Prevention of Future Deaths reports · 2024

Paul Clark

Regulation 28 report to prevent future deaths, reference 2024-0558, written 16 Oct 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report16 Oct 2024
Reference2024-0558
DeceasedPaul Clark
CoronerAlison Mutch
Coroner areaManchester South
CategoryAlcohol, 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)  Royal College of General Practitioners 
2)  Greater Manchester Integrated Care Board 

1 

CORONER 

I am Alison Mutch, Senior Coroner, for the coroner area of South Manchester  

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 17th May 2024 I commenced an investigation into the death of Paul Michael 
Clark. The investigation concluded on the 8th October 2024 and the conclusion 
was one of accidental death. The medical cause of death was drug toxicity. 

4 

CIRCUMSTANCES OF THE DEATH 

On 12th May 2024, Paul Michael Clark was found unresponsive at his home 
address 
found to have high and fatal level of his prescribed zomorph and pregabalin in 
his system.  

. Post mortem examination included toxicology. He was 

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.  –  

The inquest heard evidence that Paul Clark had previously been addicted to 
heroin. He had been successful in treating his opioid addiction and had 
remained opioid free for many years. His previous problems with opioids and 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 the risks of opioids for him were well documented within his medical notes. 
However despite the risks opioid painkillers presented to him he had been 
started in primary care on opioid based painkillers for reported pain. He had 
become addicted to them and took them at increasing levels topping them up 
with non-prescribed opioids. There was no evidence before the inquest that the 
inherent risks of reintroducing opioids to someone who had previously been 
addicted to them were considered or monitored. 
It was accepted in evidence that whilst opioid painkillers can be helpful for 
treating some patients the risks of treating a patient with a former opioid 
addiction with opioids were significant and that there needed to be a very well 
thought out rationale with careful monitoring to avoid increasing the chances of 
a patient relapsing into addiction through GP prescribed medication and that it 
was essential that GPs considered this when prescribing. 
ACTION SHOULD BE TAKEN 

6 

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 11th December 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 namely Archwood Medical Practice, 
the family, who may find it useful or of interest. 

 on behalf of 

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 
HM Senior Coroner 

16/10/2024 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 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 Gmic (PDF)
E:

Date: 25 November 2024 

Private & Confidential 

Ms Alison Mutch 
H M Senior Coroner  
1 Mount Tabor Street 
Stockport 
SK1 3XE  

Sent by email to: 

Dear Ms. Mutch 

Re: Regulation 28 Report to Prevent Future Deaths - Paul Michael Clark 

Thank you for your Regulation 28 Report dated 16 October 2024 regarding the sad death of Paul 
Michael Clark. On behalf of NHS Greater Manchester Integrated Care (NHS GM), We would like to begin 
by offering our sincere condolences to Mr. Clark’s family for their loss. 

Thank you for highlighting your concerns during the inquest which concluded on the 8 October 2024. On 
behalf of NHS GM, we apologise that you have had to bring these matters of concern to our attention. 
We recognise it is very important to ensure we make the necessary improvements to the quality and 
safety of future services.   

During the inquest you identified the following cause for concern: - 

The Inquest heard evidence that Paul Clark had previously been addicted to heroin.  He had 
been  successful  in  treating  his  opioid  addiction  and  had  remained  opioid  free  for  many 
years.    His  previous  problems  with  opioids  and  the  risk  of  opioids  for  him  were  well 
documented  within  his  medical  notes.    However,  despite  the  risks  opioid  painkillers 
presented to him, he had been started in primary care them at increasing levels, topping 
them up with non-prescribed opioids.  There was no evidence before the inquest that the 
inherent risks of reintroducing opioids to someone who had previously been addicted to 
them were considered or monitored.   

It was accepted in evidence that whilst opioid pain killers can be helpful for treating some 
patients,  the  risks  of  treating  a  patient  with  a  former  opioid  addiction  with  opioids  were 
significant and that there needed to be a very thought out rationale with careful monitoring 
to avoid increasing the chances of a patient relapsing into addiction through GP prescribed 
medication and that it was essential that GPs considered this when prescribing.  

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

A1 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 The Electronic Medical Information System (EMIS) clinical system is a digital platform designed to manage 
and  store  patient  health  information  electronically,  facilitating  improved  healthcare  delivery  and record-
keeping.  This  system  enhances  the  efficiency  of  medical  practices  and  allows  for  better  patient  care 
through easy access to medical records and data sharing among healthcare providers.  

EMIS enables GPs to input a pop-up message / warning to alert clinicians to important information about 
an individual patient.  Once an alert is set up, the message appears immediately that the patient record is 
accessed.  Following the inquest, I can confirm that Archwood Medical Practice have undertaken an audit 
of their patient records to identify all patients with a history of drug addiction.  A ‘pop up’ alert will be added 
to each identified record to ensure that anyone consulting with a patient within this cohort is immediately 
aware of the history and can therefore consider this history within their clinical decision making.   

I can confirm that all GPs within Greater Manchester have access to guidance in the prescribing of opioid 
medications; this can be accessed via the following link: 
https://gmmmg.nhs.uk/wp-content/uploads/2023/12/Opioid-resource-pack-2023-final-for-
web.pdfecific  

In addition further national guidance is available via the National Institute for Health and Care 
Excellence:  

https://www.nice.org.uk/guidance/ng215 
https://www.nice.org.uk/guidance/ng193 

In order to support our wider GP population, a Masterclass presentation on the subject of opioid 
prescribing was delivered to Stockport GPs and clinicians on 12 September 2024. The session title was 
‘Pain Transformation, IMPS and Opioid Stewardship’.  A total of 62 clinicians attended the session which 
was delivered by Dr Thomas Walton, Consultant in Anaesthesia and Pain Management.   

The Regulation 28 report and our response will also be shared, in January 2025, for system learning with 
the GM cross-sector medicines safety group - the IPMO Medicines Safety Group. This group reports to 
the Greater Manchester Medicines Management Group (GMMG) and is co-chaired by NHS GM and 
Manchester University NHS Foundation Trust (MFT). The intention is to reflect on any learning from the 
Regulation 28 report and create a 7-minute briefing to be produced, disseminated to clinical staff and 
used for shared learning.  

I hope the above information is helpful to you but if you do require any additional information, please do 
come back to me. 

Best wishes 

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

A2
Response from Rcgp (PDF)
Honorary Secretary of Council 

Alison Mutch 
HM Senior Coroner for South Manchester 
Sent by email to: 

3 December 2024 

Dear HM Coroner Alison Mutch 

Regulation 28 Report to Prevent Future Deaths - touching on the death of Paul Michael Clark 

Thank  you  for  sharing  a  copy  of  your  report  touching  on  the  tragic  death  of  Mr  Clark.  I  am 
responding  on  behalf  of  the  Royal  College  of  General  Practitioners  as  Honorary  Secretary  to 
Council. Firstly, can I convey our sincere condolences to the family and friends of Paul, I was deeply 
saddened to read of the circumstances around his death.  

The Royal College of General Practitioners (RCGP) is the largest membership organisation in the 
United Kingdom solely for GPs. It aims to encourage and maintain the highest standards of 
general medical practice and to act as the ‘voice’ of GPs on issues concerned with education; 
training; research; and clinical standards. Founded in 1952, the RCGP has just over 54,000 
members who are committed to improving patient care, developing their own skills and 
promoting general practice as a discipline. 

We have considered your report and offer our response focusing on the areas where the RCGP 
might have most significant influence to prevent further deaths. This includes supporting the 
understanding of managing addictions in General Practice as well as safety and quality processes 
in the prescribing of medicines.  

We would like to outline our response to your four matters of concern in these two areas.   

1)  Education (Curriculum and Continuing Professional Development)   
2)  Clinical Policy (Repeat Prescribing Toolkit)  

Royal College of General Practitioners 
30 Euston Square, London, NW1 2FB 
Tel: 020 3188 7400  |  info@rcgp.org.uk  |  rcgp.org.uk 
Patron: HRH The Duke of Edinburgh (1972-2021)  |  Registered Charity Number 223106 

A3 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Education and Continuing Professional Development 

The College is committed to upholding the highest professional standards and supports its 
members in the curriculum for new GPs in training, ongoing education and professional 
development. We hold national conferences and events reaching our membership and bringing 
the latest evidence and practice to support members as well as publishing a wide range of 
materials on our online platform which includes webinars interactive online resources and 
meetings. These materials include activity relevant to both ‘Managing Addiction’ as well as ‘Safe 
and effective prescribing’.  

Curriculum  

The College has a role in setting the Curriculum for General Practice which used to set the 
standards for training and is approved by the GMC. The core curriculum topic guide is wide 
ranging and includes a section on Smoking Alcohol and Substance misuse (p271). 

Continuing Professional Development 

The College supports all our members to keep up to date and regularly publishes Essential 
Knowledge updates (EKU) to reach all our GPs on a variety of clinical topic areas. These updates 
are regularly reviewed and updated by our CPD team. We have published two recent EKUs 
2017.1 (reviewed in 2023) containing a section on ‘Treatment and management of opioid use 
disorder’ and 2022.3 in March 2023 which included an ‘Update on medicine dependence or 
withdrawal symptoms and opioid reduction’. These are widely used and evidenced as part of 
ongoing professional development by GP members. 

We also provide the forum for GPs who have a particular interest and wish to gain a deeper 
understanding of the most current evidence, research and practice through Conference activity.  

The College is holding a National Conference ‘Managing addictions in Primary care’ in 
conjunction with AP (Addiction Professionals) in Manchester on Thursday 16th and Friday 17th 
January in Manchester. This is an annual conference in its 29th year and part of our continued 
commitment to this clinical area and brings expertise from across the country with the specific 
Learning objectives to:  

• 

• 

• 

• 

Increase understanding of current interventions for the prevention, assessment and 
treatment of alcohol and other drug problems 
Increase understanding of what interventions are possible to deliver in primary care and 
what require specialist help 
Increase knowledge of drug and alcohol policies in the UK and how they are implemented 
in primary care 
Increase knowledge of links between multiple needs, health inequalities and drug and 
alcohol use 

Clinical Policy  

We have recognised the importance of safety in repeat prescribing and the role that General 
Practice and Community Pharmacy have in this space. Through our Clinical Policy work we have 

A4 
 
  
 
 
 
 
 
 
 
 
 collaborated with the Royal Pharmaceutical Society and over the last year, I co-chaired a group 
to develop a New Repeat Prescribing Toolkit to improve safety and efficiency of repeat 
prescribing systems in general practices across England (the first of its kind in over 20 yrs). We 
launched this toolkit at our Annual Conference last month October 2024 in Liverpool and it has 
been circulated widely in open source (available members and non-members of RCGP and RPS). 
We recognise that safe and appropriate prescribing is a key skill for General Practitioners and 
something as a College that we take seriously. The new toolkit aims to support GP practice 
teams and primary care networks, working with community pharmacies and patients, to create a 
collaborative, safe and efficient process for repeat prescribing with the aim of improving practice 
processes, patient care and reducing waste. The toolkit also includes practical guidance on 
improving communication with patients about repeat prescribing, supported by good practice 
case studies, flow charts, action plan templates, and other useful resources. We have specifically 
highlighted the patient safety concerns around opioid prescribing within the toolkit, referencing 
a case example from a previous Regulation 28 Prevention of Future Death report in 2018. We 
hope that the toolkit shall be widely adopted and used by both GPs and Pharmacists working 
across England and beyond.  

We shall remain committed to this important area in prescribing and the support for members to 
maintain high standards but recognise that in this case these standards were not met, and our 
sincere condolences go to his family.    

Yours sincerely 

RCGP Honorary Secretary 

A5

Related reports

Other reports by Alison Mutch

See all →

More reports categorised “Alcohol, drug and medication related deaths”

See all →

Track Alcohol, drug and medication related deaths

See every Prevention of Future Deaths report matching Alcohol, drug and medication 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.