Rio Andrew

Association of Ambulance Chief Executives 
3rd floor 
32 Southwark Bridge Road 
London 
SE1 9EU 

T:  020 7783 2043 
W:  www.aace.org.uk 

Selena Lynch 
Senior Coroner  
London South 

By E-mail. 

20th March 2016 

Dear Mrs Lynch, 

Thank you for copying the Association of Ambulance Chief Executives AACE into the 
Regulation 28 ruling associated with the sad death of Rio Andrew age 15 at an illegal rave in 
Croydon in June 2014. 

As you note in your letter AACE has not been required to respond to the Regulation 28 notice 
but was copied in as you felt it may be of interest to us. 

Having considered the issue and discussed with the National Ambulance Medical Directors 
Group we did feel that we should write to you to make a few salient points and to encourage 
your engagement with the Care Quality Commission (CQC) to address the regulatory issues. 

AACE remains concerned that private ambulance providers who are providing medical cover at 
events remain unregulated by CQC in terms of the medical care they are delivering within the 
event footprint. We have raised this previously with CQC and whilst we appreciate the additional 
workload it would bring them it is clear that at times the medical care provided can be tragically 
inadequate. This also brings an unquantifiable additional burden for the statutory ambulance 
service who have to intervene and also puts patients at risk. 

We are also aware of course that the term ‘Ambulance Technician’ is not a protected title and is 
not regulated. The college of Paramedics has been lobbying for some time to have this title 
protected and to bring Ambulance Technicians under the same level of regulation as 
Paramedics. AACE is supportive of this and works closely with the College of Paramedics to 
attempt to progress this issue. 

Statutory Ambulance services when contracting with private providers will undertake their own 
quality assurance checks to ensure that all staff of all grades used by that private provider in the 
execution of that contract are appropriately qualified and skilled. It would appear however that 
some private providers do not operate to the same level of diligence as would appear to be the 
situation in this case. 

I hope this is helpful 

Chairman:  Dr Anthony C Marsh QAM SBStJ DSci (Hon) MBA MSc MA FASI 
Managing Director:  Martin Flaherty OBE 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Yours sincerely 

Anthony C Marsh QAM SBStJ DSci (Hon) MBA MSc MA FASI 
Chief Executive, West Midlands Ambulance Service NHS Foundation Trust 
Chairman, Association of Ambulance Chief Executives 

Chairman:  Dr Anthony C Marsh QAM SBStJ DSci (Hon) MBA MSc MA FASI 
Managing Director:  Martin Flaherty OBE

From Ben Gummer MP
Parliamentary Under Secretary of State for Care Quality

Department Richmond House
79 Whitehall
of Health itehal
POC 1014368 SWIA 2NS
Tel: 020 7210 4850

Ms Selena Lynch

HM Coroner — South London Area
Coroner’s Office, St Blaise Building
Bromley Civic Centre

Stockwell Close

Bromley T*

Ce hbad—

Thank you for your letter of 27" January to the Secretary of State about the death of Rio
Andrew . I am responding as the Minister with portfolio responsibility for patient safety
at the Department of Health.

I was saddened to read of Rio’s death. The death of a young person is always a great loss.
Please pass my condolences to his family.

Your report noted a number of concerns which include the regulation of the private
ambulance company by the Care Quality Commission (CQC), exemptions around
temporary events and regulation of the title ‘ambulance technician’,

With regards to the regulation of the private company by the CQC, the exemption for
temporary arrangements means that the provision of medical assistance at events is
entirely unregulated. This includes not only illegal raves, but legal events such as sporting
events, fetes and festivals.

Although Local Authorities are generally responsible for enforcing health and safety
legislation at events where an event is actually organised by a local authority, the Health
and Safety Executive (HSE) is normally responsible for enforcement. HSE is sponsored
by the Department for Work and Pensions.

To assist in the provision of safe and well run events Local Authorities have Safety
Advisory Groups which
e promote high levels of safety and welfare at events by giving advice and guidance
e promote good practice in safety and welfare planning for events
e ensure events have a minimal adverse impact on the community

The CQC does not regulate the “treatment of disease, disorder or injury” where it is
delivered under temporary arrangements for the purposes of sporting or cultural events.
The rational for this is because the short term nature of such events means system
regulation does not offer an effective mitigation of the risks in the care provided over the
course of the event. In most cases, the event would be over before the CQC would have
chance to inspect it or provided any sort of assurance about the quality and safety of
services provided at the event.

In addition, the costs and requirements of regulation to one-off events, such as village
fetes and similar, would place a disproportionate burden on the organisations wishing to
carry out those events.

The Department has become aware of some permanent established companies that
provide cover at temporary events. These providers deliver services on a year round basis,
to one off events and other social and cultural events. The range of services provided
appears to go some way beyond basic first aid and in some cases involves the delivery of
services by a multi-disciplinary team. The Department is intending to consult later this
year as to whether providers of this sorty should be brought into the scope of regulation by
CQC. The Department is proposing that permanent nature of these providers, as opposed
to the temporary nature of the events they provide services at, does offer sufficient
continuity of service that system regulation by CQC could help mitigate the risks of the
public receiving unsafe care at events.

This proposal would not extend to organisations established on a temporary basis for the
purpose of delivering services at a cultural or sporting event, for the reasons already set
out above.

I note that you have been sent a report from Ri: Life Skills

Medical UK which was, in this case, the Approved Training Centre and Provider of
ambulance service qualifications training. ade a number of
recommendations which he believes would prevent future deaths.

I have asked my officials to review the issues and proposals put forward by Life Skills
Medical UK and discuss them with the relevant bodies (e.g. CQC, Association of
Ambulance Chief Executives) in the light of on-going developments in the field.

I hope that this ¢nforyhgtion is useful. Thank you for bringing the circumstances of Rio’s

death to our attentjon.
(Ces (

BEN G R ——_—