Prevention of Future Deaths reports · 2022

Jennifer Dyer

Regulation 28 report to prevent future deaths, reference 2022-0168, written 9 Jun 2022. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report9 Jun 2022
Reference2022-0168
DeceasedJennifer Dyer
CoronerJames Healy-Pratt
Coroner areaEast Sussex
CategoryRoad (Highways Safety) related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

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

Regulation 28: REPORT TO PREVENT FUTURE DEATHS 

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

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO: 

1 

, Chief Executive of East Sussex County Council 

1  CORONER 

I am James HEALY-PRATT, Assistant Coroner for the coroner area of East 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 01 April 2021 I commenced an investigation into the death of Jennifer Ann DYER aged 
36. The investigation concluded at the end of the inquest on 12 May 2022.  The conclusion
of the inquest was that:

This young lady and mother lost her life due to a collision between her bicycle and a van. 
That collision was solely and proximately caused by a defective pothole, 58mm deep, in the 
road surface of the B2188, Cherry, Gardens Hill, Groombridge. Her death was avoidable. 

4  CIRCUMSTANCES OF THE DEATH 

This young woman was catapulted from her bicycle when it hit a pothole, camouflaged by 
dappled sunlight and tree branch shadows. The pothole was 0.45m by 0.80m at its widest 
and broadest, and 5.8cm at its deepest point. The pothole evidenced a history of failed 
repairs since late 2019, with numerous concerns being raised about the continuing danger 
that it posed to road users, especially motorbikes and bicycles. The Sussex Police Forensic 
Reconstruction Report FC1/012/21 concluded that it was highly likely that the collision was 
as a result of the defect to the road, and the pothole specifically. 

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. 

The MATTERS OF CONCERN are as follows: 
(brief summary of matters of concern) 

Under the East Sussex Highway Asset Inspection Manual, this pothole fell within the 
definition of Cat 3 - LOW for risk and remedial works. The definition is “Greater than 40mm 
and less than 59mm deep and at least 300mm in all directions”. Clearly, this pothole was 
the proximate cause of the death of a young woman, and the categorisation of potholes in 
East Sussex requires significant review, to prevent future avoidable deaths within the 
County. 

6  ACTION SHOULD BE TAKEN 

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

 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 5 August 2022.  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 have also sent it to 

who may find it useful or of interest. 

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: 09/06/2022 

James HEALY-PRATT 
Assistant Coroner for 
East Sussex 

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

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 East Sussex County Council (PDF)
REGULATION 28:  REPORT TO PREVENT FUTURE DEATHS 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

James Healy-Pratt, Assistant Coroner, for the coroner area of East Sussex, in 
response to a Regulation 28 Report to Prevent Future Deaths following an inquest 
hearing into the death of Jennifer Dyer on 29 March 2021. 

1 

EAST SUSSEX COUNTY COUNCIL 

I am 
County Council, St Anne’s Crescent, Lewes, BN7 1UE 

, Director of Communities, Economy and Transport, East Sussex 

2 

CORONER’S MATTERS OF CONCERN 

The MATTERS OF CONCERN were identified as follows: – 

Under the East Sussex Highway Asset Inspection Manual, this pothole fell within the 
definition of Cat 3 - LOW for risk and remedial works. The definition is “Greater than 
40mm and less than 59mm deep and at least 300mm in all directions”. Clearly, this 
pothole was the proximate cause of the death of a young woman, and the categorisation 
of potholes in East Sussex requires significant review, to prevent future avoidable 
deaths within the County. 

3 

Background Information 

Safety Inspections & Repairs 

Under section 41 of The Highways Act 1980, it is East Sussex County Council’s (the 
Council) statutory duty as the highway authority to keep the highway network safe for all 
highway users. 

Like most local highway authorities, the Council uses The Well-Managed Highways 
Infrastructure: A Code of Practice (the Code) to guide maintenance policies and 
practices in manging the highway network it is responsible for. This recommends a risk-
based approach is used for highway infrastructure maintenance and to set levels of 
service for inspections, responses, resilience, priorities and programmes.  

Based on the Code and intervention level policies approved by the Councils Lead 
Member for Transport and Environment, the Councils Highway Asset Inspection Manual 
sets out how the authority has assessed risk and manages defects on the road network 
to fulfil its statutory requirements to maintain a safe, serviceable and resilient network. 
The manual sets out intervention levels based on size and depth of potholes to enable 
the Council to target limited resources effectively and manage its liabilities. For 
carriageway potholes they are: 

Category 1: Greater than 100mm and at least 300mm wide in all directions - Made Safe 
within 2 hours 

Category 2: Greater than 60mm and less than 99mm deep and at least 300mm in all 
directions - Repaired within 5 days 

Category 3: Greater than 40mm and less than 59mm deep and at least 300mm in all 
directions - Repaired within 28 days 

1

 Dedicated Cycleways 

In addition to the inspection of roads, within the Highways Inspection Manual there is a 
hierarchy for inspection and repair of specifically recognised cycleways that reflects the 
differing risks associated with shared, partially segregated and fully segregated cycle 
routes. 

4 

Supporting Information 

Enhanced Risk based approach 

In May 2021 a revised Highway Inspection Manual introduced an enhanced risk 
assessment process where the highway inspector can consider other factors, such as 
the location of a defect and usage, as well as the defect category in determining whether 
a response is required or a different response time required. This means that, following 
the risk assessment, they are able to change the category of a defect such as changing 
a non-intervention defect to an intervention defect or reduce or increase the category 
response time if deemed appropriate. For example, if a category 3 pothole is located on 
the part of the carriageway cyclists are likely to use such as the nearside edge, this 
could be increased to a category 2 or 1 depending on risk assessment. 

To introduce this change, inspection staff were assessed in line with the UK Roads 
Liaison Group’s Asset Management Competence Framework and a programme of 
suitable training was developed to ensure the relevant officers were fully competent in 
their roles ahead of implementation of this policy. 

Regular reviews are held with all staff involved with inspections and the risk based 
approach to ensure it is being applied consistently.  

Cycleway Hierarchy and Road Maintenance 

In addition, following changes to the Highway Code introduced earlier this year, the 
Council have further researched best practice around cycling hierarchy, defect 
management and prioritisation of cycleway maintenance and road repairs. The Council 
are currently considering a number of potential actions that could be developed and 
costed to determine what additions or improvements can be incorporated to the current 
process. These includes: 

-  Asset plan for cycling that includes a further risk based weighting for 

prioritisation on roads where cycling is known to be popular 

-  Opportunities for improved public reporting of defects likely to impact cyclists to 

enhance our own inspections 

-  Consideration of an increased list of defects in investigatory matrix, for example 

surface with loose gravel, pothole with sharp upstand, poor drainage and 
standing water that may impact cyclists 
-  Winter maintenance of dedicated cycleways   
-  A joined up approach to cycle route maintenance with organisations outside 

- 

ESCC that also manage cycleways 
Improved cycle route hierarchy; research in collaboration with cycling groups to 
gain data on most popular cycle routes across the county 
-  Walked or cycled inspections for all dedicated cycleways 

5 

DETAILS OF ACTION TAKEN  

Since the tragic incident on 29 March 2021, the Council has introduced an enhanced 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 risk based approach to its safety inspection regimes which allows for a more flexible 
approach to determining risk for all road users and defect response times. This enables 
the inspector to change the categorisation of a pothole to include potholes for repair that 
do not meet the lowest category if required or to change the category of a pothole to a 
medium or high risk following an onsite risk assessment that now also considers location 
and road usage in addition to size and depth.  

Whilst this process was not in place at the time the pothole in this incident was identified 
and categorised, by introducing this new process, the Council believes that a specific 
review of the pothole categories is not required.  

Following the incident, the pothole was repaired the same day and the road was 
reinspected for other potholes.   

A separate review is underway to be completed by August to consider the 
circumstances of this specific case and in particular if there are any lessons to be learnt 
to further improve the service.   

6 

DETAILS OF FURTHER ACTION PROPOSED 

In response to the Coroner raising the above matters of concern, the Council will: 

-  Continue to review the effectiveness of the implemented enhanced risk based 

approach and in particular review how it would have affected this case 

-  Continue further research and consideration of cycleway hierarchy and cycle 
route maintenance in line with best practice and neighbouring authorities, 
including costing and trialling if required of the improvements/additions set out in 
section 4.  

7 

SAFETY OF ROAD USERS 

The Council is committed to improving communication with road users and improving 
the safety of the roads. The death of Jennifer Dyer is a tragic loss and the Council offer 
its’ sincere condolences to Ms Dyer’s family. 

8 

Signed:   

02/08/2022 

, Director of Communities, Economy and Transport 

3

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