Prevention of Future Deaths reports · 2024

Mark Pryor

Regulation 28 report to prevent future deaths, reference 2024-0063, written 6 Feb 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report6 Feb 2024
Reference2024-0063
DeceasedMark Pryor
CoronerPeter Nieto
Coroner areaDerby and Derbyshire
CategoryState Custody 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 

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

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO: - 

The CEO, HCRG Care Services Ltd, 
The Health Business and technical Park 
Heath Road 
Runcorn 
WA7 4QX 

Rt Hon Alex Chalk MP, the Secretary of State for Justice 
Ministry of Justice 
102 Petty France 
London 
SW1H 9AJ 

Rt Hon Victoria Atkins MP, the Secretary of State for Health and Social Care, 
Department of Health and Social Care, 
39 Victoria Street,  
London,  
SW1H 0EU 

1  CORONER 

I am Peter Nieto, senior coroner for the coroner area of Derby and Derbyshire 

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 07 September 2020 I commenced an investigation into the death of Mark PRYOR aged 46. 
The investigation concluded at the end of the inquest on 01 February 2024.  The conclusion 
of the jury was: - 

Mr Pryor suffered an alcohol withdrawal related seizure whilst detained in police custody which 
caused  cardiorespiratory  arrest  and  death.  There  were  deficiencies  in  the  health  care 
professionals’ assessment and treatment of Mr Pryor’s alcohol withdrawal which probably made 
a more than minimal contribution to his death. 

4  CIRCUMSTANCES OF THE DEATH 

Mr  Pryor  died  at  the  emergency  department  of  the  Royal  Derby  Hospital  on  5th  September 
2020,  shortly  after  being  taken  there  from  police  custody  where  he  had  gone  into 
cardiorespiratory  arrest  due  to  alcohol  withdrawal.  He  had  a  long-term  history  of  drug  and 

CONTROLLED 

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

 
 alcohol misuse and was alcohol dependent. He had been arrested and detained in police custody 
on 4th September. 

Mr Pryor was seen in police custody by Health Care Professionals (HCP's) due to his documented 
opiate  misuse,  methadone  usage  and  alcohol  dependency.  Mr  Pryor  was  attended  on  four 
separate occasions by two different HCP's whilst in custody. He was recognised to be dependent 
on alcohol and when he began to exhibit  symptoms  of withdrawal a HCP began a course  of 
alcohol  withdrawal  medication  to  reduce  the  symptoms  and  guard  against  possible  alcohol 
withdrawal related seizure. 

The inquest jury returned the following conclusion: - 

‘Mr Pryor suffered an alcohol withdrawal related seizure whilst detained in police custody which 
caused  cardiorespiratory  arrest  and  death.  There  were  deficiencies  in  the  health  care 
professionals’ assessment and treatment of Mr Pryor’s alcohol withdrawal which probably made 
a more than minimal contribution to his death’. 

The jury recorded the following findings: - 

‘The HCP assessments were not of a reasonable standard due to the following reasons:  

- Assessments provided were substantially shorter than the recognised accepted practice and 
consistently shorter than would have been required to properly assess Mr Pryor effectively. In 
addition to this the time between assessments was too long, particularly after the critical dose 
of the withdrawal medication was administered, to ascertain the effectiveness.  

-  Assessments  were  lacking  in  consistent  information  i.e.  BP,  pulse,  heart  rate  and  history. 
Previous assessments were not referenced prior to each visit, changes in vital signs were not 
acted upon.  

- Assessment records were inadequate and lacking in detail.  

There was a point at which an increase in the withdrawal medication dose should have been 
considered when Mr Pryor's BP and pulse were not taken and found to be elevated. ….. 

Although  not  demonstrably  contributory  to  Mr  Pryor's  death,  the  jury  records  the  following 
matters:  

There were inadequacies in the training and induction provided to the lesser experienced HCP 
who attended Mr Pryor.  

It is also clear that the lesser experienced HCP did not have suitable experience and skills to 
work as an HCP’. 

The lesser experienced HCP had previously worked as a mental health nurse. 

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:  

I  am  concerned  that  Health  Care  Professionals  (HCPs)  may  not  be  receiving  sufficient  and 
adequate training to enable them to practice effectively or safely in police custody suites. This 
is  based  on  the  evidence  and  findings  in  Mr  Pryor’s  inquest  and  my  understanding  that  the 
training provided by HCRG may be very similar to that given by other providers of HCP police 
custody services nationally. 

CONTROLLED 

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

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Clinical assessment and treatment is provided  to police  custody detainees by HCPs  with the 
support of an on-call doctor. Typically there will be one HCP per shift. Nationally, HCP services 
are provided by a number of independent providers under contract to individual police forces. 
Professionals eligible to be recruited as HCPs (as taken from HCRG personal specification) are 
registered nurses (general or mental health), or paramedics with a minimum of two years post-
qualification with NMC or HCPC registration and ‘nursing experience in the following: A&E, ITU, 
EAU,  SAU,  Nurse  Practitioner,  Practice  Nurse,  EAU,  SAU  (other  nursing  backgrounds  will  be 
considered)’.   

Current training provided to newly appointed HCPs (by HCRG) consists of shadowing shifts with 
an  experienced  HCP,  potentially  for  up  to  six  or  eight  shifts;  a  two-day  induction  course;  a 
medication related course of less than a day which includes a pass or fail test.  There is also 
formal supervision and a three-month probationary period.  

The two-day induction course covers the following topics: - 

Day 1  
Overview of the role of HCPs in custody; Consent, confidentiality and ethics – covering topics 
including the relevant laws, regulations and regulatory issues, the importance and limitations 
of  concept,  assessing  capacity,  nature  of  the  HCPs  dual  responsibility  and  how  it  affects 
disclosure  of  sensitive  information.  and  importance  of  record  keeping;  Fitness  to  detain  – 
covering  topics  including  the  need  to  assess  detainees  for  injuries,  illnesses,  and  drug  and 
alcohol problems, formulating a care plan in custody to manage risk and identifying those who 
are not fit to detain who may need alternative support; Fitness to interview / charge/ transfer 
/ release – covering topics including a recap on assessing capacity and assessing, safeguards 
to  prevent  the  risk  of  involuntary/false  confessions,  overview  of  illnesses  that  might  be 
worsened by interview and factors to consider  when  assessing detainees’ fitness to release; 
Drugs and alcohol is police custody – covering topics including examination features of alcohol 
and/  or  opiate  intoxication,  examination  features  of  alcohol  or  opiate  withdrawal,  key 
assessment  details  in  the  detainee  with  alcohol  dependence,  treatment  of  alcohol  /  opiate 
withdrawal in police custody; Mental health in custody - covering topics including the relevant 
sections of the Mental Health Act, the overlap of learning difficulties with mental health in police 
custody,  the  role  of  liaison  and  diversion  (L&D)  teams  and  the  approved  mental  health 
professional (AMHP) and when to refer to specialist services; Mental state examination (MSE) 
– covering topics including purpose of MSE, format of MSE, communicating MSE findings and 
risk assessments.  

Day 2  
Forensic  science  and  samples  –  covering  topics  including  understanding  Locard’s  Principle, 
which offences  may  trigger  sample  requests,  taking  non  intimate  and  intimate  samples  and 
relevant  procedural  steps;  Traffic  Medicine  –  covering  relevant  procedures  under  the  Road 
Traffic Act; Restraint, TASER and irritant sprays – covering an overview of different types of 
restraint and when a detainee may need hospital following restraint; Documentation of injury 
– covering how to take history for injuries, how to describe, document and classify injuries; 
Statement  writing  –  covering  topics  including  overview  on  preparing  a  witness  statement, 
format  of  a  witness  statement  and  information  required  to  complete  a  statement  and 
importance of good clinical notation on the assessment forms provided in custody. 

I have reproduced  the summary of  training,  which was given in  evidence  at the  inquest,  to 
illustrate  that  there  are  obviously  a  very  extensive  number  of  topics  which  are  listed  to  be 
covered.  

I find it difficult to see that necessary training can be given within the specified time to equip 
a paramedic or nurse who is fresh to the custody setting to practice effectively and safely. The 
inquest heard evidence from the more experienced HCP that when she started, with a different 
provider  some  eight  years  prior,  she  had  six  weeks  classroom-based  training  before  she 
commenced full duties as an HCP. The inquest also heard that The Faculty of Forensic & Legal 
Medicine recommends a five-day induction course for HCPs.  

CONTROLLED 

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

 
 
 
 
 
 
 
 
 
 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.  

NB – I am unclear where ministerial responsibility may lie regarding health care provision in 
police custody and hence I am sending this report to the MoJ and the Dept for Health and Social 
Care so that the relevant department/s will provide a response. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report,  
namely by 3rd April 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: 

 (son) 

Derbyshire Police Constabulary 

Independent Office of Police Conduct (IOPC) 

I have also sent it to: - 

, Chair, 

Chief Cons. 
National Police Chiefs’ Council, 
50 Broadway, 
London, 
SW1H 0BL    

, President, 

The Faculty of Forensic & Legal Medicine 
11 St Andrews Place 
London 
NW1 4LE    

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. 

CONTROLLED 

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

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 9 

 Dated: 6th February 2024 

Peter Nieto 
Senior coroner for  
Derby and Derbyshire 

CONTROLLED 

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

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 Crg Medical Services (PDF)
CRG Medical Services,

Suite 5, 

6th Floor,

Century House,

Hardshaw St, 

Saint Helens,

WA10 1QU.

Tel: 

Private and Confidential

Mr Peter Nieto

Senior Coroner for Derby and Derbyshire

St Katherine's House

St Mary's Wharf

Mansfield Road

Derby

DE1 3TQ

By email: 

Dear Sir

RE: REGULATION 28 REPORT FOLLOWING THE INQUEST TOUCHING THE DEATH OF MR MARK 
PRYOR 

We  are  providing  this  letter  in  response  to  the  Coroner’s  Regulation  28  Report  issued  pursuant  to 
Regulation  28  and  29  of  the  Coroner’s  (Investigations)  Regulations  2013  dated  6th  February  2024 
following the conclusion of the inquest touching the death of Mr Mark Pryor. 

As a result of the Regulation 28 Report, the Coroner has requested that CRG Medical Services provide 
their response in respect of the Coroner’s concerns regarding the training for newly recruited Health 
Care Professionals (HCPs) who may be fresh to the custody setting. More specifically the Coroner had 
concerns in respect of whether the two-day induction course provided by CRG Medical Services was 
sufficient to adequately cover the extensive number of topics the course intended to cover. 

Response

CRG  Medical  Services  has  been  in  the  process  of  reviewing  the  training  material  for  the  two-day 
induction course, known as foundation training, to ensure it is an interactive learning experience for 
newly recruited HCPs. As part of this process and further to the Coroner’s concerns, as of this financial 
year 2024/25 the foundation training course will be provided over five days.

The Clinical Leads and senior HCP’s will be attending a training course on presentation skills in May 
2024, to ensure that a uniformly high-quality level of training will be provided to all new recruits during 
the foundation training and intensive supervision shifts from June 2024. 

 The foundation training course will be scheduled to take place during the first week of each month 
and new recruits will not be able to work clinical shifts until they have received a certificate to show 
they have completed the foundation training. Certificates will be signed off by the Clinical Lead of the 
contract once feedback has been received from course presenters in respect of each HCP. 

Following  the  five-day  foundation  training  course,  new  recruits  will  then  work  five  shifts  under 
intensive supervision of a senior HCP. Allowing them to initially observe and then carry out duties in a 
setting  that  is  supportive  of  their  learning  and  safe  for  detainees.  The  expectations,  skills,  and 
proficiencies to be covered during the intensive supervision shifts will be based on where each HCP 
will  be  deployed,  therefore  they  will  be  set  by  the  relevant  Clinical  Lead.  At  the  conclusion  of  the 
intensive supervision shifts, the relevant Clinical Lead will receive feedback from the senior HCPs and 
if appropriate sign off the new recruit’s induction period. 

The probationary period of 3 months during which HCPs are required to have supervisory meetings 
with the Clinical Leads and assessments remains unchanged. 

In conclusion, CRG Medical Services welcomes the constructive comments made by the Coroner in his 
Regulation 28 Report. The contents of the report have been considered carefully, and CRG Medical 
Services have made changes to ensure robust training is in place to address the concerns raised by the 
Coroner. 

Should the Coroner have any queries once he has had an opportunity to consider this letter, he should 
not hesitate to contact us. 

Yours sincerely

General Counsel
Response from The Faculty of Forensic Legal Medicine (PDF)
FACULTY OF FORENSIC & LEGAL MEDICINE 
of the Royal College of Physicians of London  

E-mail f

Website www.fflm.ac.uk 

Registered Charity No 1119599 

05 March 2024 

Strictly Private and Confidential 
For the attention of 
Mr Peter Nieto,  
HM Senior Coroner for Derby and Derbyshire 
The Coroner’s Court,  
Town Hall, Rose Hill,  
Chesterfield,  
Derbyshire, S40 1LP                          

Dear Mr Nieto 

Re: Copy of Regulation 28 Prevention of Future Death Report following the conclusion of the 
Inquest into the death of Mr Mark Pryor. 

On behalf of the Faculty, I wanted to thank you very much, for sending a copy of this report to 
me. We particularly noted your comprehensive and insightful comments on the 2 days’ training 
which the HCPs’ employing organisation had provided. 

The  FFLM  is  a  charity  set  up  to  develop  and  maintain  the  highest  possible  standards  of 
competence  and  professional  integrity  in  forensic  and  legal  medicine.  The  specialty  covers 
professionals  working  in  the  following  disciplines:  forensic  medical  practitioners  (forensic 
physicians, forensic pathologists, forensic psychiatrists, forensic odontologists); medico-legal 
and  dento-legal  advisers;  clinicians  working  in  secure  and  detained  settings  and  medically 
qualified coroners. Our membership includes a number of different healthcare professionals in 
forensic roles: doctors, nurses, midwives and paramedics. 

Although  we  describe  a  specialty  above,  at  present,  forensic  and  legal  medicine  is  not 
recognised as a specialty in the UK, as, for example, Paediatrics, Obstetrics and Gynaecology 
and Surgery are. We are working hard to achieve specialist recognition. 

The FFLM has been recognised by the Home Office as being responsible for the 
standards to be expected from all healthcare professionals involved in custody healthcare 
and forensic examination; (see Hansard, March 18th 2009, Column 1164W  Forensic 
Science - Hansard - UK Parliament ). 

Our aims are: Raising standards in forensic and legal medicine; protecting vulnerable people. 

 
 
 
 
 
 
 
 
                                                                            
 
 
 
 
 
 
 
 
 
 
 
 
 
 FACULTY OF FORENSIC & LEGAL MEDICINE 
of the Royal College of Physicians of London  

E-mail 

Website www.fflm.ac.uk 

Registered Charity No 1119599 

As  a  result,  we  have  developed  and  published  recommendations  and  guidance  to  support 
education  and  supervised  training  in  Forensic  Medicine,  including  for  the  police  custodial 
setting, which can be found on our website, and I highlight, below: 

•  FFLM Quality Standards in Forensic Medicine - FFLM 
•  FFLM  Quality  Standards  for  Nurses  and  Paramedics  -  General  Forensic  Medicine 

(GFM) - FFLM 

•  Recommendations - Introductory Training Courses in General Forensic Medicine (GFM) 

- FFLM 

We  have  contacted  our  membership  via  the  bulletin,  highlighting  your  report,  which  is  now 
available on the Chief Coroner’s website. We have re-confirmed the importance of initial and 
continuing education and supervised training and all forensic clinicians have access to senior 
advice, at all times; this is a responsibility of the clinician and the employer. In addition, we are 
looking at offering additional training, particularly, in the management and care of detainees 
who are dependent on drugs or alcohol, or both. 

Thank you again for ensuring we were aware of your report.  

Kind regards, 

Yours sincerely, 

President

Related reports

Other reports by Peter Nieto

See all →

More reports categorised “State Custody related deaths”

See all →

Track State Custody related deaths

See every Prevention of Future Deaths report matching State Custody related deaths, and how often a new one appears.

What would an alert for this have sent me? Search the full text

Free to try — the preview shows the real matches and how many arrived in the last 12 months. Your first email alert is free.

These reports are published by the Chief Coroner's office at judiciary.uk and are © Crown copyright. The text here is reproduced from the published PDF so it can be searched. If something on this page is wrong, or you are a person named in it and want it reviewed, email drcjar@gmail.com and we will act promptly.