3. Memorandum from HM Prison Service
INTRODUCTION
1. The Prison Service welcomes the Joint
Committee's inquiry into this complex area and offers its full
co-operation and participation. Any death in custody is a terrible
tragedy that brings the Prison Service's duty of care to people
in its custody into sharp focus. The Human Rights Act has incorporated
the provisions of the European Convention on Human Rights into
UK law and the Prison Service is committed to its terms and is
determined to ensure that all those held in our custody are as
safe as possible. Reducing suicides and self-harm in prison is
a key objective and a great deal of work has been and continues
to be done in this area.
2. Deaths in prison remain a rare event.
Sadly, the largest proportion of those who die in custody take
their own lives (see Table 1 below). Good care and support from
staff saves many lives, but such instances go largely unreported.
141 prisoners were resuscitated following self-harm incidents
in 2002, which reflects a lot of staff effort and skill. The rate
of self-inflicted deaths in prison is substantially higher than
the rate of self-inflicted death in the community (although it
is not greater than that of people under supervision in the community).
3. An increasing number of vulnerable people
are passing through the Criminal Justice System and the general
prison population contains very large numbers of prisoners who
enter custody already struggling to cope with a wide range of
difficult issues. These include drug and alcohol abuse, family
background and relationship problems, social disadvantage or isolation,
previous sexual or physical abuse, and mental health problems.
Studies suggest, for example, that 90% of all prisoners have shown
evidence of at least one of the following: personality disorder,
psychosis, neurosis, and alcohol misuse and drug dependence. These
factors increase the likelihood of self-harm and suicide; indeed,
self-harming and suicidal behaviour often pre-date custody, and
may have started early in life. Statistics show that 20% of sentenced
men and 44% of women on remand report having attempted suicide
in their lifetime.
4. The Prison Service is taking forward
initiatives to help people deal with these issues and make them
more able to cope in the prison environment, and in the future
upon their release. But there are, regrettably, no simple solutions,
and the reasons for self-inflicted deaths are complex.
Q1. What are the main causes of deaths in
prisons? Are there any common factors? Are there particular aspects
of conditions of detention, or the treatment of detainees, or
the cultural background of prisoners or prison officers, that
contribute to:
Suicide and self-harm in prisons?
Other deaths or injuries in prisons?
1.1 Suicides in prison seem to be caused
by the combined effects of imported vulnerability, the exposure
of this vulnerability by aspects of prison regimes, the effects
of prison quality and continuing life events occurring once in
prison. Table 1 shows the number of deaths in custody during the
period 1998-2002:
Table 1
Year | Self-inflicted deaths*
| Deaths by natural/other
causes
| Total |
1998 | 82 | 56
| 138 |
1999 | 91 | 58
| 149 |
2000 | 81 | 63
| 144 |
2001 | 72 | 68
| 140 |
2002 | 94 | 71
| 165 |
Total | 420 | 316
| 736 |
| | |
|
*The term self-inflicted death includes deaths where it appears
that the death occurred as a result of a person's own actions.
1.2 In the calendar year 2003 to date (13 August), there
have been 61 self-inflicted deaths; and 49 deaths by natural/other
causes. In the financial year to date (13 August) there have been
31 self-inflicted deaths and 31 deaths by natural/other causes.
This compares to 55 self-inflicted and 47 natural/other cause
deaths at this time last calendar year and 36 self-inflicted deaths
and 25 natural/other cause deaths at this time last financial
year.
1.3 The most common method of self-inflicted death in
prison is hanging, which is likely to be related to the restriction
of access to other methods in a prison environment. The methods
of self-inflicted deaths (1998-2002) are shown in Table 2.
Table 2
Year | Sex |
Hanging | Overdose |
Cutting | Suffocation
| Food
refusal | Refused
medication
| Self-
stran-
gulation |
Arson | Total |
1998 | Male | 78
| 0 | 1 | 0 |
0 | 0 | 0 | 0
| 79 |
1998 | Female | 3
| 0 | 0 | 0 |
0 | 0 | 0 | 0
| 3 |
1999 | Male | 81
| 2 | 2 | 0 |
0 | 0 | 1 | 0
| 86 |
1999 | Female | 5
| 0 | 0 | 0 |
0 | 0 | 0 | 0
| 5 |
2000 | Male | 66
| 4 | 2 | 0 |
0 | 0 | 0 | 1
| 73 |
2000 | Female | 7
| 0 | 0 | 1 |
0 | 0 | 0 | 0
| 8 |
2001 | Male | 58
| 2 | 2 | 2 |
1 | 0 | 1 | 0
| 66 |
2001 | Female | 6
| 0 | 0 | 0 |
0 | 0 | 0 | 0
| 6 |
2002 | Male | 80
| 1 | 1 | 0 |
1 | 2 | 0 | 0
| 85 |
2002 | Female | 9
| 0 | 0 | 0 |
0 | 0 | 0 | 0
| 9 |
Total | | 393
| 9 | 8 | 3 |
2 | 2 | 2 | 1
| 420 |
| | |
| | | |
| | | |
1.4 The causes of deaths by natural and other causes
in the years 1998-2002 are provided in Table 3. The general upward
trend of natural cause deaths is probably accountable to the increasing
numbers and age of the prison population.
Table 3
Cause of death | 1998
| 1999 | 2000 |
2001 | 2002 | Total
|
Stroke related | 0 | 1
| 1 | 0 | 5 |
7 |
Heart related | 5 | 13
| 16 | 9 | 18 |
61 |
Cancer related | 1 | 7
| 12 | 2 | 5 |
27 |
Asthma related | 0 | 3
| 1 | 2 | 1 |
7 |
Long term illness | 0 | 1
| 2 | 1 | 0 |
4 |
Brain related | 1 | 3
| 1 | 0 | 1 |
6 |
Not recorded | 39 | 20
| 17 | 44 | 19 |
139 |
Liver or renal failure | 0 |
2 | 0 | 0 | 1
| 3 |
Drug abuse | 1 | 2
| 3 | 0 | 4 |
10 |
Other | 2 | 4 |
1 | 2 | 17 | 26
|
Outside prison* | 3 | 1
| 3 | 8 | 0 |
15 |
Homicide | 4 | 0
| 3 | 0 | 0 |
7 |
Choked on vomit | 0 | 1
| 0 | 0 | 0 |
1 |
Pneumonia related | 0 | 0
| 1 | 0 | 0 |
1 |
Mutilation | 0 | 0
| 1 | 0 | 0 |
1 |
Old age | 0 | 0
| 1 | 0 | 0 |
1 |
Total | 56 | 58
| 63 | 68 | 71 |
316 |
| | |
| | | |
*This category includes deaths of prisoners on leave, or
who absconded.
1.5 The characteristics of prisoners who have died in
custody by self-inflicted means during 2002 are overviewed below.
Where relevant, comparisons are drawn with deaths that have occurred
in previous years, and where possible, statistics are given for
2003 to date.
Age
1.6 The age-profile of those who died in 2002 is shown
in Table 4. Most deaths occurred in the 25-39 age groups. The
age-range of the 94 deaths was from 16 to 58. The mean age was
32 years. Two juveniles (15-17 year olds) and 12 young offenders
(18-20 year olds) died. The remaining 80 were adults, 38% of whom
were in the 30-39 year age group. This is similar to the age-profile
of those who have died in previous years and broadly reflects
the age-profile of the general prison population.
Table 4
Age Group | Number
| % |
15-17 years | 2 | 2
|
18-20 years | 12 | 13
|
21-24 years | 11 | 12
|
25-29 years | 17 | 18
|
30-39 years | 30 | 32
|
40-49 years | 16 | 17
|
50-59 years | 6 | 6
|
Total | 94 | 100
|
| | |
Gender
1.7 Ten per cent of cases of self-inflicted death involved
females. This figure is higher than would be expected, given that
women only account for 6% of the prison population. So far in
2003, the relative proportion of female SIDs is even higherof
the 58 deaths up to 4 August, 10 have been female. An important
point is that, in the community, women make up a quarter of all
deaths. Taking into account the proportions of men and women in
custody, a disproportionate number of those who kill themselves
in prison are women.
Ethnicity
1.8 Eighty nine per cent who died in 2002 were white;
white prisoners comprise around 78% of the prison population.
4% of those who died were Asian; around 3% of the prison population
is Asian. Five per cent of those died were black; around 15% of
the prison population is black. In 2003 (to 4 August), of the
58 deaths, four have been non-white. These figures show that a
disproportionate number of self-inflicted deaths occurred amongst
white prisoners. This is a consistent research finding.
Offence type
1.9 As illustrated in table 5, the most common offence-type
of those who died during 2002 is violence against the person,
followed by robbery, other criminal offences and burglary. Published
research is consistent in reporting that those who die are more
likely (than the general prison population) to be imprisoned for
violence-related offences.
Table 5
Offence-type | Number
| % |
Violence against the person | 25
| 27 |
Sexual offences | 7 | 7
|
Burglary | 12 | 13
|
Robbery | 15 | 16
|
Theft & handling | 11 |
12 |
Fraud & forgery | 1 |
1 |
Drug offences | 9 | 10
|
Other offences | 14 | 15
|
Total | 94 | 100
|
| | |
Legal Status
1.10 Forty one (44%) of those who died in 2002 were sentenced;
the remainder were either on remand (38%), convicted unsentenced
(13%) or in prison awaiting further reports (Judgement RespitedJ/R)
(5%). Unsentenced prisoners account for less than 20% of the prison
population. That the vast majority of those who die are unsentenced
is consistent with previous years.
Sentence Length
1.11 Consistent with previous years' data and published
research, sentenced prisoners who die are likely to be serving
lengthy prison terms or life. In 2002, 71% of the 41 sentenced
prisoners who killed themselves were serving terms of over 18
months. Twenty two per cent were serving life-sentences.
Latency
1.12 A consistent finding is that the majority of prisoners
who die have been in the establishment for relatively short periods
at the time of death. Table 6 shows the latency between prisoners'
receptions at the establishment and their death. Just over half
(54%) of prisoners who died in 2002 spent less than a month in
custody (52% in 2001).
Table 6
| Number | %
|
<1 day | 7 | 7
|
1 to 2 days | 7 | 7
|
3 days <1 week | 12 |
13 |
1 week <1 month | 25 |
27 |
1 month <3 months | 21 |
22 |
3 months <6 months | 13 |
14 |
6 months <12 months | 7 |
7 |
1 year or more | 2 | 2
|
Total | 94 | 100
|
| | |
Establishment-Specific Factors
1.13 As in previous years, the majority of self-inflicted
deaths (64%) in 2002 occurred in Category B Local prisons. It
has been found that male local prisons that experience a self-inflicted
death are statistically more likely to experience further death/s.
In 2002, 52 establishments experienced a self-inflicted death:
2%One prison (Durham) experienced six deaths
(four males and two females).
4%Two prisons (Lewes and Holme House) experienced
five deaths.
4%Two prisons (Dovegate and Hull) experienced
four deaths.
10%Five prisons (Exeter, Leeds, Woodhill,
Bullingdon and Bedford) experienced three deaths.
25%13 prisons experienced two deaths (Blakenhurst,
Bristol, Brixton, Doncaster, Liverpool, New Hall, Northallerton,
Nottingham, Parc, Preston, Styal, Wandsworth and Wealstun).
Finally, 56%29 establishments experienced
one death.
1.14 There is no firm evidence of a correlation between
the prison population and the number of prisoners who kill themselves,
although it is likely that an increase in prison population has
an impact on the amount of time staff can spend with each individual
prisoner. Overcrowding may also result in an increase in the length
of time prisoners are locked in their cells, rather than engaged
in purposeful activity. More people being received into custody
may mean that some prisoners are located further from home, which,
in turn, may mean that they receive fewer visits from family and
friends.
1.15 Only three (Dover in Kent, Haslar in Hampshire and
Lindholme in Doncaster) of the UK's nine removal centres are managed
by the Prison Service. They hold only male detainees (individuals
detained prior to removal from the UK, overstayers, failed asylum
seekers and illegal immigrants). These centres are managed under
the Detention Centre Rules published in April 2001. The regime
is considerably more relaxed than the regime in prison (as detainees
are not criminals).
1.16 Since September 2000, there have been two self-inflicted
deaths involving detainees in the Prison Service managed centres.
(On 31 January 2003, Michail Bodnarchuk, a Ukrainian national,
hanged himself at HM Immigration Removal Centre Haslar. He was
due for removal on the day of his death, and had been resident
at Haslar since 8 November 2002. On 31 March 2003, Rajwinder Singh
Mutti hanged himself at HMP Blakenhurst. Mr Mutti, an Indian national,
had been on remand at Blakenhurst since 3 February 2003 for an
offence of grievous bodily harm; he was also detained under the
1991 Immigration Act.)
1.17 The identification of at-risk detainees is made
more difficult by the difficulties in communication and the lack
of personal history information. The F2052SH (see paragraph 2.5
below) procedure operates in detention centres as it does in prison
establishments, with an active Suicide Prevention Team.
1.18 As mentioned above, evidence suggests that minority
ethnic prisoners are less likely to take their own lives than
white prisoners. Cases of self-inflicted death among black and
Asian prisoners are proportionately less in comparison with the
rest of the prison population; the statistics for the years 1996-2002
show that, while 20% of the prison population is composed of individuals
from minority ethnic groups, minority ethnic prisoners represent
only 9% of the number self-inflicted deaths.
1.19 The Prison Service annual report, published on 15
July 2003, said that over the past financial year, 5.1% of staff
were from a minority ethnic group (exceeding the key performance
target of 4.5%). Good prisoner/staff relationships are central
to the quality of life in prison, which is thought to be a factor
in suicide prevention. Results of research measuring the quality
of prison life are expected in the summer of 2004.
Q2. What practical steps have already been taken, and what
further steps are being considered to prevent:
Suicide and self-harm in prisons?
Other deaths and injuries in prison?
2.1 Reducing prisoner self-inflicted deaths and managing
self-harm is a key priority for Ministers and the Prison Service.
A proactive three-year strategy to develop policies and practices
to reduce prisoner suicide and manage self-harm in prisons was
announced in February 2001 by the then Home Secretary, Jack Straw,
and was implemented from April 2001. The launch of the current
strategy followed a thematic inspection review by Sir David Ramsbotham
and an internal review by Ingrid Posen (former Head of Safer Custody
Group). It replaced the 1994 Caring for the Suicidal in Custody
Strategy, which was generic across the estate, focussed on awareness,
and stressed the responsibility of all staff. Pre-1994 approaches
had been primarily medical.
2.2 The current strategy is holistic in approach, more
overtly preventative, risk-based, and strongly dependent on other
approaches (within prisons on a supportive culture based on good
staff/prisoner relationships and constructive regimes; beyond
prisons on the cooperation of other agencies). It is ambitious
in scope and in demanding year-on-year reductions in suicide and
self-harm.
2.3 Projects are underway to improve pre-reception, reception
an induction arrangements, to better facilitate inter-agency information
exchange, and to develop safer prison design, including "safer
cells". New evidence based healthcare reception screening
arrangements are being implemented and include measures to better
detect vulnerable prisoners. Thirty full-time suicide prevention
co-ordinators (SPCs) have been appointed in high-risk establishments,
and a further 102 mostly part-time SPCs are now operating across
the estate. Wing staff are supported in their work by prisoner
peer support schemes and, in the most needy prisons, by mental
health in-reach teams, similar to community mental health teams.
Samaritans are working with the Prison Service to select prisoner
"Listeners", who are then trained to listen (though
not to give practical advice) to all prisoners who need somebody
to talk to, often seven days a week, 24 hours a day.
2.4 An investment of over £21 million is allowing
physical improvements to be made at six pilot sites: Feltham,
Leeds, Wandsworth, Winchester, Eastwood Park and Birmingham. The
money is being spent on improvements to detoxification centres,
reception and induction areas, the installation of First Night
Centres and the creation of crisis suites and gated cells that
enable staff to watch at-risk prisoners closely.
2.5 Improved processes for the identification and management
of prisoners at risk of suicide and self-harm are being developed
to replace the current "F2052SH" procedures. Any member
of staff can raise an F2052SH in respect of a prisoner considered
to be at risk of suicide or self-harm. An individual care plan
is then put in place for so long as the crisis lasts, with regular
multi-disciplinary reviews. Changes in detoxification facilities
and procedures are also being introduced. Staff awareness and
training are recognised as key to the successful outcome of many
of these initiatives and training programmes are being developed
alongside new procedures.
2.6 The Prison Service is also determined to learn lessons
from death in custody. The programme of work embarked upon includes
a fresh look at strengthening investigations procedures to include
an independent element and better learning and dissemination of
lessons arising in particular cases. Investigation reports are
already routinely disclosed to the families concerned. (See also
question 5 below.)
2.7 Problems of inter-prisoner violence and bullying,
particularly among young people in custody, are being readdressed
through development of a violence reduction strategy. This will
provide a national framework of protective mechanisms and positive
behaviour management. Work is on going with other services to
ensure that the Prison Service's work in this field is consistent
with a national, multi-agency approach.
2.8 There is strong support for the strategy from groups
represented on the Ministerial Roundtable on Suicide, which is
chaired by the Prisons and Probation Minister, Paul Goggins. Membership
includes the Howard League, Prison Reform Trust, Inquest, the
Youth Justice Board, Prisons and Probations Ombudsman, HM Chief
Inspector of Prisons and Samaritans. Prison Health, the partnership
between the Prison Service and the Department of Health, is also
represented.
2.9 A number of intervention strategies have been introduced
into prisons for people who self-harm. These include crisis counselling,
support groups and specialised psychological interventions. The
Prison Service recognises that self-harm is a particular problem
among women prisoners. Safer Custody Group findings reveal that
attempted suicide/self-injury is more prevalent amongst women
that men in prison by a ratio of 18:1 (2003). At three women's
prisonsHolloway, Durham and Bulwood HallDialectic
Behaviour Therapy has been introduced. This is an innovative programme
developed in the USA by Marsha Linehan, originally for women with
"borderline personality disorder" (BPD) who also self-harm
or engage in suicidal behaviours. It has been well researched
and found to be significantly better than other treatments in
producing positive changes for this client group. Treatment targets
of DBT include reducing self-harm, increasing coping skills, decreasing
impulsive behaviours and improving emotional regulation. DBT has
also been found to have positive treatment effects on other behaviours
such as abuse and aggression.
2.10 Over the next few months the outcome of the Safer
custody strategy will be reviewed, taking into account pilot project
evaluations and emerging research findings. The next steps and
approaches will be resolved in consultation with partner agencies
and organisations. It is likely that approaches in the future
will concentrate more on better care for people than on processes
and the Prison Service will seek to reduce the desire of individuals
to attempt suicide by improving the custodial experience and the
feelings of safety in establishments. It will seek to build on
the close relationship and working partnership with Prison health.
For many in prison the growing links with local healthcare will
aid continuity of treatment. The strategy is also likely to include
greater links with the resettlement agenda and a broader understanding
of the issues to share with the public.
Q3. What has been done to foster a greater "human rights
culture" in prisons and other detention facilities? What
more could be done? Would a human rights approach to conditions
of detention and to prison management contribute to the prevention
of deaths in custody?
Q4. Are you satisfied that guidance and practice in the prison
service is sufficient to comply with obligations under Articles
8, 3 and 2 of the European Convention on Human Rights?
3.1 The Prison Service has undertaken an extensive programme
of training for staff on the introduction of the Human Rights
Act and its implications for the Prison Service. This has been
supported by the provision of written information to every member
of staff, together with information packs made available to prisoners
through the prison library. In conjunction with the Prison Reform
Trust, a booklet specifically designed for prisoners was produced
and issued in July 2001. Legal Services Officers from all prisons
have attended conferences, and governors together with senior
policy staff have attended seminars. Presentations have been made
to dispersal prisons, staff responsible for life sentenced prisoners
and Race Relations officers.
3.2 All policy leads are aware that both new and existing
policy must be HRA compliant. In those areas where there has been
doubt, legal opinion has been sought and changes made. During
the consultation process for new policy the Human Rights implications
of any changes must be considered by policyholders.
3.3 The belief is that current policy and guidance in
the Prison Service is in line with ECHR; however, if successfully
challenged as non-compliant, we will address those issues at the
time. The general nature of some ECHR terminology and its reliance
on general principles mean that it is often through a policy being
tested in the courts that precedent or non-compliance is established.
3.4 While it would be naïve to insist that all practice
is always compliant with policy, we have a thorough process of
Internal Audit, auditing of Prison Service Standards and both
announced and unannounced visits by Her Majesty's Inspectorate
of Prisons that is designed to ensure that policies are being
correctly applied. To support this we also have complaints procedures
that allow prisoners to complain about their treatment to the
Prison Service, and finally, if not satisfied, to the Prisons
and Probation Ombudsman.
3.5 The provisions of the Human Rights Act and its underlying
principles contribute to suicide and self-harm reduction in prison.
(See also Question 5 below.)
Q5. Are the Article 2 ECHR requirements of an effective, prompt
and independent investigation of deaths in custody, with effective
participation by next-of-kin. Met by the current system? How could
the effective investigation of deaths in custody be better ensured?
5.1 Since April 1998 all deaths in custody have been
investigated by the Prison Service. Investigations are carried
out by senior governors. Although "independent" of the
prison concerned, investigating officers are usually from the
same area and our investigations could not be regarded as other
than internal. Investigating officers act on behalf of the Commissioning
Authority (CA), the area manager or equivalent, responsible for
the establishment in which the death occurred, to whom they are
accountable. The CAs are in turn accountable to the Director General
and his Deputy. Currently therefore both the commissioning of
investigations and "ownership" of reports rest with
the operational line of the Prison Service.
5.2 The short answer to the first part of this question,
therefore, is that the Prison Service is playing its part but
currently remains vulnerable to judgements in individual cases
that our internal investigations do not contribute enoughthus
supporting the case for strengthening our investigations, which
we are doing as part of the three-year Safer Custody Programme.
(See paragraph 2.1 above.)
5.3 The Joint Committee will be aware that this is a
fast moving and still developing area of jurisprudence, which
we expect to be further clarified when the Lords give their judgement
in the case of Amin (heard in July) and Middleton,
which is to be heard early next year. Currently the position is
that the requirements of an Article 2 investigation (the so-called
"Jordan" criteria of independence, effectiveness, reasonable
promptness, public scrutiny and family involvement) can be met
by an amalgam of inquiries and investigationsthe Prison
Service investigation, the Inquest, civil proceedings, a criminal
trialand no single element is expected to meet Article
2 on its own (although that is possible). The Lord chief Justice
went out of his way to praise Governor Ted Butt's report in the
Mubarek case, notwithstanding that it was internal.
5.4 The attached Annex A[3]
prepared as background to our work in this area, provides further
information about the current legal position. But the reasons
for strengthening investigations into death in custody go beyond
Article 2 compliance. The main reason we want to strengthen our
investigations into deaths in custody is to contribute to the
suicide prevention strategyto ensure a better focus on
what went wrong and why and to extract learning so as to minimise
recurrences. The three-year safer custody programme therefore
incorporated a project designed to establish a system of investigation
into deaths in custody, which is:
has appropriate elements of specialist input and
independence;
secures public confidence;
explains what happened and why;
provides for the Prison Service to learn from
any identified failures;
provides the fullest possible factual information
to the Coroner as a basis for the inquest; and
involves the family of the deceased fully and
appropriately.
5.5 During 2001 Safer Custody Group undertook a wide
scale consultation exercise, consulting interests within and outside
the Prison Service on how such a system could be developed. Following
this exercise an options paper was put to Ministers in which four
options were identified. These were:
extend an existing external prisons-related role,
most likely that of the Prisons Ombudsman, with both commissioning
and investigations independent of the Prison Service;
create a new independent body based on the police
model, with a mixture of external and internal investigators,
with commissioning and investigations independent of the Prison
Service;
dedicated team(s) of investigators with pools
of expert assistants. All investigations independent-led or supported
depending on circumstances of case, with Prison Service retaining
commissioning and some "ownership" of investigation
reports; and
strengthened inquest process. (At the time the
options paper was prepared the fundamental review of the Coroner's
system had been commissioned but had not reported.)
5.6 Ministers asked for the Prisons and Probation Ombudsman
option to be worked up and costed and this work is currently in
hand. It is being taken forward by the Home Office in the context
of putting the Prisons and Probation on a statutory footing and,
simultaneously extending his role to include investigating deaths
in prison custody (and deaths of probation hostel residents).
Both the report of the fundamental review of Coroners and Dame
Janet Smith's report into the Harold Shipman affair make recommendations
for radical changes to the Coroner's role, on which a view needs
to be taken before a final decision on the Prisons and Probation
Ombudsman option is made.
5.7 The Prisons and Probations Ombudsman is unlikely
to take over responsibility for investigating deaths in custody
before April 2005. In the interim Safer Custody Group is working
with area managers (who commission death in custody investigations)
to do what we can to strengthen our current procedures in a variety
of ways, for example, by improving clinical input, incorporating
independent elements into some investigations and their management,
widening terms of reference and involving families to a far greater
extent. Five areas are trialling revised guidance on investigating
deaths in custody. This is attached at Annex B.[4]
Phil Wheatley
Director General
18 August 2003
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