Prevention of Future Deaths reports · 2022

Kane Davidson

Regulation 28 report to prevent future deaths, reference 2022-0230, written 26 Jul 2022. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report26 Jul 2022
Reference2022-0230
DeceasedKane Davidson
CoronerEdward Morgan
Coroner areaManchester North
CategoryOther 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 (1) 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

1. The Chief Executive Oldham Council

2. The Director of Housing Oldham Council

1 

CORONER 

I am Dr Edward Morgan QC Assistant Coroner for the Coroner area of Manchester North 

2 

CORONER’S LEGAL POWERS 

I  make  this  report  under  paragraph  7,  Schedule  5,  of  the  Coroner’s  and  Justice  Act  2009  and 
Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013 

3 

INVESTIGATION and INQUEST 

On 9 February 2022, Mr Matthew Cox, Assistant Coroner commenced an investigation into the death 
of Kane Thomas Harley Davidson. 

4 

CIRCUMSTANCES OF DEATH 

On 28 January 2022, Kane Thomas Harley Davidson (Kane) was found unresponsive in the bedroom 
of his family home address 

  Following  attendance  of  the  emergency  services,  he  was  transported  to  Royal  Oldham 
Hospital. Clinical assessment rendered it necessary that Kane was transferred for specialist care at 
Royal  Manchester Children's Hospital. Despite the sustained efforts of specialist clinicians, it was 
apparent that Kane had suffered extensive "widespread diffuse hypoxia pattern of ischaemic brain 
injury".  Kane's  physical  condition  declined  and  he  sadly  died  on  1  February  2022.  There  is  no 
evidence of suspicious circumstances or third party involvement in his death. 

At the material time, the family lived in a privately rented property. The letting was managed on behalf 
of  the  landlord  by  professional  letting  agents.  Prior  to  entering  into  that  letting  arrangement,  the 
landlord had applied for and obtained a private licence from the Local Authority pursuant to section 
88 of the Housing Act 2004. The licence was issued without prior inspection or audit of the proposed 
rental  property.  The  issue  of  such  a  licence  is  predicated  upon  the  basis  that  the  landlord  or 
appropriate licensed individual would continue to maintain the premises in a condition of safety from 
material hazards. 

The  window  blinds  at  the  property  had-according  to the  landlord-been  in  situ for  many  years  and 
before  the  date  that  Kane  and  his  family  moved  into  the  property.  They  were  not  the  subject  of 
assessment  for  risk  or  review  in  advance  of  the  residential  letting  arrangement  to  which  Kane's 
parents were parties. The window blinds were not compliant with the British Standard EN13120 in 
that they did not incorporate the necessary safety features as required by those standards. Those 
standards are applicable, inter alia, to those homes where children under the age of 42 months are 
likely to be present. 

 
 5 

CORONER’S CONCERNS 
In  the  conduct  of  this  Inquest,  the  Court  received  evidence  which  pointed  to  a  serious  matter  of 
concern. In such circumstances, it is my statutory duty to report those concerns to you. 

The matters of concern are as follows: 

1.  The  council  has  resolved  to  establish  and  implement  a  regime  of  landlord  license  registration 
pursuant to, inter alia, section 88 of the Housing Act 2004.  

2. The resultant application process culminates in the grant of a license without any prior audit of the 
landlord's premises. 

3.  Where  an  audit  of  residential  property  is  undertaken,  there  is  no  express  obligation  upon  the 
person conducting the audit or assessment to refer to other risks to which children might be exposed, 
including, those posed by internal blinds.  

4. This remains the position notwithstanding the fact that the council was on notice of such risk and 
indeed had issued guidance to those undertaking inspections. The nature and character of the risk 
posed by such equipment was not accommodated within any documentation to which the Court has 
been given access. 

5. There is an absence of clarity as to the enforcement action, if any, to be taken by the Council in 
the event of a licence holder failing to comply with the conditions of the licence. 

6. The form of certificate issued to Landlords does not make sufficiently clear to actual or prospective 
tenants: 

(1)  that the  issue  of the  certificate  cannot  and should  not  be  taken  as  an  endorsement  of the 

premises to which the certificate relates;  

(2)  that the premises to which the certificate relates and/or in respect of which the landlord is 

licensed should not be assumed to be compliant with the relevant safety standards. 

7. The conditions of licence are insufficiently clear in communicating the obligations upon the 
licence landlord and/or that the landlord remains personally liable for compliance with the licence 
conditions notwithstanding the use of any intermediary letting agency.  

6 

ACTION SHOULD BE TAKEN 

In  my  opinion  action  should  be  taken  to  prevent  future  deaths  and  I  believe  each  of  you 
respectively 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 20 
September 2022 I, the Assistant 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 namely:- 

1.  Kane’s Family;  
2.  The Child Accident Prevention Trust.  

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 from. 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. 

- 

Date:    26 July 2022                         Signed:

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 for Levelling Up Housing Communities (PDF)
The Rt Hon Simon Clarke MP 
Secretary of State for Levelling up Housing & 
Communities  

Department for Levelling Up, Housing and 
Communities  
4th Floor, Fry Building 
2 Marsham Street 
London SW1P 4DF 

Dr Edward Morgan 
HM Coroner - Manchester North 
HM Coroner's Court  
Floors 2 & 3  
Newgate 
Rochdale 
Lancashire 
OL16 1AT 

30 September 2022 

Thank you for your Regulation 28 Report of 27 July 2022. I’m deeply sorry to hear of Kane Davidson’s 
death and my sympathies are with his family. I am of course reminded of two similar tragic incidents 
that occurred in the last few years. I take the health and safety of all people, and children in particular, 
very seriously and therefore thank you for raising this important matter with me. 

Having  considered  this  issue  extremely  carefully,  however,  I  am  not  of  the  view  that  new  legal 
requirements on the private rented sector will achieve the outcomes we desire – namely the removal 
of dangerous looped blind cords from all residential accommodation as soon as possible. This is an 
issue that affects people in homes of all tenures, not just private renters.  

Instead,  I  believe  that  campaigns  to  raise  awareness  of  this  issue  are  the  key.  This  is  why  my 
department has supported the work done by the Office for Product Safety and Standards (OPSS), at 
the  Department  of  Business,  Energy  and  Industrial  Strategy  (BEIS),  who  have  responsibility  for 
regulation  of  the  safety  of  consumer  products  like  window  blinds.  The  Government,  through  OPSS, 
continue to fund the Royal Society for the Prevention of Accidents (RoSPA) to raise awareness of safety 
risks,  including  the  importance  of  noting  warnings  and  following  safety  instructions  where  they  are 
included. 

RoSPA are leading a campaign, supported by the Government, to highlight the potential dangers of 
looped blind cords, particularly among families with small children. Their ‘Make It Safe’ campaign along 
with safety information is available at https://www.rospa.com/campaigns-fundraising/current/blind-cord. 
My officials have worked with their colleagues at OPSS to further publicise this campaign, through our 
newsletters to landlords and local authorities and our suite of guides for private rented sector landlords 
and  tenants  (https://www.gov.uk/government/collections/housing-how-to-guides)  that  cover  safety  in 
rented properties.  

I will provide my full support to reviewing these campaigns and have asked my officials to consider how 
to strengthen their reach so that this message is seen and understood by everyone, including tenants, 
landlords and their agents. I hope that this letter assures you that the government takes this matter very 
seriously.  

RT HON SIMON CLARKE MP 
Secretary of State for Department for Levelling up, Housing and Communities
Response from Oldham Council (PDF)
From: 
Sent: Fri Sep 16 10:28:13 BST 2022 
To: 
Subject: Re: Regulation 28 notification - Coroners Office 

:CAUTION: This email originated from outside of the organisation. Do not click links or open attachments unless you recognise 
the sender and know the content is safe. 

Dear Dr Edward Morgan QC, 

I would like to take this opportunity to formally respond to your Regulation 28 report dated to prevent 
future deaths dated 26th July 2022, relating to the tragic circumstances surrounding the death of Kane 
Thomas Harley Davidson.     

As background, I can confirm that the Council implemented a Selective Licensing Scheme for privately 
rented properties in 2015 and that lasted for 5 years. This scheme only applied to certain selected areas 
of the Borough and required landlords with rental properties to apply for a licence. 

The Council has recently reintroduced a new scheme in July 2022, that again covers certain areas of the 
Borough and requires all landlords in these areas to apply and pay for a licence. All the procedures 
implemented as part of these  schemes, including the granting of a licence without any prior audit of the 
landlord's premises were carried out in accordance with the Housing Act 2004 provisions. 

The selective licensing scheme doesn't require the Council to carry out an audit of every property that is 
licensed and the scheme only covers a percentage of privately rented properties in Oldham, therefore 
there will be many more privately rented properties that the Council is unaware of and therefore won't be 
able to give advice on blind cord safety or check that they comply. There are also a large number of Local 
Authorities that do not have a licensing scheme in their location making tackling this issue potentially 
national issue in the privately rented sector. Can I suggest that as part of your considerations it should be 
highlighted to the Government's Department of Levelling Up, Housing and Communities (DLUCH) the 
dangers and inconsistency across the Country without national legislative intervention. 

I can confirm that here in Oldham the Council has already made the following improvements in response 
to your notification and as part of the paperwork issued as part of the Licensing scheme :-

•  The wording on the licence has been amended to make it clear that the licence holder is 

responsible for adhering to the licence conditions as well as ensuring the property meets the 
standards of the Housing Act. The licence is issued to the most appropriate person and in some 
cases this maybe the letting agents or another person who has significant control of the property. 
It is also made clearer in the documentation that the licence does not indicate that the property 
has been assessed against any standards and that it is up to the licence holder to carry out 
regular checks to make sure the property meets legal requirements. 

•  As the Council has discretion regarding the licence conditions that form the basis of the selective 
licensing scheme, these have been amended to include blind cord safety as a licence condition 
and this will be checked at every property visited by the Council's Environmental Health team both 
as part of any audit of a property and also as part of an inspection in response to any other 
reported issue. 

•  It is now made clearer on the licence that any breaches of the licence conditions will result in legal 

action. 

•  It is also explained on the documentation that the award of the licence is not an endorsement of 

the property 

•  Information and a link to the appropriate government website is now on the Council's website. 
Please see the link for your information  - Selective Licensing of private landlords | Selective 
Licensing of private landlords | Oldham Council 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 •  All Enforcement officers within the team who inspect residential properties have been briefed as to 

the importance of blind cord safety and instructed to check any issues with blind cords at all 
properties that they visit. 

Many thanks 

, Chief Executive 

Oldham Council 

For Satnav purposes please use OL1 1NL 

Visiting the Civic Centre by Metrolink? The nearest stop is Oldham King Street (2 - 3 mins' walk)

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