Prevention of Future Deaths reports · 2025

Kaine Fletcher

Regulation 28 report to prevent future deaths, reference 2025-0363, written 17 Jul 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report17 Jul 2025
Reference2025-0363
DeceasedKaine Fletcher
CoronerAlexandra Pountney
Coroner areaNottinghamshire
CategoryEmergency services related deaths (2019 onwards) · Police related deaths · Mental Health related deaths
Organisation namedNottinghamshire Healthcare NHS Foundation Trust
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:  

1  Chief Executive, East Midlands Ambulance Service 

2  Chief Constable for Nottingham and Nottinghamshire Police  

1  CORONER 

I am Ms Alexandra Pountney, Assistant Coroner for the coroner’s area of South Yorkshire 

(West) (sitting in Nottingham and Nottinghamshire coroner’s area). 

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 

An investigation into the death of Kaine Regan FLETCHER was opened on 28 September 

2022, and the final inquest hearing is currently being heard by me, sitting with a jury. The 

final inquest hearing started on 30 June 2025 and is due to conclude on 25 July 2025.  

The evidence is currently ongoing. 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 4  CIRCUMSTANCES OF THE DEATH 

Kaine was a 26-year-old male with a diagnosis of Paranoid Personality Disorder and a 

history of substance misuse.  

On 2 July 2022, Kaine called the police via 999 making threats to kill, if the police did not 

attend  to  him  at  his  mum’s  address.  A  double-crewed,  marked  police vehicle  attended 

Kaine and arrived at 16:00. On arrival, the response officers formed the view that Kaine 

was suffering an acute episode of mental illness, and that they may need to exercise their 

s.136 MHA 1983 powers to detain him. Kaine told the officers that he had recently used 

cocaine. The officers requested assistance from the Street Triage Team, a team formed 

through collaboration between Nottinghamshire Police and Nottinghamshire Healthcare 

NHS Foundation Trust, who duly attended to assess Kaine arriving at 17:04. The Street 

Triage  Team  comprised  of  one  police  officer  and  one  community  psychiatric  nurse, 

travelling  together  in  a  marked  police  car.  Kaine  was  assessed  by  the  community 

psychiatric nurse not to require a Mental Health Act Assessment, and so the police did not 

exercise their s.136 powers. Rather, having had his physical health checked by paramedics 

between approximately 17:27 and 17:42, he was conveyed by marked police car back to 

his residential dwelling at the YMCA in Hucknall. The police incident log confirmed that 

Kaine was at the property by 19:46. 

On 3 July 2022, at 00:04 and 00:16, respectively, two 999 calls were made by a member 

of Kaine’s family to EMAS due to a concern that he may have attempted to take his own 

life and, by the later call, that he was uncontactable by phone. EMAS advised the family 

member that the incident had been logged as a Category 3 response, and that there was an 

8 hour wait for an ambulance.  

At 00:33 a member of Kaine’s family called the police to report their concerns. A police 

resource  was  allocated  to  the  incident,  and  two  response  officers  in  a  marked  police 

vehicle arrived at the YMCA at 01:55 to conduct a ‘safe and well check’. Those officers 

quickly formed the view that Kaine was suffering an acute episode of mental illness and 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020 

 
 
 
 
 
 that  he  had  taken  illicit  substances,  namely  cocaine  and  nitrous  oxide.  To  begin  with, 

Kaine is amenable to attending hospital voluntarily for a Mental Health Act Assessment. 

He followed the police officers out of the building and got into their marked police car. 

The  situation  changed  rapidly  and  within  seconds  of  being  inside  the  vehicle,  Kaine 

vocalised his belief that the officers are not really police. The officers showed Kaine their 

ID,  but  the  situation  persisted  and  one  of  the  officers  detained  Kaine  using  her  s.136 

powers; handcuffs are applied. This happened at around 02:34. More units were requested 

and arrived at the scene. Kaine began to resist the detention, and there was then a period 

of approximately half an hour where Kaine was being restrained by officers. The restraint 

continued  as  officers  attempted  to  gain  effective  control  of  Kaine  so  that  they  could 

convey him to a place of safety by police vehicle.  

During  the  period  of  restraint,  Kaine’s  physical  condition  deteriorated,  and  at  03:03 

EMAS are called when the police recognise that he was displaying symptoms of Acute 

Behavioural Disorder. The incident was then deemed a medical emergency.  

EMAS arrived on scene at 03:18. Kaine was pre-alerted to the Queens Medical Centre 

Resuscitation Department and conveyed there by ambulance. He arrived at 03:47.  

Despite  the  best  efforts  of  the  medical  teams  at  QMC,  Kaine  had  developed 

rhabdomyolysis  and  went  into  multi-system  organ  failure,  which  culminated  in  an 

unsurvivable cardiac arrest. Kaine died at 09:46 on 3 July 2022.  

The cause of death provided by the Home Office Pathologist is: 1(a) the physiological 

effects  of  exertion  following  a  period  of  restraint,  combined  with  cocaine  and  other 

substances.  

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020 

 
 
 
 
 
 
 
 
 
 
 5  CORONER’S CONCERNS 

During the course of the inquest I heard evidence 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:  

Confusion over applicable local policy and working standards for dealing with s.136 

detention  

I am concerned that there is a lack of understanding by the police and EMAS on local 

policy and working standards for dealing with s.136 detention.  

At  the  outset  of  this  investigation,  a  direction  was  given  for  disclosure  of  “Local 

memoranda or  policies  concerning how  EMAS  and Notts police jointly manage health 

incidents”. In response to that direction, a number of policies were disclosed, including a 

document entitled “Nottingham and Nottinghamshire Multi-Agency Policy & Procedure 

Review  Group  Memorandum  of  Understanding:  Joint  Agency,  sections  135  and  136 

Mental Health Act 1983 Procedures”. Various versions of this policy were disclosed to 

the coroner, including a 2018, 2021 and 2024 version. 

During the course of the inquest so far,  I heard  evidence  from both the  police and the 

ambulance service in relation to the local policy for managing s.136 incidents. The police 

and  the  ambulance  service  do  not  share  an  understanding  of  which  policy  they  are 

expected to adhere to and whether there is a joint local policy. The police consider that 

the document above (as amended) is the applicable framework, whilst EMAS are currently 

unable to tell me if this policy has agreed to by them, notwithstanding that they appear as 

one of the agencies that formed part of the working group for each version of the MOU. 

The witness who gave policy evidence on behalf of EMAS told me that they only work to 

their own internal local standard, which is different to that in the MOU.  

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020 

 
 
 
 
 
 
 
 Persons  detained  under  s.136  of  the  Mental  Health  Act  1983  are  some  of  the  most 

vulnerable  in  society.  Their  liberty  has  been  removed,  and  they  are  reliant  upon  state 

agencies to protect their right to life. I am extremely concerned that there is no joined up 

thinking,  or  understanding,  between  the  police  and  the  ambulance  service  as  to  which 

policy and which working standards apply when furthering the protection of that right. I 

am concerned that this lack of basic understanding of policy and working standards by 

emergency services, if it persists, poses a risk of preventable future deaths.  

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. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report,  

namely by 11 September 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. 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020 

 
 
 
 
 
 
 
 
 8  COPIES and PUBLICATION 

I have sent a copy of my report to: 

Kaine’s family 

All other IPs 

Chief Executive, East Midlands Ambulance Service 

Chief Constable for Nottingham and Nottinghamshire Police  

who may find it useful or of interest. 

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.  

She may send a copy of this report to any person who she 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 

 Dated: 17 July 2025 

Ms Alexandra Pountney 

Assistant Coroner 

South Yorkshire (West) 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2020

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 East Midlands Ambulance Service (PDF)
Confidential  

Alexandra Pountney  
Assistant Coroner for the Coroner’s 
area of South Yorkshire (West) 
(Sitting in Nottingham and 
Nottinghamshire Coroner’s area)  

Trust Headquarters 
1 Horizon Place 
Mellors Way 
Nottingham Business Park 
Nottingham 
NG8 6PY 

3 September 2025 

Dear Ms Pountney 

Report regarding the case of Mr Kaine Regan Fletcher deceased  

Thank you for your letters dated 17 and 25 July 2025, regarding the Regulation 
28: Prevention of Future Death Report following the inquest into the death of 
Mr Kaine Regan Fletcher. 

I acknowledge the concerns raised and offer the following clarifications and 
commitments. 

I would like to assure you that the Trust takes all matters relating to patient 
safety extremely seriously, including those arising from HM Coroner’s inquests. 
As a Trust, East Midlands Ambulance Service (EMAS) is committed to learning 
from such events to improve our services and prevent future harm. 

The concerns highlighted in your report have been reviewed and discussed by 
the Trust’s Incident Review Group, which routinely considers issues raised 
through inquests and Prevention of Future Death reports. This process ensures 
that lessons are identified and appropriate actions are taken to address any 
systemic or procedural shortcomings. 

The Trust remains committed to continuous improvement and transparency in 
our efforts to safeguard patients and uphold the highest standards of care. 

Page 1 of 5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Matters of Concerns raised on 17 July 2025 

Confusion over applicable local policy and working standards for dealing with 
s.136 detention. I am concerned that there is a lack of understanding by the 
police and EMAS on local policy and working standards for dealing with s.136 
detention.  

EMAS acknowledges His Majesty’s Coroner’s concern regarding the lack of 
clarity and shared understanding between agencies on the applicable local 
policy and working standards for s.136 Mental Health Act detentions. While 
EMAS has been operating under a Regional Mental Health conveyance policy 
since May 2021, developed in consultation with regional Police Forces, Mental 
Health Trusts, and Approved Mental Health Professional (AMHP) services, there 
appears to be a disconnect in awareness and implementation across partner 
agencies. 

EMAS is committed to continuous improvement and ensuring the highest 
standards of patient safety and governance. In response to the issues 
identified, EMAS has initiated a retrospective audit of all operational 
Memoranda of Understanding (MoUs) received and implemented across the 
organisation. 

The purpose of this audit is to: 

•  Ensure appropriate governance is in place for each MoU. 
•  Verify implementation and operational alignment with agreed 

• 

protocols. 
Identify gaps or inconsistencies in practice that may pose risks to patient 
safety. 

•  Strengthen inter-agency collaboration through clear, accountable 

agreements. 

This audit is being conducted in collaboration with relevant stakeholders and 
partner organisations. Findings will be reviewed by the EMAS Clinical 
Governance and Risk Management teams, and any necessary actions will be 
taken to address deficiencies, update procedures and reinforce staff training. 

The Trust is committed to learning from this process and will incorporate the 
outcomes into our broader quality improvement framework. A summary of the 
audit findings and actions taken will be shared with the relevant bodies upon 
completion.  

Page 2 of 5 

 
 
 
 
 
 
 
 
 
 
 
 Actions and Learning: 

EMAS will initiate a joint fact-finding exercise with Nottinghamshire Police and 
Nottinghamshire Healthcare NHS Foundation Trust (NHCFT) to clarify existing 
protocols and identify gaps in understanding. 

EMAS will lead the development of a refreshed joint EMAS conveyance 
protocol, ensuring full consultation and sign-off by all system partners within 
the EMAS region. 

EMAS will improve internal and external communication regarding regional 
policies to ensure consistent application and awareness across all stakeholders. 

Matters of Concerns raised on 25 July 2025 

Lack of joint agency policy/cross-sector working on Acute Behavioural 
Disorder/Disturbance 

EMAS recognises the absence of a formalised joint agency policy for managing 
Acute Behavioural Disorder (ABD). Currently, EMAS identifies ABD through 
NHS Pathways disposition codes and dispatches a Category 1 response when 
appropriate. Nottinghamshire Police have a training package for recognising 
ABD symptoms and initiating ambulance support, but there is no unified 
protocol guiding joint operational response. 

Actions and Learning: 

EMAS will continue its participation in the Police Regional Clinical Governance 
Forum to align training and response protocols for ABD. 

EMAS will work with regional police forces and health partners to explore the 
development of a joint operational framework for ABD management. 

EMAS will review internal clinical guidance to ensure consistency with police 
training and national best practice. 

Lack of agreed joint agency policy between EMAS and the police on s.136 MHA 
1983 detentions 

EMAS acknowledges the Coroner’s concern and confirms that while regional 
workstreams under the Right Care Right Person (RCRP) initiative have made 
progress, a formal joint policy with Nottinghamshire Police is not yet in place.  

EMAS has led regional improvements in s.136 conveyance, which have been 
nationally recognised, but further work is needed to formalise these 
arrangements locally. 

Page 3 of 5 

 
 
 
 
 
 
 
 
 
 
 
 
 The Trust is undertaking a retrospective audit of all operational MoUs received 
to ensure appropriate governance and implementation. 

Actions and Learning: 

EMAS and Nottinghamshire Police will co-lead the drafting of a joint s.136 
conveyance protocol, with input from system partners including Integrated Care 
Boards (ICBs) and Mental Health Trusts. 

EMAS will incorporate lessons from the RCRP initiative into the new protocol to 
ensure best practice is embedded. 

EMAS will establish a regular review mechanism to monitor the effectiveness of 
joint working on s.136 detentions. 

Mental Health Services – ‘the gap’ 

EMAS notes the Coroner’s identification of a service gap for patients with dual 
diagnosis (mental health and substance misuse). While commissioning 
responsibility lies with NHCFT and the ICB, EMAS recognises the importance of 
supporting these patients effectively. However, to date there are no formal 
Mental Health pathways with NHCFT for EMAS to access. 

Due to increased demand for Mental Health support via the ambulance service, 
in 2022 EMAS secured external funding through regional ICBs to ensure 24/7 
coverage of Mental Health Clinicians within the Emergency Operations Centre. 
Furthermore, with funding from Nottinghamshire ICB, EMAS secured a Mental 
Health Response Vehicle, staffed with a qualified Paramedic and Mental Health 
Practitioner supported by NHCFT in 2024. This service was launched in October 
of that year and has shown excellent outcomes for patients receiving the right 
care, by the right people, at the right time. 

Actions and Learning: 

EMAS will continue to support system partners by providing on-scene care for 
patients with dual diagnosis and referring to available local pathways. 

EMAS will engage with commissioners to highlight operational challenges and 
advocate for service development to address this gap. 

EMAS frontline staff currently receive mandatory Mental health Training which 
includes acknowledgment of dual diagnosis. This training is currently under 
review and we will use this opportunity to strengthen the guidance around dual 
diagnosis in order to manage these presentations safely and compassionately. 

I hope that this response provides you with the appropriate level of assurance 
in relation to our commitment to continuous improvement of our services.  

Page 4 of 5 

 
 
 
 Please do not hesitate to contact me should you require any additional 
information or any clarification, in connection with the above.  

Yours sincerely  

Chief Executive 

Page 5 of 5
Response from Nottingham and Nottinghamshire Police (PDF)
By email only:

Date 11/09/25

Dear HMC Pountney,

Force Headquarters
Sherwood Lodge
Arnold
Nottingham
NG5 8PP

RE:  Regulation 28 notice following inquest of Mr Kaine FLETCHER

First  and  foremost,  I  want  to  reiterate  our  sincere  condolences  to  the  family  of  Kaine  Fletcher.  Our
thoughts remain with all those affected by his death.

Making  sure  we  operate  in  the  safest  way  possible  is  of  paramount  importance  to  us.  We  are
committed to take all the necessary steps to keep the public and our workforce safe.

We have reflected carefully on the findings of the inquest and scrupulously considered the details of
the two Regulation 28 notices you have issued.

Outlined below is a detailed summary of the action taken in response to each area of concern raised
within the Regulation 28 notices.

Regulation 28 notice - 17 July 2025

This  notice  was  issued  during  the  inquest  to  both  Nottinghamshire  Police  and  East  Midlands
Ambulance Service (EMAS).

It  outlined  your  concern  about  an  apparent  lack  of  understanding  by  the  police  and  EMAS  on  local
policy and working standards for dealing with s.136 detention.  Specifically, our differing  positions on
the application of the below document:

Nottingham  and  Nottinghamshire  Multi-Agency  Policy  &  Procedure  Review  Group
Memorandum of Understanding: Joint Agency, sections 135 and 136 Mental Health Act 1983
Procedure.

As was clarified in the course of the inquest and reflected in your later Regulation 28 notice dated 25
July  2025,  Nottinghamshire  Police  had  implemented  this  policy  since  its  inception.  However,  we

 recognise  the  concern  outlined  in  your  later  notice  that  a  multi-agency  policy  cannot  be  said  to  be
effective unless all parties named in the policy have implemented it.

We have consulted with colleagues from EMAS to address this issue and suggested several potential
remedies.  We  have  been  advised  by  the  EMAS  Head  of  Mental  Health,  that  after  careful
consideration  their  Chief Executive  has  directed that  they  will not  be  seeking to  implement  or refine
the existing multi-agency policy and procedure for Nottingham and Nottinghamshire.

EMAS have advised that instead they intend to lead on the creation of a new regional Mental Health
(MH)  conveyance  policy  with  system  partners,  and  in  the  interim  continue  to  utilise  their  current
regional policy. We understand this is due to complexities across county boundaries where localised
agreements may  cause confusion  resulting in  less optimal  patient experience.  We remain  in regular
contact  with  EMAS  and  will  fully  support  the  development  of  this  new  regional  policy  being
implemented in the most expedient way possible.

The EMAS Head of Mental Health has confirmed they will be personally leading on this work and has
already had discussions with our tactical lead for mental health to begin joint work on the new regional
document.

In  the  interim,  we  have  introduced  robust  internal  governance  arrangements  to  monitor  all  s.136
conveyance, which is covered in greater detail below. I am reassured that the steps described in this
report  provide  comprehensive  oversight  of  our  actions  in  this  area  and  minimise  any  risks  in  the
intervening period between now and the implementation of the new regional policy.

Regulation 28 notice - 25 July 2025

This notice was issued at the conclusion of the inquest to all of the recipients below:

1.  Chief Executive, East Midlands Ambulance Service
2.  Chief Constable, Nottinghamshire Police
3.  College of Policing
4.  Chief Executive, Nottinghamshire Healthcare NHS Foundation Trust
5.  Secretary of State for Health and Social Care

This notice outlined six specific areas of concern which are addressed individually below in the order
they appear within the notice.

1.  Lack of joint agency policy/cross-sector working on Acute Behavioural

Disorder/Disturbance

This  aspect  of  the  notice  outlined  concerns  about  the  2022  position  statement  issued  by  the  Royal
College of Psychiatrists, and the apparent lack of action to implement the recommendations contained
therein, specifically in relation to joint agency working on ABD.

The  notice  recognised  this  lack  of  joint  agency policy  on  ABD  was  not  confined  to  Nottinghamshire
and appeared to be the position for the whole East Midlands region and indeed nationally.

To improve our understanding of the national policing position on this issue, we contacted the Mental
Health Co-ordinator from the College of Policing. They explained that whilst the College were aware
of  the  position  statement  from  the  Royal  College  of  Psychiatrists  it  had  to  some  extent  been

 superseded  by  subsequent  literature  on  ABD  and  some  of  its  recommendations  were  not  widely
accepted at the time of its publication.

They  also  explained  that  as  the  presentation  of  ABD  is  a  medical  emergency  the  Royal  College  of
Emergency Medicine (RCEM) were in fact the foremost medical experts to provide guidance on this
area. I understand the College of Policing are aligned with the RCEM in their understanding of ABD
and are both in agreement that this is a medical issue which health professionals should lead on. As
such  it  is  incumbent  on  health  agencies,  rather  than  policing,  to  lead  on  the  development  of  joint
agency  working  required  in  this  area.  This  is  our  understanding  as  to  why  there  is  currently  no
national joint agency policy on ABD, but the College of Policing are better placed to provide greater
clarity and detail in this area.

We  are  keen  to  ensure that  here  in  Nottinghamshire  there  is  clarity  between  front  line  staff  from  all
agencies on how to respond to ABD related incidents. As was provided in evidence to the inquest, we
have already undertaken a great deal of work within Nottinghamshire Police to train our officers and
staff to spot the signs and symptoms of ABD and recognise it as a medical emergency.

In response to the specific concern raised within this notice we have had discussions with the EMAS
Head of Mental Health, about how we can work together on a joint agency policy on ABD. Through
these  discussions  we  have  identified  that  some  activity  is  already  ongoing  through  the  Regional
Clinical Governance Forum on this exact issue. EMAS have advised us that they consider this forum
to be the best route to address the issue of concern.

We  have  contacted the Deputy  Medical  Director who  supports this  group,  who has confirmed  some
work  is  already  ongoing  in  relation  to  multi-agency  collaboration  on  ABD.  We  have  now  arranged
meetings  to  establish  how  Nottinghamshire  Police  can  actively  contribute  to  this  work  and  have
identified  a  senior  officer  to  attend  the  next  Regional  Clinical  Governance  Forum  to  support  and
accelerate the progression of this work.

2.  Lack of agreed joint agency policy between EMAS and the police on s.136 MHA 1983

detentions

This element of the Regulation 28 notice was a refinement of the first notice issued on 17 July 2025.
Our response to this element is provided above in relation to this earlier notice.

3.  Police use of an ambulance as the mode of conveyance for s.136 detainees

This  section  of  the  notice  outlined  concerns  about  the  frequency  with  which  an  ambulance  was  not
used as the mode of conveyance following a s.136 MHA detention. The notice also detailed concerns
about  a  potential  training  issue  due  to  the  lack  of  awareness  and  adherence  to  the  policy  that  an
ambulance should be used to convey all s.136 detainees.

We have taken these concerns extremely seriously and immediate action was taken during the course
of  the inquest  when this issue  became apparent. We have  implemented a  multifaceted  approach to
rapidly improve performance in this area through the steps outlined below.

   Rapid  review  of  compliance  indicated  an  ambulance  had  only  been  requested  for  s.136
conveyance  on  51%  of  occasions  between  July  24  and  July  25.  Officer  awareness  and
adherence to policy identified as issues which needed to be improved.

  Communications  message  from  our  Assistant  Chief  Constable  personally  to  all  operational
police  officers  reminding  them  that  all  s.136  MHA  detentions  should  be  transported  by
ambulance.  This  was  published  on  the  intranet  news  page,  included  in  the  force-wide
newsletter  “In  The  Know”,  included  in  the  control  room  newsletter  “Keeping  You  Informed”,
and emailed directly to all police officers.

  All  training  materials  for  new  recruits  and  experienced  officers  has  been  refreshed  so  that
whenever anything on s.136 MHA is delivered a reminder is given that conveyance should be
by ambulance.

  Briefing slides were developed and a face-to-face briefing has been delivered to all response
officers  by  their  sergeants.  Registers  were  taken  to  ensure  all  officers  were  captured  and  a
central register was collated to ensure everyone received these key messages.

  Any  instance  when  an  ambulance  is  not  used  for  s.136  conveyance  is  now  scrutinised  by  a
Police Inspector. Where  a  rationale is  either  not recorded,  or deemed not appropriate, these
are followed up directly with the officer concerned by the Inspector.

  New compliance governance has been introduced with new review regime as below:

o  Daily reviews of all s.136 detention conveyance by Street Triage Team Sergeant
o  Weekly  review  of  themes  and  issues  by  our  dedicated  Police  Inspector  based  within  the

Vulnerability Hub

  A  new monthly  s.136 Conveyance Oversight Panel  has  been  established.  This  is  chaired by
the  Contact  Management  Superintendent  or  Chief  Inspector  and  provides  scrutiny  and
accountability  for  all  of  the  measures  outlined  above.  EMAS  are  also  invited  to  attend  this
meeting so emerging themes can be shared and jointly problem solved.

  Since  the  direction  from  the  ACC  on  10/07/25  there  have  been  60  s136  detentions  in
Nottinghamshire.  Of  those  49  (82%)  were  conveyed  by  ambulance.  The  11  which  were  not
have  all  been  carefully  scrutinised  through  the  above  process.  A  summary  of  the  review
outcomes is below:

o  Seven occasions when EMAS were unable to provide an ambulance within 30 minutes

o  Four occasions when it was a Police decision not to use ambulance:

  Two  of  these  have  National  Decision  Model  (NDM)  compliant  rationale  explaining

why an ambulance was not suitable in the circumstances.

  Two had a rationale which the reviewing Inspector felt was not sufficient to deviate

from policy so appropriate feedback was provided to the two officers.

I believe this is a robust and expedient response to the concerns which have been highlighted. I am
also  reassured  that  the  measures  in  place  will  ensure  a  high  level  of  compliance  in  the  future.  The
data captured shows officers had done what was expected in all but two of the sixty occasions since

 the  refreshed  communications  by  the  Assistant  Chief  Constable.  This  represents  an  effective
compliance rate of 97%.

We  are  grateful  for  your  identification  of  this  matter,  which  I  believe  has  been  robustly  addressed
through a substantial governance framework.

4.  Police training on s.136 MHA 1983 detention and mental health

This concern related to an apparent lack of national training for police officers on the correct wording
to communicate a decision and the reasons for a s.136 detention to the detainee. It also referenced
concerns  about  specific  training  relating  to  persons  who  are  struggling  with  their  mental  health  and
who may be under the influence of illicit substances.

In response to this concern, we have had a meeting with Mental Health Co-ordinator from the College
of  Policing  who  has  directed  us  to  a  section  of  Approved  Professional  Practice  (APP)  which  does
provide some guidance in this area. Mental health – detention | College of Policing

Based  on  the  APP  guidance,  we  have  now  developed  some  specific  guidance  for  officers  on  the
correct wording to use at the point of exercising s.136 powers. We are in the process of briefing and
training our officers on the importance of using this wording. This change has also been woven into all
new recruit and existing officer training. Face to face briefings are also being delivered by Sergeants
to all response officers.

This  training  also  includes  a  reminder  to  officers  that  persons  who  are  struggling  with  their  mental
health,  and  are  also  under  the  influence  of  illicit  substances,  may  present  in  a  different  or  more
extreme way, thereby increasing their vulnerability.

When using s136, the person must be told the below in a considered and empathetic manner:

 They have to come with the police because of the officer’s concern for their wellbeing

 The Police have a power to make them come with them under section 136 of the Mental

Health Act



It is not a criminal arrest / they are not under suspicion for any crime

 The have to go with police because of concern for their safety and / or safety of others

 They will be taken to a place of safety (specify where)

 At  the  place  of  safety,  they  will  be seen  by  health  professionals  for  a  mental  health

assessment

Suggested wording (example to adapt to situation)

‘You are going to be taken to place of safety (specify where) because I am concerned for your
wellbeing and /or the safety of others. I have a power to take you there under s136 of the Mental
Health Act and you must come with me. You are not under arrest for any crime, but you have no
choice and must come with me to (specify place of safety) where you will be seen by health
professionals for a mental health assessment.’

 5.  The availability of the Street Triage Team

This section of the notice outlined concerns that the operating hours of the Street Triage Team (STT)
in  Nottinghamshire  were  based  on  detailed  analysis  of  demand  data  from  2017.  Whilst  annual
assessments of our teams are conducted through our Force Management Statement process, led by
our  corporate  services  department,  a  deeper  assessment  of  demand  versus  assets  is  now  being
undertaken.

I feel it impotant to highlight that the Street Triage Team (STT) approach to mental health incidents is
not  a  national  offer.  This  was  a  pioneering  approach  established  in  Nottinghamshire  in  2014,  which
was amongst the first of its kind in the country.

Whilst  some  other  forces  now  have  a  smilar  offer  it  is  my  understanding  that  the  majority  of  police
forces  in  the  country  do  not  deploy  an  STT  car  at  all.  Whilst  I  am  aware  of  some  forces  that  have
mental health professionals in their control room to provide remote advice, the partnership of a Police
Officer  and  Community  Psychiatric  Nurse  (CPN)  physically  deploying  together  to  live  incidents  is
exceptionally rare.

The  use  of  s.136  MHA  is  ultimately  a  policing  power.  Whilst  guidance  stipulates  advice  and
consultation  with  helath  professionals  must  take  place  the  provision  of  an  STT  vastly  exceeds  this
requirement  for  the  benefit  of  the  communities  of  Nottinghamshire.  We  are  very  proud  of  our
investment  in  the  Street  Triage  Team  to  provide  an  enhanced  service  for  the  people  of
Nottinghamshire, which does not exist througout the country.

In response to the specific concern about the operating hours of the STT we have conducted some
demand pattern analysis of both mental health incidents and the timing of s.136 detentions. This data
shows that the volume of mental health incidents reported to the control room declines sharply after
midnight.  However,  scutinry  of  the  timing  of  s.136  power  being  used  indicates  the  reduction  after
midnight is not as pronounded as in the incident data. Whilst there is a notable decline after midnight
it does not significantly taper off until 0300hrs.

Early indiciations from our demand analysis work has directed us to the exploration of extending the
hours of STT until 0300hrs. As this is a partnship with colleagues from the NHS the feasibility of this
will need to be carefully considered in collaboration with our partners. I have asked for this data to be
shared  with  NHS  colleagues  so  dicussions  can  commence  about  the  achievability  of  extending  our
joint STT provision as soon as possible.

6.  Mental Health Services – ‘the gap’

This  concern  referred  to  the  perceived  ‘gap’  in mental  health  services  for  those  people who  have  a
dual diagnosis of a recognised mental health condition, combined with a substance misuse diagnosis.
We have carefully read these concerns and discussed them with colleagues from EMAS. We are in
agreement this aspect of the notice is not a matter for Nottinghamshire Police and will be addressed
by the other recipients of the Regulation 28 notice.

I  hope  that  the  information  contained  within  this  response  provides  assurance  to  you  and  Mr
Fletcher’s family  that  we,  as  an  organisation  have  heard  and  understood  the  significant  concerns
raised throughout and as a consequence of this inquest, and that we are committed to continuing to
make these important improvements to services and processes for future service to the public.

 Yours sincerely,

Temporary Chief Constable

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