Prevention of Future Deaths reports · 2024

Michael Pender, Jan Klempar and Paul Mullen

Regulation 28 report to prevent future deaths, reference 2024-0049, written 31 Jan 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report31 Jan 2024
Reference2024-0049
DeceasedMichael Pender, Jan Klempar and Paul Mullen
CoronerAndrew Cox
Coroner areaCornwall and the Isles of Scilly
CategoryOther 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.

Information Classification: CONTROLLED 

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

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

1.  Mr A Chisholm, Permanent Secretary (Cabinet Office) 

1  CORONER 

I am Andrew Cox, the Senior Coroner for the coroner area of Cornwall 
and the Isles of Scilly. 

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 31/1/24, I concluded the inquests into the deaths of: 

i)  Michael Pender, who drowned at Treyarnon beach on 25/5/20; 
ii)  Jan Klempar, who drowned at Porthcurno beach on 25/6/20; 
iii)  Paul Mullen, who drowned at Church Cove on the Lizard on 

20/8/20. 

The three inquests were heard together as they arose out of a common 
occurrence namely that, following the relaxation of the national lockdown 
after the COVID-19 pandemic, they all happened on beaches that would 
ordinarily have been lifeguarded but were not at the material times. A 
copy of my judgment is attached. 

4  CIRCUMSTANCES OF THE DEATH 

i)  Mr Pender drowned at Treyarnon beach on 25 May 2020. He lived 

locally. At the time, the country had just come out of lockdown 
after the emergence of the COVID-19 pandemic. Lifeguards 
would ordinarily have been present on the beach but, on that 
date, were not. Additional signage had been put up and there 
had been an extensive media campaign to alert the public to 
the position. Mr Pender was seen to get into difficulty. He was 
found floating in the water and taken to Padstow lifeboat station 
where he was confirmed deceased. 

ii)  Mr Klempar drowned at Porthcurno beach on 25 June 2020., 

having travelled down from the Midlands for the day with his 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Information Classification: CONTROLLED 

family. At the time, the country was still coming out of 
lockdown after the emergence of the COVID-19 pandemic. 
Lifeguards would ordinarily have been present on the beach 
but, at the time of the incident, were not. Additional signage 
had been put up and there had been an extensive media 
campaign to alert the public to the position. Mr Klempar was 
seen to get into difficulty. He was found floating in the water 
and recovered to the beach. Efforts to resuscitate him were 
unsuccessful. 

iii) Mr Mullen drowned at Church Cove on the Lizard on 20 August 

2020. He was on holiday with his family. At the time, the 
country was still coming out of lockdown after the 
emergence of the COVID-19 pandemic. Lifeguards would 
ordinarily have been present on the beach but, at the time 
of the incident, were not. Additional signage had been put 
up and there had been an extensive media campaign to 
alert the public to the position. The sea was unusually rough 
due to an approaching storm. Mr Mullen went into the sea 
after his son got into difficulties. He was found floating in 
the water and recovered to the beach. Efforts to resuscitate 
him were unsuccessful. 

5  CORONER’S CONCERNS  

During the course of these inquests, the evidence has 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 fall into two broad areas: 

COVID-19 related concerns 

i)  The government took the decision to offer furlough to those in 

receipt of PAYE as at the end of February 2020. Most of the 
c1600 lifeguards who work on the 250 beaches where the RNLI 
are present are seasonal employees. They did not qualify for 
furlough. At that point in time, the RNLI was in the process or 
recruiting and training the seasonal lifeguards it required. When 
furlough was not offered, a number had to seek alternative 
means of income. As lockdown was eased and lifeguards were 
required, the RNLI did not have immediately available to it the 
seasonal employees it required to provide beach safety around 
the coast.  

2 

 
 
 
 
 
 
 
 Information Classification: CONTROLLED 

I found this contributed to the problems that ensued in a partial 
sense. I do not suggest that had the seasonal lifeguards been 
furloughed all of the difficulties could have been avoided. The 
evidence revealed some lifeguards may not have wanted to 
take up their position in light of COVID and there were 
additional complications like how new lifeguards became 
formally qualified when providers were not available as well as 
how the RNLI could have provided COVID secure places of 
work in the time available; 

ii)  The lack of advance notice given to the RNLI of government’s 
intention to relax lockdown and allow people to travel to the 
beach again. The RNLI anticipated the difficulties developing. It 
wrote to the Department of Transport and the Prime Minister to 
make sure the relevant people were aware of the problems. By 
letter of 24 April 2020, Kelly Tolhurst MP, Minister for Aviation, 
Maritime & Security informed the RNLI Chief Executive that: 
‘Officials will ensure RNLI is notified as far in advance as 
possible to enable you to mobilise your assets as appropriate.’ 
That did not happen. The RNLI learned of the decision to relax 
lockdown at the same time as the general public and was put in 
an impossible situation of needing to provide lifeguards on 
beaches the next day. Mr Pender drowned before there were 
any lifeguards on any beaches. 

iii)  The RNLI had considerable difficulties sourcing PPE on the open 

market. Thought may wish to be given to whether it should 
have priority access to government stock in the event of a 
future pandemic. 

It is recognised that this was an unprecedented situation that was 
changing rapidly where there were many competing interests. There do 
appear, however, to be lessons that can be learned from considered 
review of what has happened. I am not sure whether responsibility to 
undertake this best lies with you or the on-going public inquiry. I have 
written to the Secretary to the inquiry additionally and leave you to 
resolve between yourselves who is best placed to address this. 

Beach Safety concerns generally 

I want to put what follows in an accurate context. 

In 2019, there were RNLI lifeguards on 248 beaches. There were 
approximately 1600 lifeguards, the vast majority of whom were employed 
on a seasonal basis. They were on beaches that saw approximately 18M 
visitors, they provided 200,000 hours of supervised patrols during the 

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 Information Classification: CONTROLLED 

course of which 30,000 people were assisted and an estimated 154 lives 
saved. The total cost came in at £21 million, in respect of which the 
charity received contributions totalling just under £4 million. 

In 2016, seven men drowned at Camber Sands in East Sussex. My 
colleague, HM Senior Coroner Mr Craze, wrote a series of PFDs. This led 
to the publication by the MCA of previously lacking guidance for 
landowners and local authorities on how to manage beach safety and is 
to be welcomed.  

The MCA also commissioned from DWF a report reviewing legal 
responsibilities for beach safety that was available in January 2019 but 
not published until November 2020. It identified a confused and 
conflicting legal landscape where there was no clear legal duty to provide 
lifeguards and most owners/occupiers were acting out of social 
conscience than for any other reason. All stakeholders wanted greater 
clarity to be introduced. That has not happened and there has been no 
formal government response to the review. Indeed, it appears as though 
there is no government department that has responsibility for the area. In 
a letter from the Secretary of State for Transport, Mr Harper, to me I was 
informed:  

Neither the MCA, nor the Department for Transport (DfT), has any wider 
responsibilities for beach safety policy or legislation.   

This may provide an explanation for why this concern has remained for 
so long. As long ago as 2006, a local MP observed that it was a 
‘ridiculous anomaly’ that there was more regulation for swimming in a 
public pool than there was for swimming in the more dangerous 
environment of the sea, or that there were stricter standards for working 
on a vessel at sea than there were for members of the public going to the 
coast. 

What is apparent, however, is that a stated intention to reduce drownings 
by half by 2026 is in real danger of being missed. 

It is for government to decide whether there should be policy in this area 
and, if so, who should be responsible for it. My duty is simply to bring the 
concerns to your attention which I hope I have now discharged. 

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.  

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 Information Classification: CONTROLLED 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date 
of this report, namely by 30 March 2024. 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: 

-  The family of Mr Pender; 
-  The family of Mr Klempar; 
-  The family of Mr Mullen; 
-  The RNLI; 
-  The MCA; 
-  Cornwall Council; 
-  The National 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 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 

[DATE]                                              [SIGNED BY CORONER] 

31.1.24                                            

5

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 Cabinet Office (PDF)
CABINET OFFICE

Catherine Little CB
Civil Service Chief Operating Officer
and Cabinet Office Permanent Secretary
3 October

Dear Mr Cox,

I am grateful for your letter dated 31 January 2024 relating to the deaths of Michael Pender, Jan
Klempar and Paul Mullen. Thank you also for the Regulation 28 Preventing Future Deaths report
you prepared setting out your judgement following the inquests into the deaths and your concerns
around the circumstances in which these deaths occurred.

I note from your letter dated 10 May 2024 that you are seeking a formal response to your
Preventing Future Deaths report, following my letter acknowledging receipt of the same.

I have reviewed the concerns that you highlighted for the Government’s attention in relation to the
easing of Covid-19 measures in the first half of 2020, which served as the common backdrop for
the deaths as detailed in your correspondence. I also acknowledge the concern you have raised in
relation to the issue of beach safety policy more generally, and responsibility for it within UK
Government.

Please find below the actions taken or planned action in relation to your recommendations relating
to these issues, or an explanation where no action is being taken.

Covid-19 measures

The UK Covid-19 Inquiry is ongoing and given they are also in receipt of your Preventing Future
Deaths report, we await its recommendations from Module 2 of the Inquiry, focussing on
decision-making and political governance during the pandemic. However, I believe it is
appropriate to pass on your observations to the government departments most likely to influence
future measures in a similar pandemic or national crisis and have addressed your concerns relating
to Covid-19 measures as follows:

○ On the issue of the RNLI lifeguards not being eligible for furlough, we have shared
your concerns with HMT and HMRC given their oversight of the policy, which
they have acknowledged receipt of. Covid economic support schemes, including
the Coronavirus Job Retention Scheme, are being examined in Module 9 of the
Inquiry, and we await the Inquiry’s recommendations on this issue;

 ○ On the RNLI receiving advance notice to allow them to recruit and train lifeguards,

the Department for Transport and the Maritime and Coastguard Agency have
advised they maintain a strong working relationship with the RNLI with regular
communication with the organisation. Government communication is also a subject
that was covered in Module 2 of the UK Covid-19 Inquiry so we await their
recommendations in relation to this;

○ On the concerns around the RNLI not having access to an adequate supply of PPE,
we have passed your concerns onto DHSC, which they have acknowledged receipt
of. The procurement and distribution of healthcare related supplies including PPE
is being examined in Module 5 of the Inquiry, and we await the Inquiry’s
recommendations on this issue.

Beach safety policy

I note your concerns
in relation to beach safety policy more generally, including the calls for
greater clarity for landowners and occupiers on their duties, and the lack of clear departmental
responsibility within government. Government is currently considering these issues and we would
be happy to provide your office with an update as this progresses.

You raised, in particular, the National Water Safety Forum’s (NWSF) target to reduce drownings
by half by 2026. When formed in 2004, the Forum brought together a broad range of existing
groups into a one-stop-shop for the prevention of drowning and water safety harm in the UK. HM
Coastguard (HMCG), part of the Maritime & Coastguard Agency (MCA), is a member of the
Forum and works with stakeholders to share information from HMCG incidents. The MCA
communications team works with HMCG to highlight safety messaging to members of the public
in attempts to try to reduce incidents around the coastline of the UK.

The MCA’s surveyors and marine office teams ensure that vessels are safe for those working or
travelling on board. Their navigation specialists support the team and wider services to protect
routes taken. The fishing industry is important for the United Kingdom (UK), and we continue to
work with this sector to reduce fatalities and support them in developing best work practices.

The data from the NWSF’s Water Incident Database suggests the number of deaths caused by
drowning have fluctuated in recent years. There has been a significant increase in water-based
activity participation rates over the past four years, particularly stand-up paddle boarding,
kayaking and open-water swimming. The Forum believes that a more defined reduction in
drownings in relation to population and participation numbers would be evident were these factors
fully analysed.

The NWSF are improving their data collection to enhance understanding of the data. They intend
to broaden their risk assessment to include rescues to understand localities that require targeted
prevention work. In addition, they plan to carry out a demographic analysis to assess the impact of
reduced rates of swimming attainment in schools to assist in future plans to prevent drownings.

 I am grateful to you for bringing the above issues to my attention. We remain committed to
working with the Inquiry to facilitate its investigations into the pandemic, and we await any
recommendations it may make in the areas you have raised, as well as any further questions or
comments you may have on the above.

Yours sincerely,

Civil Service Chief Operating Officer & Cabinet Office Permanent Secretary

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