Prevention of Future Deaths reports · 2021

Hamish Howitt

Regulation 28 report to prevent future deaths, reference 2021-0320, written 23 Sep 2021. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report23 Sep 2021
Reference2021-0320
DeceasedHamish Howitt
CoronerFiona King
Coroner areaWest Sussex
CategoryPolice related deaths
Sourcejudiciary.uk record · original PDF
Responses published3

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

Regulation 28: REPORT TO PREVENT FUTURE DEATHS (1) 

NOTE:  This form is to be used after an inquest. 

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO: 

1  Home Office : The Right Honourable Kit Malthouse M.P., Minister for Crime and 

Policing 

2  National Police Chief Council: 
3  College for Policing (Training) 
4  Chief Constable Avon and Somerset Police: 

1  CORONER: 

I am, Fiona M. King, Assistant Coroner for the area of West Sussex 

2  CORONER’S LEGAL POWERS 

I 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 

On 06 June 2018 I commenced an investigation into the death of Hamish John Cameron 
HOWITT aged 20.  Hamish had died in Frome in Somerset on 1st  July 2016 the Investigation 
and subsequent Inquest being transferred in 2018 at the request of his parents who lived in 
West Sussex.  The investigation concluded at the end of the inquest on 22 July 2021.  The 
conclusion of the inquest was that: 

Hamish, a previously fit young university student died unexpectedly overnight following an 
evening spent with friends in Frome going to a concert and drinking.  The medical cause of 
death established that he died from the combined effects of Alcohol, a Traumatic Brain injury 
and self - administered Ketamine.  None of these 3 causes would have individually resulted in 
his death.  The alcohol and ketamine consumed were considered to be at relatively low levels. 

4  CIRCUMSTANCES OF THE DEATH :  While walking home at approximately 23:35 there was 
an altercation on the street in Frome with another group of males.  Hamish immediately 
complained that he was injured and bystanders called the police.  Police Officers attended and 
spoke to Hamish for approximately 7 minutes.  They concluded that Hamish had been 
drinking, was coherent and understood them.  He told them that one of his friends had been 
involved in an incident and that he had intervened to prevent a fight and had been hit in the 
face.  Hamish showed the officers his face and pointed to his forehead.  The Officers recorded 
that they could see no injury.  Concluding that Hamish was suffering the effects of alcohol 
they advised him to go home with his friends, which he did.  Once he returned to 

 he was in pain and before going to bed took an amount of Ketamine that resulted in a 
 of blood. Low therapeutic doses of ketamine in 

post mortem finding of 
a hospital setting were given to be at a waking level average of 
blood.  Ketamine at such a level would not alone have caused death. 

 of 

5  CORONER’S CONCERNS 

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

Regulation 28 – After Inquest
Document Template Updated 30/07/2021 

 
 
 
 The MATTERS OF CONCERN are as follows: 
(brief summary of matters of concern) 
(1) it is highly unlikely that Hamish would have died had he gone to hospital when the police 
saw him after the incident.  Police at the scene did not recommend or encourage this course 
of action. 
(2) The apparent effects of alcohol when assessed by police (who are not medically qualified) 
can frequently mask serious underlying conditions such as traumatic brain injury (in this case) 
but also symptoms of post epileptic attack; diabetic high/low; and drug taking (either 
prescribed or illegally used). 
(3)  Police Officers who come into contact with the public are not medically qualified but must 
be trained at both a national and local level to take steps to ensure those who appear 
inebriated and are complaining of injury are taken to hospital/seen by ambulance services. 
(4) Police training material and national policy setting should include directives to this effect. 

6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I believe you (and/or your 
organisation) have the power to take such action. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report, 
namely by 17th  November, 2021.  I, the 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. 

8  COPIES and PUBLICATION 

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

I am also under a duty to send a copy of your response to the Chief Coroner and all interested 
persons who in my opinion should receive it. 

I may also send a copy of your response to any person who I believe may find it useful or of 
interest. 

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. 

9  Dated: 23/09/2021 

Fiona KING 
for 
West Sussex Coroners Service 

Regulation 28 – After Inquest
Document Template Updated 30/07/2021

Responses

3 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 College of Policing and National Police Chiefs Council (PDF)
Coroner’s Office 
Centenary House 
Durrington Lane 
Worthing  
West Sussex 
BN13 2PQ 

17 November 2021 

Dear 

Regulation 28 Report – Mr Hamish John Cameron Howitt 

We write on behalf of the College of Policing (the College) and National Police Chiefs Council 

(NPCC) in relation to paragraph 7, Schedule 5 of the Coroners and Justice Act 2009, and 

regulations 28 and 29 of the Coroners (Investigations) Regulations 2013, and the prevention of 

future deaths reports sent to the College and to the NPCC, both dated the 23rd September 2021. 

Whilst the College and the NPCC have separate and distinct responsibilities, the two organisations 

frequently work together on national approaches to policing policy. As such, this response is 

provided jointly in respect of both organisations’ separate prevention of future deaths reports. The 

notice sets out concerns that arose from the information received during the inquest in to the death 

of Mr Howitt. We are very sorry to read of the circumstances of Hamish’s death. Our sympathies are 

with his family and friends and we share your commitment to addressing the issues that contributed 

to his untimely loss.  

The notice sets out your principal concerns which were in respect of the recognition of Hamish’s 

condition as a matter requiring a medical response and the ramifications for future first aid training 

provided to police officers. You specifically asked for a response in relation to a number of matters 

of concern in which the College and NPCC would have involvement.  

The College licences the First Aid Learning Programme (FALP) used by Home Office Forces, 

including Avon and Somerset Police. The programme is endorsed by the NPCC and the Health and 

Safety Executive (HSE).  The College is responsible for ensuring appropriate quality assurance 

processes are in place to guide forces in the implementation of the HSE guidelines relating to the 

provision of first aid.  

 
 
 
 
 The FALP has five modules and the national recommendation is that police officers and staff in 

public facing roles receive a minimum of Module 2 training (the equivalent to the qualification of a 

HSE Emergency First Aider) – this is the minimum required for frontline response officers. The 

FALP does include a high level learning outcome for managing head injuries, but this is only a 

requirement in higher modules (Modules 3 - developed for first aid in a custody setting and Module 

4 - the equivalent to the qualification of a HSE First Aid at Work).  

As long as individual forces achieve the learning outcomes contained within the FALP modules they 

will be compliant with the College’s licence. The FALP does include the scope for Chief Officers to 

deliver additional training to their officers but we recognise that the management of head injuries is 

not currently in the standard for Module 2.  With regards to the matter of concern relating to alcohol, 

module 2 includes a high-level learning outcome to enable officers to assess the casualty, and 

modules 3 and 4 address issues of poisoning. However, it is noted that there is no explicit reference 

to the potential impact of alcohol on recognising conditions. 

As a matter of course, all coroner reports and inquests related to the provision of first aid by police 

officers are reviewed by the NPCC First Aid Forum as a standing agenda item. The College is also 

working with clinical leads to review the high-level learning outcomes within the FALP with the aim 

of placing greater emphasis on the training elements that preserve life. The review is already 

considering addressing the issue of acute alcohol intoxication and intentional overdoses within 

Module 2. It is also considering extending the learning in relation to head injuries to Module 2. The 

matters of concern you raise with relation to the impact of alcohol and the assessment of head 

injuries will be raised formally at the next meeting (13th December) to assess whether it is feasible 

and practicable to address these concerns within the scope of the licence.  

Officers are called on to provide first aid in a wide range of incidents as part of their role. The range 

of incidents they attend mean it is not possible or viable for all officers to be trained for all types of 

medical emergencies, or for the FALP to explicitly outline the appropriate medical response in every 

context. That said, as detailed in this response, we acknowledge there is more that we can do to 

standardise our training and I trust that we have provided you with assurances that the matters of 

concern you have raised will be addressed.  

Yours sincerely 

CC 
CEO, College of Policing 

Chair, National Police Chiefs’ Council
Response from Avon and Somerset Constabulary (PDF)
Avon and Somerset Constabulary, Police and Fire HQ, 
PO Box 37, Valley Road, Portishead, Bristol BS20 8QJ 

T/Chief Constable 

16th November 2021 

HM Coroner Fiona King 
County of West Sussex 
C/O Mr Geoff Charnock 
Coroner’s Office 
Centenary House 
Durrington Lane 
Worthing 
West Sussex 
BN132PQ 

Dear Ms King, 

Chief  Constable  of  Avon  and  Somerset  Constabulary’s  Response  to  Regulation  28  Report  to 

Prevent Future Deaths following the Inquest into the death of Hamish Howitt 

1.

I write to respond to your Report to prevent other deaths dated 23 September 2021, in accordance

with paragraph 7, Schedule 5 of the Coroners and Justice Act 2009, and regulations 28 and 29

of the Coroners (Investigations) Regulations 2013.

2. Avon and Somerset Constabulary take the matters raised in your Report extremely seriously, and

careful consideration has been given to your Report and our response to it. I hope that the actions

detailed  below  reflect  the  Constabulary’s  commitment  to  ensuring  that  all  of  the  matters  of

concern and risks identified in your Report are effectively addressed.

3. As explained below, we will continue to keep these matters under review, and to work with the

College  of  Policing  (CoP)  and  National  Police  Chiefs’  Council  (NPCC)  to  ensure  that  any

recommended changes to training, policy and guidance are promptly and fully implemented by

Avon and Somerset Constabulary.

Matters of Concern 

4. The matters of concern identified in your Report have been reviewed by relevant Constabulary

officers, including the force lead for first-aid training. Officers have also met with representatives

of the CoP and the NPCC to discuss these matters.

5. The Constabulary is aware that two police officers encountered Hamish after an altercation on

the street involving the group Hamish was with and another group of males. One police officer

 
 
 gave evidence that he had spoken to Hamish, and noted that it appeared he had been drinking. 

Hamish informed him that he had been hit to his face. The police officer looked at Hamish’s face 

and  could  not  see  any  signs  of  trauma,  and  Hamish  was  not  advised  that  he  should  attend 

hospital. 

6.  Consideration has been given to the statement in your Report that “it is highly unlikely that Hamish 

would have died had he gone to hospital when the police saw him after the incident”. The expert 

medical evidence and your Ruling dated 25 March 2021 following the hearing of expert evidence 

on 25-26 February 2021, as well as your findings and conclusion following the hearing of 19-23 

July 2021 have been re-reviewed. No expert or other medical evidence, or any Ruling, finding or 

conclusion  has  been  identified  which  supports  this  statement,  and  it  has  been  noted  that 

paragraphs 17 and 18 of your Ruling dated 25 March 2021 determined that no further medical 

expert evidence would be obtained. 

7.  Regardless, I share your concern that the effects of alcohol may mask other underlying conditions 

(in  particular  head  injury),  and  that  police  officer  first  aid  training  should  provide  appropriate 

guidance and / or directives in relation to responding to this. 

Position in relation to training 

8.  Avon and Somerset Constabulary officers are provided with first aid training as part of their initial 

training. They are then provided with refresher first aid training on an annual basis. 

9.  The First Aid Learning Programme (FALP) which is used by Avon and Somerset Constabulary to 

train its officers is licensed by the CoP, and endorsed by the NPCC and the Health and Safety 

Executive. Avon and Somerset Constabulary is compliant with the CoP’s licence, and all frontline 

response officers receive a minimum of Module 2 first aid training, as recommended by the CoP. 

10. The FALP Module 2 training includes a requirement for training on casualty assessment. It does 

not currently require specific training on managing head injuries. 

11. Module 3 and Module 4 of the FALP training (which are provided to certain officers in specialist 

roles,  but  are  not  provided  as  standard  to  all  frontline  officers)  does  require  training  on  head 

injuries. All first aid trainers are required to hold a Module 4 qualification. 

12. The FALP training does not currently require training on the potential effect of alcohol in masking 

symptoms of other conditions. 

Actions following Inquest and Report 

 
 
 
 
 
 
 
 
 
 
 
 13. Following the hearing of 19-23 July 2021, and prior to receiving your Report, the Constabulary 

had identified the absence of specific training for frontline officers on head injury as a matter of 

concern, and this issue was under review, which has continued following receipt of your Report. 

14. The following actions have been taken by the Constabulary: 

i. 

An  internal  communications  bulletin  has  been  sent  to  all  officers  which  identified  head 

injuries  as  a  matter  of  concern,  and  provided  a  link  to  “essential  guidance”  on  head 

injuries. This was included in the “Must know” section of the bulletin, which all officers are 

required to read. The linked guidance states that if an officer or staff  member has any 

suspicion, or is told in good faith, that a person may have a head injury, they should treat 

the person as such in the absence of clear evidence to dispel that suspicion. The guidance 

makes clear that no visible marking is not an acceptable level of evidence that a head 

injury has not been sustained. It states that in circumstances involving a potential head 

injury,  medical  assistance  should  be  requested  and  /  or  facilitated  by  officers  (whilst 

acknowledging that officers would not in all circumstances have the power to detain or 

require members of the public to remain and engage with any medical intervention). 

ii. 

All first aid trainers have been sent the essential guidance on head injuries. 

iii. 

The lesson plan for Modules 1, 2 and 4 for “Assess a Casualty (Primary and Secondary 

survey)” has been amended to require this training to provide the same essential guidance 

on head injuries. 

iv. 

The Module 3 and 4 first aid training on head injuries has been amended to incorporate 

the same essential guidance on head injuries. 

v. 

Avon and Somerset Constabulary officers with responsibility for leading force training in 

relation to Taser, Personal Safety Training and Public Order training have also been made 

aware  of  the  Report  and  of  the  first  aid  guidance  on  head  injuries,  which  have  been 

incorporated into their training programmes. 

15. Since receiving your Report, representatives of the Constabulary, including the force lead for first 

aid  training,  have  met  twice  with  CoP  and  NPCC  representatives  to  discuss  the  matters  of 

concern identified and the actions to be taken in response to your Report. 

 
 
 
  
 
  
 
 
 
  
  
 16. The CoP has confirmed that Module 2 FALP training does not currently include the management 

of  head  injuries,  and  that  there  is  no  explicit  reference  in  FALP  training  requirements  to  the 

potential impact of alcohol on recognising conditions. The NPCC and CoP have confirmed that: 

i. 

Your Report will be reviewed by the NPCC First Aid Forum. 

ii. 

The CoP is working with clinical leads to review the high level learning outcomes with the 

aim  of  placing  greater  emphasis  on  the  training  elements  that  preserve  life,  and  is 

presently considering: 

a.  Addressing the issue of acute alcohol intoxication and international overdoses within 

Module 2. 

b.  Extending the learning in relation to head injuries to Module 2. 

iii. 

The matters of concern raised in your report in relation to the impact of alcohol and the 

assessment of head injuries will be raised formally at the next CoP review meeting, and 

consideration will be given to whether and how the matters you have identified can be 

addressed within the scope of the FALP. 

17. It is understood that all matters of concern identified at Part 5 of your Report will be reviewed by 

the NPCC and CoP, including provision of training on head injury, the potential impact of alcohol 

in masking other underlying conditions, and your recommendations in relation to training material 

and national policy setting. 

18. Avon and Somerset Constabulary will update its training provision immediately on receipt of any 

updated guidance from the CoP and / or NPCC. 

19. A copy of this response, and relevant updated force guidance and training documents, will also 

be sent to the CoP and the NPCC so that they are aware of all of the changes that have been 

made internally by Avon and Somerset Constabulary, and can take these into consideration when 

determining whether any additional national guidance, or amendments to training provision are 

required. 

20. We will continue to keep these matters under review, and will work with the CoP and NPCC to 

ensure that any recommended changes to training, policy and guidance are promptly and fully 

implemented by Avon and Somerset Constabulary. 

 
 
 
 
 
 
 
 
  
 
 
 
 
 Summary of Actions Taken and to be Taken 

Action 

Person 

Date 

Responsible 

1 

Circulate memorandum to all officers 

Avon and Somerset 

Completed  

with guidance to ensure they are 

Constabulary First 

14 October 2021 

aware of the risk of head injury and 

Aid Training Lead 

the requirement that medical 

assistance is sought (“the essential 

guidance on head injuries”). 

2 

Send the essential guidance on head 

Avon and Somerset 

Completed 

injuries directly to all first aid trainers. 

Constabulary First 

October 2021 

Aid Training Lead 

3 

Add the essential guidance on head 

Avon and Somerset 

Completed 

injuries to Module 1, 2 and 4 first aid 

Constabulary First 

October 2021 

training for assessing a casualty 

Aid Training Lead 

(provided to all frontline officers). 

4 

Add the essential guidance on head 

Avon and Somerset 

Completed 

injuries to Module 3 and 4 first aid 

Constabulary First 

October 2021 

training on head injuries. 

Aid Training Lead 

5 

Training on appropriate response to 

Leads for Taser, 

Completed 

head injury to be incorporated into 

Public Safety and 

October 2021 

Taser, Public Safety and Public Order 

Public Order 

training. 

training. 

6 

NPCC First Aid Forum to review 

NPCC 

9 December 2021 

Report. 

7 

CoP review of training provision with 

CoP 

Ongoing 

clinical leads, and consideration of 

amendments to scope of FALP to 

address matters raised in Report. 

8 

Update Avon and Somerset 

Avon and Somerset 

To be actioned 

Constabulary first aid training 

Constabulary First 

immediately on 

provision / policy / guidance in 

Aid Training Lead 

receipt of any 

accordance with NPCC / CoP 

updated guidance. 

updated CoP FALP 

training 

requirements and / 

 
 
 
 
 or CoP / NPCC 

policy or guidance. 

Yours sincerely, 

T/Chief Constable 
Avon and Somerset Constabulary  

Avon and Somerset Constabulary Privacy Notice, which relates to the use of personal information, can be viewed via the force website 
https://www.avonandsomerset.police.uk/privacy
Response from Home Office (PDF)
Fiona King 
HM Coroners Service 
County of West Sussex 

Coroner's Office, Worthing 

By email only 

Rt Hon Kit Malthouse MP 
Minister of State for Crime, 
Policing and Probation 
2 Marsham Street 
London SW1P 4DF 

www.gov.uk/home-office 

16 November 2021 

Thank you for your letter of 23 September.  As requested, I am responding to your formal 
report in relation to paragraph 7(2) of Schedule 5 to the Coroners and Justice Act 2009 
and Regulation 29 of The Coroners (Investigations) Regulations 2013. 

I should like to start by expressing my sincerest condolences to the family and friends of 
Hamish John Cameron Howitt on his untimely death. 

The College of Policing is independent from Government and its role is clear: setting high 
professional standards sharing what works best; acting as the national voice of policing; 
and ensuring police training and ethics is of the highest possible quality.  This includes 
setting standards for police training on encountering those with injuries or who are 
otherwise vulnerable. 

My officials have consulted College of Policing and National Police Chiefs Council (NPCC) 
on their response to your report. As mentioned in their joint letter, front line response 
police officers receive training at least equivalent to HSE Emergency First Aider level.  Our 
police are required to deal with a wide range of situations on a daily basis and this includes 
working closely with ambulance services and other medical colleagues when responding 
to certain medical incidents, where appropriate.  

The College continually reviews the content of the curriculum for officers and I am assured 
that the concerns you have raised will be addressed through the formal policing First Aid 
governance routes. 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 I should like to thank you for bringing this issue to my attention.  

Rt Hon Kit Malthouse MP

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