PFD report

Christine Marie Stevenson · Prevention of Future Deaths report

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Issued 10 Mar 2016•Manchester South

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
1

Raised in this report

Recipients
1

Named on the report

Responses found
2

Of 1 recipient

Stated actions
6

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

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Report evidence summary

Concerns raised1

  1. Failure to control the quantity of Oramorph solution prescribed
    Part of recurring concern: Medication quantity controls failing to prevent unsafe access to excessive amounts
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.4

  1. Action

    Highlight high-volume controlled-drug prescribing in the Care Quality Commission’s next national Controlled Drugs Vigilance Newsletter.

    Stated by NHS Greater Manchester Integrated Care BoardStated plannedThe respondent said that this action was planned when they made their response on 10 March 2016.
  2. Action

    Examine the controlled-drug incident reporting system to identify high-volume prescribers and question the reasons for high-volume prescribing.

    Stated by NHS Greater Manchester Integrated Care BoardStated plannedThe respondent said that this action was planned when they made their response on 10 March 2016.
  3. Action

    Raise concerns about prescribed controlled-drug volumes and strengths through the network and provide guidance to prescribers.

    Stated by NHS Greater Manchester Integrated Care BoardStated plannedThe respondent said that this action was planned when they made their response on 10 March 2016.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.5

  1. Position

    Restricting Oramorph volumes could disadvantage legitimate patients who require high doses at the end of life.

    Stated by NHS Greater Manchester Integrated Care BoardDisputes the concernThe respondent disagreed with part of the concern or the basis for it.

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 control the quantity of Oramorph solution prescribed

Wider context from the report

“Concerns were raised at the Inquest as to the lack of control for Oramorph medication. A 10mgs per 5ml solution does not fall under the controlled drug requirements in the BNF. It is noted that whilst the Misuse of Drugs Act 1971 lists morphine as a Schedule 2, Part 1, Class A Controlled drug, Section 5 gives an exemption for preparation that contain not more than 0.2% morphine Oramorph (10 mg per 5 millilitres) has a morphine content that is under the 0.2% (as the 10 mg is present as morphine sulphate). However even though the solution at this strength is not to be subject of control, should there be restrictions on the amount of the solution which can be prescribed? This lady was prescribed 500mls (a total available dose of 1000 mg) of this solution which poses as a dose serious risk to health. The Court heard evidence that in a naïve user 50mls of the solution at this strength can be a risk to life. Given that Oramorph has an increasing street value and is a commonly abused drug whilst the strength of the solution may not require control the issuing of 500mls without control seems a matter which requires consideration. ”

Is this part of a recurring concern?

Yes — Medication quantity controls failing to prevent unsafe access to excessive amounts.

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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

Highlight high-volume controlled-drug prescribing in the Care Quality Commission’s next national Controlled Drugs Vigilance Newsletter.

Verbatim wording from the response

“• We have shared your letter with the Local Intelligence Network (LIN); one of the recommendations from the group was to highlight the issue of prescribing high volumes of controlled drugs in the next national newsletter from the Care Quality Commission “Controlled Drugs Vigilance Newsletter”, which is published every two months; Karen O’Brien will take this recommendation forward as a member of this group.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Examine the controlled-drug incident reporting system to identify high-volume prescribers and question the reasons for high-volume prescribing.

Verbatim wording from the response

“• Greater Manchester has a web based reporting system where all providers report incidents involving controlled drugs. This means we have real time data of incidents across the Network so early warnings can be distributed. We will examine the system to identify high volume prescribers and question reasons for prescribing high volumes.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Raise concerns about prescribed controlled-drug volumes and strengths through the network and provide guidance to prescribers.

Verbatim wording from the response

“• Greater Manchester along with all areas of NHS England has established Local Intelligence Networks where information is shared across a network of healthcare providers such as hospitals, hospices, private hospitals, clinics, the police, the Care Quality Commission, and regulators such as the General Pharmaceutical Council. The Network meets twice a year to share learning concerning controlled drugs and more recently “legal highs”. We are going to raise the issue concerning the volumes and strengths of controlled drugs prescribed and provide guidance to prescribers.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Operate a web-based controlled-drug incident reporting system with real-time data and provider alerts for possible abuse.

Verbatim wording from the response

“• Greater Manchester has a web based reporting system where all providers report incidents involving controlled drugs. This means we have real time data of incidents across the Network so early warnings can be distributed. We will examine the system to identify high volume prescribers and question reasons for prescribing high volumes.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Restricting Oramorph volumes could disadvantage legitimate patients who require high doses at the end of life.

Verbatim wording from the response

“All prescribers are advised to keep the prescribed volume of drugs to a minimum especially with controlled drugs. Patients taking drugs such as morphine do find that over time they need increasing doses to control their symptoms and this varies greatly between patients. Limiting the volume of Oramorph prescribed may disadvantage some patients who are legitimately on a high dose at the end of their life.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Existing prescribing guidance advises keeping drug volumes to a minimum while allowing higher volumes for patients with legitimate end-of-life needs.

Verbatim wording from the response

“All prescribers are advised to keep the prescribed volume of drugs to a minimum especially with controlled drugs. Patients taking drugs such as morphine do find that over time they need increasing doses to control their symptoms and this varies greatly between patients. Limiting the volume of Oramorph prescribed may disadvantage some patients who are legitimately on a high dose at the end of their life.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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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

Prescribers, rather than the respondent, are responsible for deciding appropriate Oramorph prescriptions and volumes.

Verbatim wording from the response

“The second issue you raise is concerning the volume of Oramorph prescribed which in this instance was 500ml and whether this could restricted. Prescribers are aware they are responsible for all prescriptions they sign (EL(91)127). This Executive Letter states clinical responsibilities lies with the clinician who signs the prescription. This means they should prescribe appropriately for each patient and this has been reinforced to all new prescribers and existing prescribers since 1991.”

Source location

Christine-Stevenson-Response
Page 2 · response
Published 10 March 2016

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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

The ACMD has been commissioned to examine harms from diversion and illicit supply of medicines, including controlled drugs.

Verbatim wording from the response

“I also note your point about the missing 300mls of morphine sulphate. The diversion of prescription drugs into the illicit supply is taken very seriously, which is why the Home Secretary has commissioned the ACMD to “explore the potential for medical and social harms arising from the illicit supply of medicines – predominantly controlled drugs”.”

Source location

2016-0123-Response-by-Home-Office
Page 2 · response
Published 10 March 2016

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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

A daily maximum morphine dose cannot be set because individual pain-relief needs vary and a limit could harm patient care.

Verbatim wording from the response

“My officials have consulted with other departments and agencies who have responsibility for prescribing opiate medicines for severe pain relief, including the Department of Health and the Care Quality Commission. The amount of morphine needed to give relief from severe pain varies enormously according to the needs of each individual. It is not possible to set a daily maximum dose. If a limit to the amount of Oramorph which can be prescribed were set, it may have unintended consequences and could have a negative impact on some patients’ care.”

Source location

2016-0123-Response-by-Home-Office
Page 1 · response
Published 10 March 2016

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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.2

  1. 1

    Maintain a Local Intelligence Network that shares controlled-drug learning among healthcare providers, police, regulators and other partners.

    Stated by NHS Greater Manchester Integrated Care BoardStated completedThe respondent said that this action was complete when they made their response on 10 March 2016.
  2. 2

    Commission the ACMD to explore medical and social harms arising from the illicit supply of predominantly controlled medicines.

    Stated by Home OfficeStated completedThe respondent said that this action was complete when they made their response on 10 March 2016.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.1

  1. 1

    Existing professional standards, prescriber accountability, controlled-drug governance requirements and NICE guidance address safe prescribing and management.

    Stated by Home OfficeExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

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

Maintain a Local Intelligence Network that shares controlled-drug learning among healthcare providers, police, regulators and other partners.

Verbatim wording from the response

“• Greater Manchester along with all areas of NHS England has established Local Intelligence Networks where information is shared across a network of healthcare providers such as hospitals, hospices, private hospitals, clinics, the police, the Care Quality Commission, and regulators such as the General Pharmaceutical Council. The Network meets twice a year to share learning concerning controlled drugs and more recently “legal highs”. We are going to raise the issue concerning the volumes and strengths of controlled drugs prescribed and provide guidance to prescribers.”

Source location

Christine-Stevenson-Response
Page 3 · response
Published 10 March 2016

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

Commission the ACMD to explore medical and social harms arising from the illicit supply of predominantly controlled medicines.

Verbatim wording from the response

“I also note your point about the missing 300mls of morphine sulphate. The diversion of prescription drugs into the illicit supply is taken very seriously, which is why the Home Secretary has commissioned the ACMD to “explore the potential for medical and social harms arising from the illicit supply of medicines – predominantly controlled drugs”.”

Source location

2016-0123-Response-by-Home-Office
Page 2 · response
Published 10 March 2016

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

Existing professional standards, prescriber accountability, controlled-drug governance requirements and NICE guidance address safe prescribing and management.

Verbatim wording from the response

“All professionals who prescribe any medicines should act within their scope of practice and comply with their Regulators’ standards. All prescribers are required to accept clinical and professional responsibility for their prescribing decisions. Following the Shipman Inquiry the governance requirements for the safe management of controlled drugs, including the prescribing, requisitioning, supply and storage of controlled drugs were strengthened and guidance was issued by the Department of Health and the National Prescribing Centre. Most recently NICE published guidance on the safe use and management of controlled drugs in April 2016 (https://www.nice.org.uk/guidance/NG46).”

Source location

2016-0123-Response-by-Home-Office
Page 1 · response
Published 10 March 2016

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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