)

See every Prevention of Future Deaths report matching Child Death (from 2015), and how often a new one appears.

What would an alert for this have sent me? Search the full text

Free to try — the preview shows the real matches and how many arrived in the last 12 months. Your first email alert is free.

These reports are published by the Chief Coroner's office at judiciary.uk and are © Crown copyright. The text here is reproduced from the published PDF so it can be searched. If something on this page is wrong, or you are a person named in it and want it reviewed, email drcjar@gmail.com and we will act promptly.