PFD report

Azroy Dawes-Clarke · Prevention of Future Deaths report

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Issued 29 Jul 2025•Kent and Medway

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

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Concerns
7

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
6

Described in responses

Recipients and published responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised7

  1. Insufficient ACCT process training and competence among frontline and civilian staff
    Part of recurring concern: Unreliable ACCT suicide and self-harm prevention processes
  2. Inconsistent or incomplete understanding of the legal framework for prison officers’ involvement in prisoner care and treatment
  3. Failure to provide bedding materials resistant to being ripped into ligatures
    Part of recurring concern: Failure to control ligature risks in inpatient and custodial environmentsPart of recurring concern: Inadequate control of access to means of self-harmPart of recurring concern: Ineffective prison suicide and self-harm prevention systems
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.5

  1. Action

    Continue rolling out SASH, speed training and ACCT upskilling to improve staff recognition of suicide and self-harm risks and case management.

    Stated by HM Prison and Probation ServiceStated in progressThe respondent said that this action was in progress when they made their response on 30 July 2025.
  2. Action

    Conduct a cell design review to assess alternative materials meeting fire-safety and anti-ligature requirements for bedding.

    Stated by HM Prison and Probation ServiceStated in progressThe respondent said that this action was in progress when they made their response on 30 July 2025.
  3. Action

    Create bespoke first-on-scene care videos for prison officers and frontline staff covering potential emergency scenarios.

    Stated by HM Prison and Probation ServiceStated completedThe respondent said that this action was complete when they made their response on 30 July 2025.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.1

  1. Position

    Healthcare professionals, not officers, are responsible for assessing prisoners’ mental capacity when staff have concerns.

    Stated by HM Prison and Probation ServiceRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient ACCT process training and competence among frontline and civilian staff

Wider context from the report

“(2) Officers involved in Mr Dawes-Clarke’s ACCT process, described different experiences, familiarity and training in respect of the ACCT process. Some described finding new ACCT paperwork as difficult, others were unclear as to what matters should be recorded within the ACCT paperwork. Capacity to provide training to frontline officers and other civilian staff within the prison appeared to be limited. ”

Is this part of a recurring concern?

Yes — Unreliable ACCT suicide and self-harm prevention processes.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Inconsistent or incomplete understanding of the legal framework for prison officers’ involvement in prisoner care and treatment

Wider context from the report

“(4) Whilst the use of force paperwork completed following Mr Dawes-Clarke’s physical restraint made mention of the Mental Capacity Act 2005, none of the officers (including the individual who completed the paperwork) appeared to have any basic understanding of the circumstances when the Mental Capacity Act may apply in a custodial setting. Equally, many were unclear as to what their role would be in conveying a prisoner who lacked the capacity to consent to their conveyance to hospital in a medical emergency. Answers in respect of handcuffing prisoners for the purpose of conveying them to hospital in a medical emergency varied. Answers in respect of the legal framework which applied when prison officers are involved in care and treatment of a prisoner (the particular issue in the present case being the conveyance to hospital and the decision to dress him) were inconsistent or incomplete. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to provide bedding materials resistant to being ripped into ligatures

Wider context from the report

“(1) Despite being in a safer cell, dressed in an anti-ligature gown, Mr Dawes-Clarke was able to make a ligature from the bedding material in his cell. The material from which the mattress and pillow cover are made, permit strips to be ripped from them. ”

Is this part of a recurring concern?

Yes — Failure to control ligature risks in inpatient and custodial environments; Inadequate control of access to means of self-harm; Ineffective prison suicide and self-harm prevention systems.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Inconsistent decision-making about handcuffing prisoners during emergency hospital conveyance

Wider context from the report

“(4) Whilst the use of force paperwork completed following Mr Dawes-Clarke’s physical restraint made mention of the Mental Capacity Act 2005, none of the officers (including the individual who completed the paperwork) appeared to have any basic understanding of the circumstances when the Mental Capacity Act may apply in a custodial setting. Equally, many were unclear as to what their role would be in conveying a prisoner who lacked the capacity to consent to their conveyance to hospital in a medical emergency. Answers in respect of handcuffing prisoners for the purpose of conveying them to hospital in a medical emergency varied. Answers in respect of the legal framework which applied when prison officers are involved in care and treatment of a prisoner (the particular issue in the present case being the conveyance to hospital and the decision to dress him) were inconsistent or incomplete. ”

Is this part of a recurring concern?

Yes — Unsafe police restraint practices and controls.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of prison officers’ understanding of when the Mental Capacity Act applies in custody

Wider context from the report

“(4) Whilst the use of force paperwork completed following Mr Dawes-Clarke’s physical restraint made mention of the Mental Capacity Act 2005, none of the officers (including the individual who completed the paperwork) appeared to have any basic understanding of the circumstances when the Mental Capacity Act may apply in a custodial setting. Equally, many were unclear as to what their role would be in conveying a prisoner who lacked the capacity to consent to their conveyance to hospital in a medical emergency. Answers in respect of handcuffing prisoners for the purpose of conveying them to hospital in a medical emergency varied. Answers in respect of the legal framework which applied when prison officers are involved in care and treatment of a prisoner (the particular issue in the present case being the conveyance to hospital and the decision to dress him) were inconsistent or incomplete. ”

Is this part of a recurring concern?

Yes — Failure to reliably apply Mental Capacity Act principles in care decisions.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Unclear prison officer roles in conveying prisoners lacking capacity to hospital

Wider context from the report

“(4) Whilst the use of force paperwork completed following Mr Dawes-Clarke’s physical restraint made mention of the Mental Capacity Act 2005, none of the officers (including the individual who completed the paperwork) appeared to have any basic understanding of the circumstances when the Mental Capacity Act may apply in a custodial setting. Equally, many were unclear as to what their role would be in conveying a prisoner who lacked the capacity to consent to their conveyance to hospital in a medical emergency. Answers in respect of handcuffing prisoners for the purpose of conveying them to hospital in a medical emergency varied. Answers in respect of the legal framework which applied when prison officers are involved in care and treatment of a prisoner (the particular issue in the present case being the conveyance to hospital and the decision to dress him) were inconsistent or incomplete. ”

Is this part of a recurring concern?

Yes — Unreliable emergency access to hospital care; Unsafe interoperability between prison custody and healthcare procedures.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to maintain prison officers’ first aid and basic life support competence during physical restraint

Wider context from the report

“(3) Officers who were present during Mr Dawes-Clarke’s cardio-respiratory arrest had different training with regard to first aid and basic life support. During the course of the inquest, evidence was heard that whilst all uniformed prison officers would have regular training in respect of control and restraint, not all had recent (if any) training in first aid or basic life support. Some of the officers who gave evidence were unclear as to the correct response to a cardio respiratory arrest during physical restraint. ”

Is this part of a recurring concern?

Yes — Failure to reliably respond to patient breathing emergencies; Inadequate staff competence to provide first aid.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue rolling out SASH, speed training and ACCT upskilling to improve staff recognition of suicide and self-harm risks and case management.

Verbatim wording from the response

“You raised that staff at inquest described different levels of familiarity and training in respect of the Assessment, Care in Custody and Teamwork (ACCT) process. HMP Elmley is committed to providing appropriate local training to upskill both operational and non-operational staff. This includes reinforcement of ACCT procedures through the ongoing rollout of Suicide and Self-Harm (SASH) training and “speed training” for bite-sized learning. Since Mr Dawes-Clarke’s death much work has been undertaken to help increase awareness and recognition of risk factors that increase the possibility of suicide and/or self-harm. A focus on continuing to upskill and support better case management as well as ACCT training for all staff working with prisoners is ongoing.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 30 July 2025

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Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Conduct a cell design review to assess alternative materials meeting fire-safety and anti-ligature requirements for bedding.

Verbatim wording from the response

“HMPPS are currently undertaking a cell design review which is looking at all aspects of cell design, including furniture and fittings, to ensure it takes account of developments in how prisoners are accommodated and improvements in what is currently available on the market. As part of this review, we will explore the possibility of using different materials which meet the stringent fire safety requirements and can also function as anti-ligature for bedding. The review is expected to conclude at the end of 2026.”

Source location

Response from HM Prison and Probation Service
Page 1 · response
Published 30 July 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Create bespoke first-on-scene care videos for prison officers and frontline staff covering potential emergency scenarios.

Verbatim wording from the response

“To further improve our emergency contingency arrangements and to better equip employees to provide first-on-scene care (before medical assistance arrives), HMPPS have with St John Ambulance created a set of bespoke first-on-scene videos for Prison Officers and frontline staff. These provide practical guidance on what to do in several potential scenarios staff may come across in the course of their duties.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 30 July 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Attend ACCT case reviews to share experience and guidance with staff.

Verbatim wording from the response

“The quality of ACCT management and compliance with policy is routinely assured, as per the nationally mandated quality assurance process, and findings from this assurance is fed back to staff to enable ongoing awareness and improvement. Additionally, Elmley’s safety team have devised an action plan to support improving case management including ACCT upskill training, attending case reviews to share experience and guidance and developing an improved booking system to enable better multi-disciplinary attendance and consistency of case co-ordinators.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 30 July 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Re-issue the national first aid refresher framework defining emergency first aid, workplace first aid and establishment cover requirements.

Verbatim wording from the response

“You also raised that during the inquest it became clear that not all staff had recent training in first aid or basic life support. The first aid refresher framework was re-issued nationally in August 2023. It outlines the requirements for emergency first aid and first aid at work, emphasising the responsibility of Governors to always ensure adequate first aid cover. This is achieved by conducting a detailed local risk assessment to establish the number of trained first aiders at work (FAW) and emergency first aiders at work (EFAW) needed for each establishment.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 30 July 2025

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Healthcare professionals, not officers, are responsible for assessing prisoners’ mental capacity when staff have concerns.

Verbatim wording from the response

“Officers are not expected to assess a prisoner’s mental capacity; this responsibility lies with healthcare professionals. Where staff have concerns about a prisoner’s mental capacity, they are directed to seek healthcare input. Staff are instead required to act in accordance with policy, supported by appropriate de-escalation techniques and, to apply use-of-force measures only when strictly necessary and in a proportionate and sensitive manner.”

Source location

Response from HM Prison and Probation Service
Page 3 · response
Published 30 July 2025

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.1

  1. 1

    Develop an improved booking system to support multidisciplinary attendance and consistent ACCT case coordination.

    Stated by HM Prison and Probation ServiceStated in progressThe respondent said that this action was in progress when they made their response on 30 July 2025.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Develop an improved booking system to support multidisciplinary attendance and consistent ACCT case coordination.

Verbatim wording from the response

“The quality of ACCT management and compliance with policy is routinely assured, as per the nationally mandated quality assurance process, and findings from this assurance is fed back to staff to enable ongoing awareness and improvement. Additionally, Elmley’s safety team have devised an action plan to support improving case management including ACCT upskill training, attending case reviews to share experience and guidance and developing an improved booking system to enable better multi-disciplinary attendance and consistency of case co-ordinators.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 30 July 2025

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026