Hannah Jacobs

Parliamentary Under-Secretary of State for Public Health and Prevention 

39 Victoria Street 
London 
SW1H 0EU 

Our ref: 

Dr Shirley Radcliffe,  
HM Assistant Coroner,  
East London Coroner’s Office  
Queens Road 
Walthamstow, E17 8QP 

By email:

Dear Dr Radcliffe,  

15 October 2024 

Thank you for the Regulation 28 report of 20 August 2024 sent to the Secretary of State at 
the  Department  of  Health  and  Social  Care  (DHSC)  and  to  the  Secretary  of  State  for 
Education about the death of Hannah Jacobs. I am replying on behalf of both Secretaries of 
State  as  I  am  the  Minister  in  DHSC  with  responsibility  for  long-term  conditions,  including 
allergies.  In  preparing  this  response,  my  officials  have  liaised  with  the  Department  for 
Education (DfE), the Medicines & Healthcare products Regulatory Agency (MHRA) and NHS 
England.  

Firstly, I would like to say how saddened I was to read of the circumstances of  Hannah’s 
death, and I offer my sincere condolences to her family and loved ones. Hannah’s loss at 
such  a  young  age  must  be  extremely  distressing  for  them  and  I  am  grateful  to  you  for 
bringing these concerns to my attention.  

Your report raises concerns over: 

•  A lack of consideration about how to contain the risk of anaphylaxis on the journey to 

and from school. 

•  The lack of a readily available adrenaline autoinjector (AAI) especially where they are 

misused, lost or forgotten, leaving an absence of an AAI over the weekend. 

•  The need for appropriate structures in place to educate schools, patients and parents 

of the importance of carrying an AAI on their way to and from school.  

I also understand that in a separate report that you have issued to NHS England, you raised 
concerns  about  supplies  of  AAIs  as  the  pharmacy  at  which  Hannah  and  her  mother 
attempted  to  obtain  an  EpiPen  did  not  have  any  adult  doses  in  stock  and,  by  that  point, 
Hannah required two doses from an adult EpiPen. 

On the issue of educating patients parents and schools, the message to use an AAI at the 
first signs of a severe reaction before calling for help, and the recommendation for patients 
to carry two AAIs has been reinforced through a series of advice and guidance.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 In June 2023, the MHRA launched new guidance to highlight the latest safety advice from 
the Commission on Human Medicines (CHM’s) working group on the safe and effective 
use of AAIs. The guidance included advice for healthcare professionals to provide to 
patients and carers and reinforces the importance of carrying 2 AAIs at all times, and using 
AAIs without delay if anaphylaxis is suspected, even if in doubt about the severity of the 
event. The guidance can be accessed at the following link:  
https://www.gov.uk/government/publications/adrenaline-auto-injectors-aais-safety-
campaign/adrenaline-auto-injectors-aais 

The MHRA has also produced a toolkit of resources which is available for health and 
social care professionals to support the safe and effective use of AAIs. These resources 
are freely available and include an infographic about the correct use of an AAI. Health and 
social care professionals are asked to use the materials to inform patients and caregivers 
what to do if they suspect anaphylaxis and how to use AAIs and that prescribers should 
prescribe two AAIs to make sure that patients always have a second dose. The resources 
are available at the following link: 

https://aaisafety.campaign.gov.uk/resources/ 

The information set out in the guidance remains current and we have been advised by 
MHRA that there are currently no plans to revise it. MHRA continues to signpost the 
public, media and charities to the guidance to encourage safe use of AAIs wherever 
possible. 

Information is also contained in the British National Formulary (BNF) and the BNF for 
children (BNFc), that patients should carry two AAI devices (AAI) at all times; on the 
importance of training as well as on the importance of training patients and carers in the 
use of the particular AAI prescribed. The BNF and BNFc are joint publications of the British 
Medical Association and the Royal Pharmaceutical Society and are accessible from the 
National Institute for Heath and Care Excellence’s (NICE) website. The information 
referred to above can be found at: 

https://bnf.nice.org.uk/drugs/adrenaline-epinephrine/#important-safety-information 

Prescribers are expected to refer to information within the BNF to help inform prescribing 
decisions made with Individual patients and carers. This expectation is set out in the 
GMC’s publication on ‘Good practice in prescribing and managing medicines and devices', 
which I have referred to above, within the section titled: keeping up to date and prescribing 
safely. This section can be found at the following link:  

https://www.gmc-uk.org/professional-standards/professional-standards-for-doctors/good-
practice-in-prescribing-and-managing-medicines-and-devices/keeping-up-to-date-and-
prescribing-safely. 

Advice on preventing anaphylaxis is provided on the NHS.UK website and this also 
recommends that patients carry two AAIs with them at all times. The advice can be 
accessed at the following link:  

 
 
 
 
 
 
 
 
 
 https://www.nhs.uk/conditions/anaphylaxis/#:~:text=Immediate%20action%20required%3A
%20Call%20999%20if%3A&text=your%20skin%2C%20tongue%20or%20lips,and%20can
not%20be%20woken%20up 

Section 100 of the Children and Families Act 2014 places a legal duty on schools to make 
arrangements for supporting pupils at their school with medical conditions. The 
accompanying statutory guidance - Supporting Pupils at School with Medical Conditions - 
is not voluntary; schools are legally required to have regard to this guidance when carrying 
out their section 100 duty.  

The guidance makes clear to schools what is expected of them in taking reasonable steps 
to fulfil their legal obligations and to meet the individual needs of pupils with medical 
conditions, including allergies. Schools should ensure they are aware of any pupils with 
medical conditions and have policies and processes in place to ensure these can be well 
managed.  

The guidance can be accessed at the following link:  

https://www.gov.uk/government/publications/send-code-of-practice-0-to-25 

DfE included a reminder to schools of these duties in its regular schools’ email bulletin in 
both March and September this year. Copies of the bulletin are available here:  

March 2024 - Update to all education and childcare settings and providers 
(govdelivery.com) 
September 2024 - Update to all education and childcare settings and providers 
(govdelivery.com) 

In the same communication DfE also alerted schools to the newly created Schools Allergy 
Code. The Code was developed by The Allergy Team, Independent Schools’ Bursars 
Association (ISBA) and the Benedict Blythe Foundation, who are all trusted voices on the 
matter of allergies. DfE has now also added a link to the Code to its online allergy 
guidance on Gov.uk. The Code can be accessed at the following link:  

https://theallergyteam.com/schools-allergy-code/ 

In 2017, the Department of Health published non-statutory guidance to accompany a 
legislative change to allow schools to purchase spare AAIs from a pharmacy, without a 
prescription and for use in an emergency situation. This guidance gives clear advice to 
schools on the recognition and management of an allergic reaction and anaphylaxis, and 
outlines when and how an AAI should be administered for pupils in schools. The guidance 
states that children at risk of anaphylaxis should have their prescribed AAIs at school for 
use in an emergency, and in line with MHRA advice, those prescribed AAIs should carry 
two devices at all times. The guidance also states that depending on their level of 
understanding and competence, children and particularly teenagers should carry their 
AAIs on their person at all times or they should be quickly and easily accessible at all 
times. I understand that it is not uncommon for schools, particularly primary schools, to 
request a pupil’s AAIs are left in school to avoid the situation where a pupil or their family 

 
 
 
 
 
 
 
 
 
 forgets to bring the AAIs to school each day. Where this occurs, the guidance states that 
the pupil must still have access to an AAI when travelling to and from school.  

‘Guidance on the use of adrenaline auto-injectors in school’ can be accessed through the 
following link and DHSC keeps the guidance under review.  

https://assets.publishing.service.gov.uk/media/5a829e3940f0b6230269bcf4/Adrenaline_au
to_injectors_in_schools.pdf 

An Expert Advisory Group for Allergy (EAGA) has been established, which brings together 
key stakeholders with the aim improving the quality-of-life of people with allergies. Chaired 
jointly by DHSC and the National Allergy Strategy Group, EAGA identifies priority areas for 
DHSC, NHS England and other government departments and agencies relating to allergy 
that require policy change or development and advises on how to best achieve improved 
outcomes and improve support for people with allergies.  

In relation to shortages of AAIs, DHSC works closely with all suppliers of AAIs to ensure 
supplies remain available for patients. We understand that in February 2023 all suppliers 
of adrenaline 0.3mcg auto-injectors were in stock, including EpiPen. One supplier of 
0.15mcg had been out of stock since early 2020 but the remaining two suppliers, including 
EpiPen, were available in sufficient quantities to support patient demand. The sole supplier 
of the 0.5mcg pen (Emerade) was also in stock during this time. 

Officials continue to work with MHRA, the pharmaceutical industry, NHS England and 
others operating in the supply chain to help prevent shortages and to ensure that the risks 
to patients are minimised when shortages do arise.  

I hope this response is helpful in demonstrating the ways in which your concerns are being 
addressed and will continue to be addressed. Thank you for again for bringing to the 
attention of the Secretaries of State and their respective departments the concerns that 
have followed the inquest into the tragic death of Hannah Jacobs.   

Yours sincerely,