Prevention of Future Deaths reports · 2025

Andrew Brown

Regulation 28 report to prevent future deaths, reference 2025-0258, written 23 May 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report23 May 2025
Reference2025-0258
DeceasedAndrew Brown
CoronerTimothy Brennand
Coroner areaManchester (West)
CategoryAlcohol, drug and medication related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text recovered by OCR from a scanned PDF. OCR is imperfect: check anything you rely on against the source PDF. 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:

1
Secretary of State for the Home Department
Home Office
2 Masham Street
LONDON
SW1P 4DF

CORONER

I am Mr Timothy W Brennand, HM Senior Coroner for the coroner area of Manchester West.

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.

INVESTIGATION and INQUEST

On 14 August 2023 I commenced an investigation into the death of Andrew Alexander Roger BROWN
aged 45. The investigation concluded at the end of the inquest on 19 April 2024.

The medical cause of death was determined to be:

a

I returned a narrative conclusion that Andrew Alexander Roger BROWN died as the consequence of a
self-administered quantity off in circumstances where his intentions remain
unclear.

Reporting restrictions were imposed in this case because of an ongoing criminal investigation in the
United Kingdom, Europe and the United States of America, the case being one of a cluster of eight
similar cases upon the Greater Manchester West jurisdiction.

Reporting restrictions were lifted on the 19th of Apri! 2024.

This report is being published following updates from Greater Manchester Police and suicide
prevention organisations received on the 14th of March 2025.

CIRCUMSTANCES OF THE DEATH

Between January and June 2023, for reasons that could not be established, the deceased had
acquired and retained amongst his possessions at his residence, at least 3 consignments of the
registered poison EE obtained on the internet. He had a medical history that
included episodic mixed anxiety and depressive disorder, his relapse profile being linked to
dysfunctionality within his domestic matrimonial circumstances.

On the morning of the 9th of August 2023, the deceased was discovered by a family member,
collapsed and unresponsive within the bedroom of his residence at Po Wigan.
Paramedics attended promptly, establishing the deceased to be dead and beyond attempted
resuscitation.

Regulation 28 — After Inquest.
Document Template Updated 30/07/2021

A Greater Manchester Police investigation concluded there to be an absence of evidence that
supported a viable suggestion of there being third party involvement or suspicious circumstances in
the case. Beyond an ‘Advanced Decision to Refuse Treatment’ document found by paramedics on the
deceased’s bed, no direct evidence of the deceased’s intent was recovered or could be identified from
the evidence secured at the scene or otherwise.

A forensic post mortem examination established the sole cause of death to have been
HE oxicity, albeit the evidence could not establish either directly or by inference in what
quantity, at what time, in what circumstances and for what reason the deceased had self-
administered an amount of MY that could be presumed to have been dissolved in
liquid and thereafter ingested at his own hand. Of a number of possible inferences that could be
drawn as to his intentions, including his actions being influenced by illogical, strange and disordered
thinking in the context of emotional dysregulation arising from his personal circumstances and mental
health history, the more likely factor that motivated his actions was a manifestation of fleeting, ill-
considered, irrational self-harming ideation acted out as a means of displaying a desire for rescue and
help, the deceased naively failing to appreciate or understand the potential lethality of ingestion of
even a modest quantity of MM his death being an inadvertent and unintended
consequence of his deliberate actions.

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 untess action is taken. In the circumstances it is
my statutory duty to report to you.

The MATTERS OF CONCERN are as follows:
{brief summary of matters of concern)

1 i; a reportable poison as well as a reportable explosives precursor within the
terms, meaning and effect of Part 4 of Schedule 1A of the Poisons Act 1972 with the consequence
that:
a. The Poisons Act 1972 sets out the legal obligations in relation to the sale, purchase, and use of
these chemicals for suppliers, professional users and members of the public.
b. The published Guidance (commenced in 2014 and updated in August 2024) does not give specific
guidance or suggested training to sellers, particularly in” acquired by members of
the public, particularly over ‘online marketplaces’ in circumstances of the purchase on a ‘one off’
basis for the means of self-harming.
c. Whilst there is a legal duty on persons selling this substance to report “suspicious” transactions
within 24 hours to the Home Office, the purchase of small quantities is being presumed to be
connected to the many legitimate uses of the substance (such as food preservation, fertilizer etc)
rather than in fact, being evaluated as a member of the public seeking purchase of modest quantities
used as their chosen means by which to end life.
d. The current Home Office guidance and supporting video, leaflet and posters do not reference

as a specific example of concern and focuses on the phenomenon of ‘malicious’
misuse and not deliberate misuse in the sense of suicide/self-harm.

2. The police investigation into one UK based source of supply revealed in 247 cases separate
supplies of 500 grams of less of MMto customers in the UK and Europe, police established
that 85 of these individuals who were traceable had either died as the consequence of self-ingestion
of the substance, or had purchased it with a view to having the means to use this method to end

Regulation 28 — After inquest
Document Template Updated 30/07/2021

their life in circumstances where:

a. the vendors of the HE were not aware of this potential misuse of the substance.
b. the small quantities being purchased had been incorrectly evaluated to be an increase in
individuals pursuing recreational home-curing/food preservations as a hobby, being an artefact of
‘lockdown’ living following the COVID national pandemic emergency.

c. Vendors were unaware that their website/details were being distributed as part of internet
information platforms designed to aid, abet, assist or promote suicide methods.

3. The police investigation revealed the ability of members of the public to access a number of
websites, primarily created in the USA, Canada and Mexico that promoted information as to how to
access:

a. Poisons that could bring about death

b. How, in what way and with with other necessary preparations (in particular -antiemetic
medications) the poisons should be administered.

c. Sourcing such poisons/chemicals/medications in the Uk and abroad.

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.

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report,
namely by May 16, 2025. 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.

COPIES and PUBLICATION
I have sent a copy of my report to the Chief Coroner and to the following Interested Persons

1. The family of Andrew Alexander Roger BROWN
2. HH) Alexia Durran - The Chief Coroner of England and Waies
Chief Coroner's Office
11" Floor, Thomas More Building
Royal Courts of Justice
Strand
LONDON

T have also sent it to

Greater Manchester Mental Health
Greater Manchester Police
Shevington Surgery

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.

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

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.

Dated: 23'4 May 2025

/

Mr Timothy W Brennand
HM Senior Coroner for
Manchester West

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

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 The Home Office (PDF)
OFFICIAL 

Mr Timothy Brennand 
HM Senior Coroner for Manchester West 
Coroner’s Office Greater Manchester West 
First Floor Padeborn House 
Howell Croft North 
Bolton 
BL1 1QY 

By email: 

Dear Mr Brennand, 

Security Minister 
2 Marsham Street 
London
SW1P 4DF
www.gov.uk/home-office

22 July 2025  

TIMOTHY W BRENNAND REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

Thank you for the Regulation 28 report, dated 23 May 2025, that was sent to the Home Secretary following 
the  inquest  into  the  death  of  Andrew  Brown,  who  tragically  died  on  9th  August  2023.  I  am  responding  on 
behalf of the Home Secretary, in my capacity as the Minister of State for Security.  

I would like to offer my heartfelt condolences to Mr Brown’s family and loved ones – though almost two years 
have passed, I understand that the pain of such a profound loss endures. Thank you for sharing the concerns 
raised  in  your  report,  which  I  have  carefully  noted.  I  am  grateful  to  you  for  bringing  these  matters  to  my 
attention. 

Your  report  has  raised  several  matters  of  concern,  which  are  relevant  to  both  the  Home  Office  and 
Department of Health and Social Care, namely: 

•  There is no specific guidance or training for sellers of the substances in question, particularly over 
online  marketplaces  in  circumstances  of  the  purchase  on  a  ‘one  off’  basis  for  the  means  of  self-
harming.  Additionally,  current  guidance  does  not  specifically  reference  these  substances  as  a 
concern. 

•  Potentially suspicious sales of these substances are often evaluated as being for legitimate uses. 
•  Vendors  are  often  not  aware  of  its  potential  for  misuse,  or  that  their  details  are  being  shared  on 

suicide-related internet forums.  

•  Members  of  the  public  are  able  to  access  websites  hosted  overseas  that  promote  information  on 

methods of suicide and information on how to source poisons that can bring about death. 

As your report highlights, there have been several tragic cases involving these substances. The substances 
involved in your report are “reportable” substances listed in Part 4 of Schedule 1A of the Poisons Act. This 
means they can be purchased by members of the public, but suspicious transactions must be reported by 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 retailers  if  there  are  questionable  grounds  for  suspecting  it  is  intended  for  any  illicit  use.  The  aim  of  the 
legislation is to control chemicals and poisons that can be used to cause harm, while still allowing members 
of the general public and businesses with a legitimate need to access these substances to continue their 
activities.  It  falls  under  my  portfolio  as  Security  Minister  as  the  legislation  supports  delivery  of  the 
Government’s counter-terrorism strategy, CONTEST. 

The Poisons Act was amended in October 2023 to strengthen controls and enhance our suspicious activity 
reporting requirements. This includes new obligations for online marketplaces. As well as the requirement to 
report  suspicious  transactions,  economic  operators  supplying  any  reportable  substances  must  now 
demonstrate  that  their  personnel  are  aware  of  which  of  their  products  contain  listed  substances  and  are 
instructed on their obligations.  

Concerns about these substances have been raised through coroner’s reports and other correspondence. In 
response, the Home Office has been working with other government departments to limit access to these 
substances and raise awareness among suppliers about the risks of misuse. In a recent letter to 

, Assistant Coroner for Surrey, I outlined the Home Office’s response following another such incident. 
Since  then,  officials  from  the  Home  Office  and  the  Department  of  Health  and  Social  Care  (DHSC),  who 
manage  the  national  Suicide  Prevention  Strategy,  have  been  collaborating  to  assess  policy  options  and 
coordinate a cross-government response. This response builds on the existing measures that are already in 
place. 

Responding to the issues your report raises in turn: 

•  Guidance and assessment of suspicion:  

The substances in question are not routinely individually highlighted within government issued guidance in 
relation to their potential misuse for self-harm or suicide. This is to avoid bringing widespread attention to 
them.  However,  my  officials  have  engaged  with  selected  online  platforms  and  retailers  individually  to 
encourage them to voluntarily remove the sale of these substances to members of the public in their pure 
form and be vigilant for the possibility of purchase for self-harm or suicide. For all substances within scope 
of the Poisons Act, the Homeland Security Group works to improve retailer awareness of their legal obligation 
to report suspicious activity and to inform retailer sales practices. For example, we encourage suppliers to 
use declaration of use forms for sales of potentially harmful substances. This work will continue to ensure 
suppliers are meeting their obligations under the Poisons Act. 

Furthermore if, during the processing of suspicious activity reports, a safeguarding concern is identified by 
Counter Terrorism Policing, consideration will be given to disseminating this intelligence to police forces to 
consider a welfare check.   

To  target  potentially  harmful  acquisitions  from  overseas  merchants,  Border  Force  has  introduced  new 
guidance for its officers. This guidance operates within existing legal provisions. It sets out the actions officers 
can take if they receive any form of information suggesting that goods at the border contain items intended 
to  assist  with  suicide.  This  relies  on  Border  Force  working  closely  with  police  forces  and  other  relevant 
agencies to safeguard vulnerable individuals to the full extent possible. This work is complex, and Border 
Force will continue to monitor its policies, exploring opportunities to improve its ability to act where possible 
and to ensure that frontline Border Force staff who may encounter these items know what action to take and 
are supported on a case-by-case basis when required. 

•  Suicide-related online forums: 

2 

 
 
 
 
 
 
 
 
 
 
 As your report highlights, we are aware of the existence of a number of websites, hosted overseas, which 
promote  information  about  how  to  access  poisons  for  the  purposes  of  suicide.  As  of  17  March  2025,  the 
illegal content duties in the Online Safety Act (OSA) came into effect, which is an important and positive step 
in  addressing  a  range  of  online  harms.  Providers  in  scope  of  the  OSA  are  legally  required  to  implement 
measures to reduce the risks that their services are used for illegal offending and remove illegal content from 
their platforms where it does appear. This includes illegal content relating to the most serious and prevalent 
illegal content and activity such as terrorism, child sexual exploitation, inciting violence, and encouraging or 
assisting  suicide.  These  measures  are  designed  to  create  a  safer  online  environment  by  ensuring  robust 
systems and processes are in place to protect users from illegal content.  

The Online Safety Act applies to services even if the companies providing them are overseas, should they 
have links to the UK. This includes if the service has a significant number of UK users, if the UK is a target 
market, or if it is capable of being accessed by UK users and there is a material risk of significant harm to 
such users.  

Ofcom is the regulator for this regime. It has strong enforcement powers where providers fail to comply with 
their duties. Ofcom have launched several enforcement programmes to monitor compliance with the regime, 
including  an  investigation  into  a  service  linked  to  promoting  suicide  content1.  The  government  is  closely 
monitoring the implementation and effectiveness of the OSA and remains committed to strengthening our 
laws if it does not deliver the necessary protections to ensure a safer online environment.  

Thank you for bringing these important concerns to my attention. I hope that this response is helpful. Please 
be assured that the Home Office is actively working with relevant departments and partners to mitigate the 
dangers associated with these substances.  

Yours sincerely, 

Security Minister 

1 Ofcom investigates online suicide forum - Ofcom: https://www.ofcom.org.uk/online-safety/illegal-and-harmful-
content/ofcom-investigates-online-suicide-forum 

3

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