Prevention of Future Deaths reports · 2022

Marjorie Walker

Regulation 28 report to prevent future deaths, reference 2022-0176, written 15 Jun 2022. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report15 Jun 2022
Reference2022-0176
DeceasedMarjorie Walker
CoronerAlison Mutch
Coroner areaManchester South
CategoryHospital Death (Clinical Procedures and medical management) related deaths · Alcohol, drug and medication related deaths
Sourcejudiciary.uk record · original PDF
Responses published2

The report

Text extracted from the PDF text layer. 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) Secretary of State for Health and 
Social Care; 2) Greater Manchester Health and Social Care Partnership 

1  CORONER 

I am Alison Mutch, Senior Coroner, for the Coroner Area of Greater 
Manchester South 

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 28th  May 2020 I commenced an investigation into the death of 
Marjorie Walker. The inquest concluded on the 3rd  March 2022 and the 
conclusion was one of: Narrative: Died from a combination of natural 
causes contributed to by a toxic level of prescribed medication 
given in hospital and neglect. 

The medical cause of death was: 1a) Combined effects of gabapentin, 
morphine, buprenorphine on a background of congestive cardiac 
failure, chronic renal failure, chronic obstructive pulmonary disease, 
bronchopneumonia, cerebrovascular disease and hyperkalaemia 

4  CIRCUMSTANCES OF THE DEATH 

Marjorie Walker had a significant number of co-morbidities. She was on 
pain relief in the community including Fentanyl and liquid Morphine (for 
breakthrough pain). She had reacted poorly to an increase in opioid 
based pain relief in the community. She was admitted to Tameside 
General Hospital with a significantly raised INR. Whilst an inpatient she 
was prescribed Gabapentin 
2020 she was transferred to the Stamford Unit. Whilst on the unit she had 
a series of falls. The second fall necessitated her going to the Emergency 
Department at Tameside General Hospital. Tests there indicated she had 
an acute kidney injury in addition to chronic kidney disease. She returned 
to the Stamford Unit and then back on 22nd  May 2020 to Tameside 
General Hospital due to a further raised INR. The Gabapentin continued 

 On 18th  May 

1 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 to be given at the previous dosage because it was not recognised by any 
of the treating clinicians or the hospital pharmacy review that it needed to 
be reduced because of her reduced kidney function. The increased risk of 
toxicity was not recognised. On 22nd  May 2020 at the Stamford Unit her 
Fentanyl patch was changed to a Buprenorphine patch. Her Morphine 
Sulphate oral prescription was not changed to reflect the amendment in 
the amount of opioid being delivered through the patch. That she was on 
too high a dose was not recognised by the clinicians on the Stamford 
Unit, the clinicians on her return to Tameside General Hospital or at the 
hospital pharmacy review at Tameside General Hospital. Her raised 
potassium level on 26th  May 2020 was not acted on for reasons that were 
unclear. On 27th  May 2020 she was found unresponsive in her bed at 
Tameside General Hospital. CPR was not given because a DNA CPR 
was in place. The DNA CPR had not been completed in accordance with 
the Trust's protocol. Post Mortem examination included toxicology. The 
toxicologist found that Gabapentin was present at an above therapeutic 
level and at a level that is encountered in fatalities. Morphine and 
Buprenorphine that she was prescribed were also found. 

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.  The inquest heard evidence that despite the consequences for a 
patient of a DNA CPR it had not been completed in accordance 
with protocols. The inquest heard evidence that the importance of 
well documented and correctly completed paperwork in relation to 
DNA CPR was important in all cases but particularly in relation to 
vulnerable members of the community such as Mrs Walker; 

2.  Mrs Walker had lived with significant chronic pain for many years. 

Evidence was heard that she would have benefited from an 
appointment with a pain clinic for specialist input and the risks 
around pain medication could have been reduced with specialist 
input. The inquest heard that there were significant delays in 
accessing specialist pain clinics due to demand and capacity 
issues across the NHS; 

3.  Mrs Walker was prescribed Gabapentin as part of helping her to 
manage her chronic pain. The evidence was that the use of pain 
medication such as Gabapentin carried risk particularly in relation 
to a patient with underlying kidney issues. The inquest was told 
that a lack of understanding and recognition of monitoring kidney 
function including clearance results by health professionals 
including pharmacists and doctors alongside prescribing created a 
risk of overdose particularly of vulnerable patients. The inquest 
was told that the risk would be reduced by greater ease of access 
to results, more robust checking and education. 

2 

 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I 
believe you 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 10th  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 
 on behalf of the family; 
Interested Persons namely 1) 
2) Tameside General Hospital, who may find it useful or of interest. 

I 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. 

9 

Alison Mutch OBE 
HM Senior Coroner 

15.06.22 

3

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 Department of Health and Social Care (PDF)
From Neil O’Brien MP 
Parliamentary Under Secretary of State for Primary Care and Public Health 

39 Victoria Street 
London 
SW1H 0EU 

Ms Alison Mutch 
Senior Coroner 
Manchester South 
1 Mount Tabor Street 
Stockport  
SK1 3AG 

Dear Ms Mutch, 

23 January 2023 

Thank you for your letter of 15 June 2022 about the death of Mrs Marjorie Walker.  I am replying as 
Minister  with  responsibility  for  Primary  Care  and  Public  Health  at  the  Department  of  Health  and 
Social Care. 

Firstly,  I  would  like  to  offer  my  sincere  condolences  to  the  family  of  Mrs  Walker.    I  was  very 
saddened  to  read  the  circumstances  of  her  death  and  I  am  grateful  to  you  for  bringing  these 
matters to my attention.  

In  preparing  this  response,  Departmental  officials  have  made  enquiries  with  NHS  England,  the 
Medicines and Healthcare products Regulatory Agency (MHRA) and the Care Quality Commission 
(CQC). 

Regarding  your  concern  about  significant  delays  to  access  specialist  pain  clinics,  the  pandemic 
has  put  enormous  pressures  on  the  NHS  with  elective  waiting  lists  growing  to  over  7  million 
patients, but we remain committed to ensuring people get the right care at the right time.  That is 
why we are delivering record staffing numbers, and putting in record levels of funding, to help the 
NHS recover and transform services.  Having virtually met our target to eliminate long waits of two 
years  or  more  for  elective  procedures  in  July  2022,  our  next  ambition  is  to  eliminate  waits  of 
eighteen months or more by April 2023. 

To support this elective recovery, the government plans to spend more than £8 billion from 2022-
23  to  2024-25,  in  addition  to  the  £2  billion  Elective  Recovery  Fund  and  £700  million  Targeted 
Investment Fund already made available to systems last financial year, to help drive up and protect 
elective  activity.    Taken  together,  this  funding  could  deliver  the  equivalent  of  around  nine  million 
more  checks  and  procedures  and  will  mean  the  NHS  in  England can  aim  to  deliver  around  30% 
more elective activity by 2024-25 than before the pandemic.  

A  significant  part  of  this  funding  will  be  invested  in  staff,  both  in  terms  of  capacity  and  skills.  
However, the Department has also committed to a £5.9 billion investment in capital for new beds, 
equipment and technology.  The Department will also continue to work closely with NHS England 
to  deliver  the  ‘Delivery  Plan  for  Tackling  the  COVID-19  Backlog  of  Elective  Care’,  providing  the 
necessary support and challenge to make sure it benefits patients and delivers value for money. 

Turning  specifically  to  pain  clinics,  it  is  within  the  remit  of  Integrated  Care  Boards  (ICBs)  to 
commission services within their geographical area and NHS England expects ICBs to commission 
appropriate  services  to  meet  the  needs  of  the  population  they  serve,  including  services  that  can 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 support people with chronic pain.  NHS England is only responsible for the commissioning of highly 
specialist  pain  services  in  line  with  a  published  service  specification.1 There  are  currently  eight 
adult  NHS  England  specialist  pain  providers  and  access  to  these  will  depend  on  meeting  the 
eligibility criteria. 

Your  other  concern  addressed  a  lack  of  understanding  and  recognition  of  monitoring  kidney 
function, including clearance of test results by pharmacists and doctors alongside prescribing, that 
created a risk of overdose particularly in vulnerable patients.  You may wish to know that the NHS 
Medicines  Safety  Improvement  Programme,  which  forms  a  key  part  of  the  NHS  Patient  Safety 
Strategy, has launched a focussed programme of work relating to the improved care of people with 
chronic pain and a reduction in the use of prescribed opioids.2  The programme has been in place 
since  January  2021  and  is  supporting  Integrated  Care  Systems  to  learn  from,  adapt  and  adopt 
effective practice using a whole-system improvement approach.  As of 2022/23, 18 Integrated Care 
Systems  are  receiving  intensive  support  to  develop  and  implement  improvements  in  care  and  a 
further 15 are participating in shared learning events. 

In  addition,  the  National  Overprescribing  Review  report  evaluated  the  extent,  causes  and 
consequences  of  overprescribing  and  made  20  recommendations  to  address  it.3   Led  by  NHS 
England,  a  cross-organisational  implementation  programme  brings  together  lead  organisations, 
along  with  partners  from  across  the  health  system,  to  implement  the  review’s  recommendations.  
The programme aims to achieve long term sustainable reductions to overprescribing via delivery of 
systemic  and  cultural  improvements  within  the  NHS.    One  of  the  key  deliverables  of  the 
programme is a national resource to help practices improve the consistency of repeat prescribing 
processes  and  supported  by  appropriate  training.    Additionally,  as  part  of  the  Dependence  and 
Withdrawal  Forming  Prescribed  Medicines  Implementation  programme,  the  National  Institute  for 
Health  and  care  Excellence  (NICE)  has  published  guidance  on  Chronic  pain  assessment  and 
management.4 

Further to this, the MHRA monitors the safety of medicines and endeavours to ensure that up-to-
date  information  on  the  benefits  and  risks  of  a medicine  is  available for  healthcare  professionals 
and  patients.    The  Summary  of  Product  Characteristics  (SmPC)  for  a  medicine  provides 
information  for  healthcare  professionals  (HCPs)  about  the  medicine,  including  warnings  and 
precautions of use in higher risk situations.  Gabapentin is a controlled medicine under the Misuse 
of Drugs Regulations 2012 and is regularly reviewed for signals of adverse effects to be included in 
the SmPC.  The current SmPC for gabapentin contains detailed guidance on the administration of 
gabapentin  in  patients  with  compromised  renal  function  and  /  or  those  on  haemodialysis.    The 
MHRA  also  published a Drug  Safety  Update  article  in  2019,  concerning prescribing  medicines  in 
renal impairment.5 

Also  in  2019,  the  MHRA  sought  advice  from  the  Opioids  Expert  Working  Group  (EWG)  of  the 
Commission on Human Medicines on the risks of dependence to opioids in the treatment of non-
cancer  pain.    The  review  included  an  examination  of  worldwide  clinical  guidance  on  dose 
recommendations  where  risks  exceed  benefits,  and  the  available evidence on conversion  factors 
and  calculations  for  the  different  opioids  into  morphine  equivalent  values.    The  EWG  concluded 
that  available  values  are  not  precise  as  they  can  be  influenced  by  the  individual  patient  past 
experience of opioid use as a patient can develop tolerance to their opioid medicine.  The issue of 
tolerance has been reflected in the SmPC.  The MHRA worked closely with the Faculty of Pain and 
the  issues  of  tolerance  and  dose  calculation  has  been  highlighted  in  the  Opioids  Aware  pages.  

1 https://www.england.nhs.uk/publication/adult-highly-specialist-pain-management-services/  
2 https://www.england.nhs.uk/patient-safety/patient-safety-improvement-programmes/#MedSIP  
3 https://www.gov.uk/government/publications/national-overprescribing-review-report  
4 https://www.nice.org.uk/guidance/NG193  
5 Drug Safety Update volume 13, issue 3: October 2019: 3. 

 
 
 
 
 
 
 
 
 The  British  National  Formulary  and  the  Opioids  Aware  pages  provide  approximate  conversion 
values to enable calculation of an appropriate dose to be used with a recommendation that a lower 
dose be used when switching between opioids. 

The MHRA also issued a Drug Safety Update article for pregabalin, which is similar to gabapentin 
in its mechanism of action and side effects.  The article highlights a European review of all reports 
of  severe  respiratory  depression  thought  to  be  associated  with  pregabalin  alone.    Therefore, 
healthcare professionals were advised to consider dose adjustments in patients at a higher risk of 
respiratory depression, such as those with compromised respiratory function or renal impairment.6 

Finally, the MHRA continue to monitor the benefits and risks of gabapentin and opioid medicines 
and  will  take  further  prompt  regulatory  action  when  needed  to  ensure  that  product  information  is 
clear and consistent. 

I hope this response is helpful. Thank you for bringing these concerns to my attention.  

NEIL O'BRIEN 

6 Drug Safety Update volume 14, issue 7: February 2021: 2
Response from Greater Manchester Integrated Care (PDF)
Date: 9th August 2022 

Ms A Mutch  
HM Senior Coroner 
Coroner’s Court  
1 Mount Tabor  Street  
Stockport  
SK1 3AG 

Dear Ms Mutch 

Re: Regulation 28 Report to Prevent Future Deaths – Marjorie Walker 27/05/20 

Thank you for your Regulation 28 Report dated 15/06/22 concerning the sad death of Marjorie Walker on 
27/05/20. On behalf of NHS Greater Manchester Integrated Care (NHS GM), I would like to begin by 
offering our sincere condolences to Ms Walkers family for their loss. 

Thank you for highlighting your concerns during Ms Walkers Inquest which concluded on 3 March 2022. 
On behalf of NHS GM, I apologise that you have had to bring these matters of concern to our attention 
but it is also very important to ensure we make the necessary improvements to the quality and safety of 
future services.   

The inquest concluded that Marjorie’s death was a result of 1a) Combined effects of gabapentin, 
morphine, buprenorphine on a background of congestive cardiac failure, chronic renal failure, chronic 
obstructive pulmonary disease, bronchopneumonia, cerebrovascular disease and hyperkalaemia. 
Following the inquest, you raised concerns in your Regulation 28 Report to NHS GM that there is a risk 
future deaths will occur unless action is taken. 

I hope the response below demonstrates to you and Ms Walker’s family that NHS GM has taken the 
concerns you have raised seriously and will learn from this as a whole system.  

This letter addresses the issues that fall within the remit of NHSGM and how we can share the learning 
from this case. 

Completion of DNACPR documentation 
Following the trust’s own investigation, the findings were presented to the Surgical PASQAF and Grand 
Round. This is a learning forum attended by all clinical staff across all divisions of the organisation.  
Electronic white boards have been introduced in all patient areas which assist in improving oversight of 
patient needs, flow and bed capacity and highlighting concerns through a control centre. Patient safety 
information including falls risk, nutritional needs and medical conditions can also be highlighted using the 
boards. DNACPR status is included within the options available for staff. 
Using the DNACPR feature allows clinical teams to identify where one is in place or where one may be 
required. This is discussed within safety huddles in each clinical area at the start of each shift. These 
statuses can be updated at any time supporting early identification of patients admitted who may not 
have had such decisions made in the community, or whose condition may have changed necessi tating 
consideration of this. 

A trust-wide DNACPR audit took place in February and March 2022 with actions identified around 

4th Floor, Piccadilly Place, Manchester  M1 3BN   
Tel: 0161 6257791  www.gmintegratedcare.org.uk 

 
  
   
 
 
 
 
 
 
 
 
 
 
 
 DNACPR discussion and completion of appropriate documentation. The findings were presented to the 
Trust Deteriorating Patient Group and Mortality Steering Group. A medical lead has been appointed to 
support the identified actions and strengthen the overall process. This has included reviewing the e -
learning modules which support DNACPR training. This training will be made  available to all medical 
staff and the specialist palliative care nursing team. 

Access to specialist pain clinics 
Provision of pain management services are within the standard contract. This is agreed at a national 
level with no specification for this area. A contracted plan is agreed at the start of each financial year to 
include activity for patients who require inpatient care, clinical interventions on a day case basis and 
specialist management and review in outpatient clinics. 

Patients who have two or more long term conditions (including COPD and heart failure), are eligible for 
referral to the Trust Extensive Care Team. This is a specialist team for patients with long term conditions 
focused on living independently, managing their condition to avoid hospital admission, which may have 
also identified that specialist advice relating to pain management may have been beneficial.  

Within Tameside there is a single commissioning function for health and social care. There are strong 
links between the five neighborhoods or primary care networks and the trust. The trust is currently 
discussing how best to share the learning from this inquest with GP partners, including facilitated 
discussion about best practice and available services. 

Understanding of risks associated with gabapentin usage 
In response to the missed opportunities to appreciate the dose of morphine and gabapentin in relation to 
the reduced kidney function, the trust completed a baseline analgesic dosing audit in 2021. A re -audit 
was undertaken following the introduction of new medication charts in December 2021. The audit was 
reviewed by the Medicines Safety Group and Pharmacy Governance and further learning identified and 
actioned. A Pharmacy Safe Bulletin has been distributed to Multidisciplinar y Teams. A presentation was 
also provided to the Trust wide Grand Round.  

Actions taken or being taken to share learning across Greater Manchester.  

1.  Learning to be presented/shared with the Greater Manchester System Quality Group.  This 
meeting is attended by commissioners, including commissioners of specialist services, 
regulators, Healthwatch and NICE. 

2.  Shared learning from this and similar cases at Greater Manchester and borough level will be 

cascaded to professionals through relevant governance and learning forums. 

In conclusion, key learning points and recommendations will be monitored to ensure they are embedded 
within practice. NHS GM is committed to improving outcomes for the population of Greater Manchester.  

I hope this response demonstrates to you and Ms Walkers’ family that NHS GM has taken the concerns 
you have raised seriously and is committed to work together as a system including our service users, 
carers  and families to improve the care provided.  

Thank you for bringing these important patient safety issues to my attention and please do not hesitate 
to contact me should you need any further information. 

4th Floor, Piccadilly Place, Manchester  M1 3BN   
Tel: 0161 6257791  www.gmintegratedcare.org.uk 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 Yours sincerely 

Interim Chief Nurse 
GM Integrated Care 

4th Floor, Piccadilly Place, Manchester  M1 3BN   
Tel: 0161 6257791  www.gmintegratedcare.org.uk

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