PFD report

Shanté Andrée Marie TURAY-THOMAS · Prevention of Future Deaths report

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Issued 27 Jan 2020•Inner North London

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.

View original report
Concerns
21

Raised in this report

Recipients
12

Named on the report

Responses found
9

Of 12 recipients

Stated actions
45

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

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

Report evidence summary

Concerns raised21

  1. Provision of incorrect advice that an adrenaline auto injector switch is only a brand substitution
  2. Failure to reconsider adrenaline auto injector dose after switching device
    Part of recurring concern: Unsafe medication prescribing
  3. Inadequate and incorrect national training content for 111 call handlers on adrenaline auto injectors
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.29

  1. Action

    Amend and release the Distance Learning Pack with stronger anaphylaxis guidance, second-dose adrenaline advice and accurate images of adrenaline autoinjectors.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  2. Action

    Amend NHS Pathways guidance so a second adrenaline autoinjector is advised after five minutes without improvement, through Release 20.

    Stated by NHS EnglandStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  3. Action

    Develop and apply an audit framework for NHS Pathways providers, including audit standards, frequencies, qualifications and training requirements.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.22

  1. Position

    Information about specific adrenaline auto-injector doses is a prescriber’s responsibility, not the call handler’s.

    Stated by NHS EnglandRedirects 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

Provision of incorrect advice that an adrenaline auto injector switch is only a brand substitution

Wider context from the report

“7. The GPs relied upon the advice given by Enfield Clinical Commissioning Group (CCG) that the scriptswitch was simply the replacement of one branded product with another branded product of the same drug/device. This gave false reassurance. The CCG joint formulary committee introduced a new drug for GPs, but then gave the wrong advice to accompany this. ”

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 reconsider adrenaline auto injector dose after switching device

Wider context from the report

“5. When Shanté’s AAI was changed from an EpiPen to an Emerade, her GPs failed to reconsider the prescription and to increase her dose from 300mgs to 500mcgs. ”

Is this part of a recurring concern?

Yes — Unsafe medication prescribing.

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

Inadequate and incorrect national training content for 111 call handlers on adrenaline auto injectors

Wider context from the report

“17. In terms of national training for 111 call handlers, the NHS Digital distance learning pack contains advice that is in part inadequate and in part wrong. It does not give the crucial information that one dose of adrenaline, by whichever device it is administered, is very unlikely to be sufficient in the case of acute anaphylaxis. It contains a photograph to illustrate the use of an AAI, but in the photograph the device is held incorrectly. ”

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 identify patients at particularly high risk from allergies and asthma

Wider context from the report

“1. At the time of her death, Shanté was not receiving specialist care for her allergies. However, her general practitioners (GPs) failed to appreciate this. They assumed that she was being treated for her allergies at the transitional asthma clinic to which she had been referred following her paediatric discharge. This was an incorrect assumption. The GPs had not identified Shanté (who had a high BMI and was severely allergic) as being at particularly high risk from her allergies and asthma, and had no awareness that they were the sole providers of Shanté’s allergy care. ”

Is this part of a recurring concern?

Yes — Unreliable asthma care and management.

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 named accountability for allergy services and provision

Wider context from the report

“20. The issues within this prevention of future deaths report are predominantly national issues, but I heard at inquest that there is no person with named accountability for allergy services and allergy provision at NHS England or the Department of Health as a whole. ”

Is this part of a recurring concern?

Yes — Unclear accountability for allergy services and provision.

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 assess patients’ access to and understanding of adrenaline auto injector advice

Wider context from the report

“2. Shanté’s GPs knew that she should carry two adrenaline auto injector (AAI) pens at all times, and they may have mentioned this to her, but they failed to record this and they did not emphasise it to her. They failed to emphasise to Shanté and her family that the reason for carrying two pens is primarily because in the event of severe acute anaphylaxis, the very strong likelihood is that both pens will need to be administered, one five minutes after the other, to keep the patient alive until the arrival of an emergency ambulance. The GPs did not explore with Shanté the reason for her erratic requests for a pen. They did not explore with her where she kept her pens. They did not test her understanding of medical advice. ”

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 of the Adastra system to update location information across screens in real time

Wider context from the report

“14. When Shanté became ill following the ingestion of nuts, her mother rang NHS 111 and got through to the London Central & West (LCW) service. However, the call handler incorrectly recorded Shanté’s location: he failed to untick a box and so her grandmother’s address was recorded as her location, rather than her mother’s address where she was staying at the time. In an example of good practice, this error was recognised by the clinician who later took over the call. However, what nobody at LCW realised was that the Adastra computer system would not then update in real time for any screens save that of the particular clinician inputting the information. The staff at LCW have since been made aware of this and have been trained to walk over and look at the primary screen to check the address, but it is not clear to me that there is now a national understanding of that element of the system. ”

Is this part of a recurring concern?

Yes — Unreliable ambulance-service computer systems for safety-critical information.

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 establish whether specialist allergy care was being provided

Wider context from the report

“1. At the time of her death, Shanté was not receiving specialist care for her allergies. However, her general practitioners (GPs) failed to appreciate this. They assumed that she was being treated for her allergies at the transitional asthma clinic to which she had been referred following her paediatric discharge. This was an incorrect assumption. The GPs had not identified Shanté (who had a high BMI and was severely allergic) as being at particularly high risk from her allergies and asthma, and had no awareness that they were the sole providers of Shanté’s allergy care. ”

Is this part of a recurring concern?

Yes — Failure to provide continuity of patient care.

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

Inconsistency in anaphylaxis ambulance categorisation between 999 and 111 services

Wider context from the report

“16. The individuals making these errors were working within the context of NHS Digital’s categorisation of anaphylaxis as needing a category 2 ambulance rather than a category 1 ambulance, on the Adastra computer system that supports the LCW 111 service. This was the wrong categorisation and not the categorisation that the call would have received if 999 had been called and the London Ambulance Service contacted in the first instance. Acute anaphylaxis is immediately life threatening and must be treated as a category 1. I heard at inquest that NHS Digital has since changed its categorisation. However, I also heard that for those areas (I think approximately half the country, though this is not completely clear to me), where the 999 service and the 111 service are supported by different computer systems rather than the same system being common to both services, there could remain inconsistencies of categorisation between 999 and 111. Even where there are inconsistencies in categorisation, the 999 service will not re-categorise following a 111 clinician’s categorisation, unless a 999 clinician has spoken to the patient, so inappropriate 111 categorisation will not be safety netted by the 999 service. This must be recognised and factored in. ”

Is this part of a recurring concern?

Yes — Unreliable ambulance call triage and re-triage; Unsafe emergency call handling.

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 explain the need for sequential administration of two adrenaline auto injectors in acute anaphylaxis

Wider context from the report

“2. Shanté’s GPs knew that she should carry two adrenaline auto injector (AAI) pens at all times, and they may have mentioned this to her, but they failed to record this and they did not emphasise it to her. They failed to emphasise to Shanté and her family that the reason for carrying two pens is primarily because in the event of severe acute anaphylaxis, the very strong likelihood is that both pens will need to be administered, one five minutes after the other, to keep the patient alive until the arrival of an emergency ambulance. The GPs did not explore with Shanté the reason for her erratic requests for a pen. They did not explore with her where she kept her pens. They did not test her understanding of medical advice. ”

Is this part of a recurring concern?

Yes — Failure to communicate safety-critical care information effectively between care providers and families; Failure to recognise and respond to anaphylaxis; Inadequate anaphylaxis safety education for patients, parents and schools.

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 of 111 call audits to identify all significant call-handling failings

Wider context from the report

“15. During the course of the 111 call, a number of errors were made. These were the errors of LCW individuals. When LCW audited the call in the first instance, the audit identified the problem with the address, but failed to recognise how badly the call had gone in other ways. Without effective audit and recognition of failings, it is difficult to see how there can be effective improvement. ”

Is this part of a recurring concern?

Yes — Failure of care and safety auditing to identify deficiencies; Failure to reliably audit emergency call handling.

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

Rare provision of practical placebo-device adrenaline auto injector training

Wider context from the report

“13. I heard that the gold standard of training for use of any AAI is to give the patient the relevant pen (whichever that patient is prescribed) containing a placebo rather than adrenaline and, following appropriate instruction, ask the patient actually to administer a dose. I heard at inquest that the incidence of this standard of training (in any setting) is rare. That may be for good reasons, but it seems that revisiting best practice training at a national level would be helpful. ”

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 healthcare-professional training after an adrenaline auto injector switch

Wider context from the report

“6. Following the scriptswitch, the GPs failed to ask Shanté to come in to the surgery for training in use of the Emerade. This would also have presented an ideal opportunity to explore Shanté’s understanding of the use of her pens and to ensure that she understood she needed to carry two at all times. ”

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 communicate device-specific training requirements for adrenaline auto injectors

Wider context from the report

“9. The CCG failed to inform prescribers that the Emerade pen requires different training to the EpiPen because different AAIs do not operate in the same way. In fact, the CCG gave the opposite advice. ”

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 of NHS Digital to retain and act on previously identified call-handling safety issues

Wider context from the report

“19. One of the errors made by the first 111 call handler was a failure to ask to speak direct to the patient. This was the error of an individual. However, this is not the first time that the issue has been brought to the attention of NHS Digital. At inquest, I asked the witness who appeared on behalf of NHS Digital, and indeed had been chosen by NHS Digital as the person best able to assist the court, if this had been an issue in the past. He said no. However, on 18 December 2018, Peter Harrowing, HM Assistant Coroner for Avon, sent a prevention of future deaths report to NHS Digital following the inquest touching the death of David Longden. It was only when I asked the witness appearing on behalf of NHS Digital specifically about Coroner Harrowing’s report in respect of Mr Longden, pointing out that Coroner Harrowing had raised the need for NHS Digital to place greater emphasis on the call handler speaking to the patient, that the witness remembered that he had indeed seen that report. I choose to characterise this as a memory lapse rather than as an intention wilfully to mislead the court. (A witness who lies whilst giving evidence on oath at inquest may be found in contempt of court and may even be prosecuted for the crime of perjury.) Nevertheless, if NHS Digital does not have a grasp of this sort of detail, specifically brought to its attention by a coroner in a prevention of future deaths report, it is difficult to see how there can be effective improvement. ”

Is this part of a recurring concern?

Yes — Failure to identify and address recurring safety issues through organisational learning.

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 of AAI leaflets to specify the need for device-specific healthcare-professional training

Wider context from the report

“12. The Emerade AAI (and I assume the EpiPen and JEXT) leaflet does not specifically advise that training from a healthcare professional is needed in how to use this particular AAI as opposed to any other. ”

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 of the 999 service to safety-net inappropriate 111 categorisation

Wider context from the report

“16. The individuals making these errors were working within the context of NHS Digital’s categorisation of anaphylaxis as needing a category 2 ambulance rather than a category 1 ambulance, on the Adastra computer system that supports the LCW 111 service. This was the wrong categorisation and not the categorisation that the call would have received if 999 had been called and the London Ambulance Service contacted in the first instance. Acute anaphylaxis is immediately life threatening and must be treated as a category 1. I heard at inquest that NHS Digital has since changed its categorisation. However, I also heard that for those areas (I think approximately half the country, though this is not completely clear to me), where the 999 service and the 111 service are supported by different computer systems rather than the same system being common to both services, there could remain inconsistencies of categorisation between 999 and 111. Even where there are inconsistencies in categorisation, the 999 service will not re-categorise following a 111 clinician’s categorisation, unless a 999 clinician has spoken to the patient, so inappropriate 111 categorisation will not be safety netted by the 999 service. This must be recognised and factored in. ”

Is this part of a recurring concern?

Yes — Unreliable ambulance call triage and re-triage.

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

Single-sale availability of Emerade adrenaline auto injectors

Wider context from the report

“4. The Emerade AAI is sold singly. It could be sold in boxes of two as the norm and only singly in the alternative. ”

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 record and emphasise the need to carry two adrenaline auto injector pens

Wider context from the report

“2. Shanté’s GPs knew that she should carry two adrenaline auto injector (AAI) pens at all times, and they may have mentioned this to her, but they failed to record this and they did not emphasise it to her. They failed to emphasise to Shanté and her family that the reason for carrying two pens is primarily because in the event of severe acute anaphylaxis, the very strong likelihood is that both pens will need to be administered, one five minutes after the other, to keep the patient alive until the arrival of an emergency ambulance. The GPs did not explore with Shanté the reason for her erratic requests for a pen. They did not explore with her where she kept her pens. They did not test her understanding of medical advice. ”

Is this part of a recurring concern?

Yes — Failure to recognise and respond to anaphylaxis; Inadequate anaphylaxis safety education for patients, parents and schools.

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 advise prescribers to reconsider adrenaline auto injector dose after a device switch

Wider context from the report

“8. The CCG failed to draw prescribers’ attention to the need, following scriptswitch from EpiPen to Emerade, to reconsider the dose and to prescribe the higher dose of 500mcgs for patients at higher risk (which would have included Shanté). ”

Is this part of a recurring concern?

Yes — Incomplete medication safety guidance for prescribers.

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 display the advice to carry two adrenaline auto injectors on the outside of the box

Wider context from the report

“3. The Emerade AAI accompanying leaflet does include the advice that two pens should be carried at all times, but the advice is not re-iterated on the outside of the box. Consideration will need to be given to whether this is the appropriate advice in all cases, but it seems worthwhile to review the issue as a whole. ”

Is this part of a recurring concern?

Yes — Inadequate safety warnings on medication packaging.

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

Amend and release the Distance Learning Pack with stronger anaphylaxis guidance, second-dose adrenaline advice and accurate images of adrenaline autoinjectors.

Verbatim wording from the response

“NHS Digital welcomed the evidence given by the expert witness, Professor Fox, at the inquest and immediately recognised that the distance learning pack could be improved, assuring the Coroner (in evidence and in the supplementary second witness statement dated 20th December 2019) that a review would be undertaken, in consultation with Professor Fox, to address the points raised during his evidence.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 4 · response
Published 13 August 2020

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

Amend NHS Pathways guidance so a second adrenaline autoinjector is advised after five minutes without improvement, through Release 20.

Verbatim wording from the response

“NHS Pathways has always prompted call handlers to give instructions in respect of a second administration of AAI if there is no improvement, as NHS Digital stated in the PFD submissions, dated 17 January 2020. This is NHS Pathways content and is not affected by the system into which NHS Pathways is embedded (e.g. Adastra in this case).”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 5 · response
Published 13 August 2020

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

Develop and apply an audit framework for NHS Pathways providers, including audit standards, frequencies, qualifications and training requirements.

Verbatim wording from the response

“NHS Digital has developed an extensive audit framework that applies to providers using NHS Pathways. This was described in NHS Digital’s: supplementary second witness statement dated 20th December 2019; submissions on conclusion dated 3 January 2020; and PFD submissions dated 17 January 2020.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 2 · response
Published 13 August 2020

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

Change NHS Pathways ambulance categorisation so symptoms suggesting life-threatening anaphylaxis receive a category 1 response, and deploy the changes nationally.

Verbatim wording from the response

“Following the Ambulance Response Program, NHS England led (supported by NASMED and ECPAG) a “clinical coding review” in May 2019, reviewing the category 1 ambulance response definition. Consequently, it was decided that symptoms which may suggest life-threatening anaphylaxis should receive a category 1 ambulance response and the necessary changes were made by NHS Pathways. These were beta tested in September 2019 and deployed nationally from October 2019.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 3 · response
Published 13 August 2020

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

Disseminate prescribing, dosing, device-change and training guidance for adrenaline auto-injectors through safety bulletins, newsletters, intranet updates, scriptswitch messages and practice events.

Verbatim wording from the response

“1. The narrative verdict was discussed at the NCL Medication Safety Officer (MSO) Local Network on 17th January 2020. The network agreed that a Medicines Safety Bulletin on Adrenaline Auto Injectors (AAIs) would be distributed to GPs and other primary care healthcare professionals. The NCL Medicines Safety Bulletin on Adrenaline Auto Injectors (AAI) dated 24th January 2020 is attached as appendix 1. The bulletin was approved virtually by one NCL Medication Safety Officer (MSO) Local Network following the meeting on 17th January 2020 and distributed to Enfield GP practices on 30th January 2020.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 1 · response
Published 13 August 2020

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

Establish an NCL primary care group to review local formulary and scriptswitch messaging and standardize messages across CCGs.

Verbatim wording from the response

“NCL primary care group has been set up to review the local formulary and scriptswitch messaging to standardize messages across NCL CCGs.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 4 · response
Published 13 August 2020

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

Implement a post-incident review, produce a report, and submit it to the Quality and Safety Committee to oversee recommendations and implementation.

Verbatim wording from the response

“The CCG will now implement a post incident review and a report will be completed to ensure that all actions identified are implemented to prevent a recurrence of this nature. This will include a review of governance processes and decision-making points. This report will go to the Quality and Safety Committee, which will oversee any recommendations and ensure implementation of all actions.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 4 · response
Published 13 August 2020

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

Follow up practices through meetings and training, and collate records confirming patient device training and dosage reviews.

Verbatim wording from the response

“CCG pharmacists to check what action they have taken regarding the NCL Medicines Safety Bulletin on Adrenaline Auto Injectors (AAI) have contacted all GP practices. This is being followed up with individual practice meetings, training meetings for GPs, training sessions for Primary Care Network pharmacists, and by CCG pharmacists working in practices. A record is in the process of being collated to capture actions by individual practices to ensure all patients regularly receive appropriate training in the use of their device and dosages have been reviewed. This process is due to complete by 30th April 2020.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 4 · response
Published 13 August 2020

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

Require senior pharmacist approval of scriptswitch messages and GP Clinical Lead approval of newsletters before distribution.

Verbatim wording from the response

“An analysis of CCG actions that may have been contributory to this incident were lack of governance around scriptswitch messaging and newsletters sent to practices from the CCG Medicines Management team. Following the review of this case, it was identified that a more robust governance and decision making process was needed. Current measures to stop any recurrence include:”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 4 · response
Published 13 August 2020

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

Review the design of Emerade trainer pens.

Verbatim wording from the response

“Bausch distributes trainer pens to allergy clinics and further supplies may be accessed through the Emerade website by all patients for practice purposes. These trainer pens do not include a placebo as this would limit use of the trainer pen to single use and, by administering an apparent “dose”, would present a risk of confusion, with implications for patient safety.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 4 · response
Published 13 August 2020

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

Incorporate an activated needle-cover shield extension into redesigned trainer pens while retaining repeated practice use.

Verbatim wording from the response

“Bausch is currently reviewing the design of its trainer pens and plans to incorporate a needle cover shield extension when activated, to more closely replicate the patient experience with the actual pen, albeit still capable of being used on multiple occasions for practice purposes.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 4 · response
Published 13 August 2020

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

Initiate discussions with MHRA about adding advice to outer packaging that patients should carry two adrenaline auto-injectors.

Verbatim wording from the response

“With respect to information on the labelling of medicinal products, this is controlled by the Human Medicines Regulations 2012 and the addition of any text must be approved by the competent regulatory authority before it can be implemented. When considering the addition of information not specified in the regulations, it is necessary to take into account whether this can be included on the packaging in legible form without adversely impacting the essential information already required to be present.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Continue participating in ambulance user groups to share data, discuss cases, exchange learning, and support triage-system improvements through feedback mechanisms.

Verbatim wording from the response

“The LAS, as an MPDS user for its 999 services and an NHS Pathways user for its 111 services, attend the relevant user groups with other ambulance trusts and fully participate in such meetings, where there is the opportunity to share data back and forth, discuss cases of note and share learning in order to make continual improvements through the feedback mechanisms to NHS Digital and the Academy at PDC process. The LAS will discuss the findings of PFD report at such user groups. Ultimately, however, changes to how the triage system operates are a matter for the International Academies of Emergency Dispatch (IAED) where MPDS (owned by PDC) is concerned, or for NHS Digital under their national clinical governance group where NHS Pathways is concerned.”

Source location

2020-0124-Response-from-London-Ambulance-Service_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Consider how best to clarify in CG134 that two adrenaline auto-injectors should be prescribed and carried at all times.

Verbatim wording from the response

“We do not consider it appropriate for us to duplicate the BNF advice referred to above. However, we will consider how best to make clear in CG134 the advice that 2 adrenaline auto-injectors should be prescribed, which patients should carry at all times.”

Source location

2020-0124-Response-from-NICE_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Recruit an in-house pharmacist to provide current AAI guidance and patient training during prescribing and dispensing.

Verbatim wording from the response

“8. The Practice recruited an in-house pharmacist who commenced work in December 2020. This appointment will prove conducive in ensuring that both patients and clinicians have up to date information in relation to AAI awareness. The pharmacist is also on hand to provide training to any patients in relation to the correct use of an AAI. There is accordingly now two layers of protection in that guidance is offered to a patient when prescribing the AAI as well as when dispensing it.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Audit AAI patients’ prescribed doses and contact patients to confirm correct devices, usage knowledge and storage advice.

Verbatim wording from the response

“1. Following Ms Turay-Thomas’ death, the Practice undertook an audit in October 2019 of all patients who were being prescribed Emerade to ensure that the dosage was in accordance with the BNF based on the respective patients’ weight and age. Indeed, all patients who use AAI pens have had their doses reviewed. Patients have been contacted to ensure that they have the correct dose and appropriate knowledge about the use and storage of the pen. Letters were sent to patients on Emerade, which included up to date advice from the MHRA in July 2019, December 2019 and March 2020. In respect of patients taking Jext and Epipen, letters were sent to them in January 2020.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

Require clinical staff to review AAI prescriptions, device understanding and relevant secondary-care support whenever attending patients use adrenaline.

Verbatim wording from the response

“6. It was recognised by the Practice that some patients will not be inclined to attend the Practice in order to obtain advice and training in the use of an AAI pen. To mitigate this, links to training videos and the relevant websites have been included within the letters to patients to encourage them to check that they are familiar with AAI self-administration and advice. Furthermore, all clinical staff at the Practice have been instructed to ensure that any patient who attends (regardless of the purpose of their attendance) and who is being prescribed adrenaline has their AAI prescription as well as their understanding in relation to the use of the pen reviewed. This includes checking whether the patient is receiving appropriate care and support from secondary care.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Check during medication reviews whether patients turning eighteen are appropriately transitioned to adult allergy specialists where necessary.

Verbatim wording from the response

“7. In addition, whenever a patient who has an allergy turns eighteen, the Practice will ensure that as part of any medication review, a check is undertaken as to whether that patient is appropriately transitioned into the care of adult allergy specialists if this is deemed necessary. This will guard”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Process AAI prescriptions as acute prescriptions and provide device-specific safety instructions covering appropriate dosing, carrying two pens and emergency action.

Verbatim wording from the response

“2. All prescriptions for AAIs are now dealt with as acute prescriptions, as opposed to repeat prescriptions. This ensures that each prescription is scrutinised in detail to ensure that the type of pen and dose of adrenaline is appropriate for the patient. On the face of any AAI prescription, it is expressly stated for the avoidance of any doubt that a patient should carry two AAI pens on their person at all times and ensure that they are familiar with the use of the pen. There is also some safety netting advice in the event of an emergency. We have enclosed a sample prescription to illustrate this change. In addition, each prescription is accompanied by an AAI brand specific letter to the patient providing the most important details about the AAI pens to enable a patient to use it safely and effectively. We have also enclosed a copy of a standard letter in this regard.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

Deliver enhanced anaphylaxis content within mandatory basic life-support training, including symptom recognition, carrying two pens and device-specific administration.

Verbatim wording from the response

“4. In addition to the in-house training, mandatory basic life support training was held at the Practice on 27 February 2020. This was delivered by an external provider, Mr ████████ of ████████ and Associates Healthcare Training and Education. The basic life support training always includes a segment on anaphylaxis management. However, the Practice contacted the training provider prior to the course in order to emphasise that a more extensive section was required on anaphylaxis management. We enclose a copy of the e-mail in this regard. The basic life support training lasted two and a half hours in duration. It included a 40 minute section on anaphylaxis management which encompassed recognising symptoms, the imperative of carrying two pens at all times and the different administration of the three types of pens available.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Train clinical staff on the three common AAI devices and maintain sample pens for patient demonstrations and training.

Verbatim wording from the response

“3. The Practice has taken significant steps to ensure that it is up to date with anaphylaxis management and the use of AAI pens. It arranged in-house training for all clinical staff on 9 December 2019, which was delivered by a Nurse, ████████. This training included demonstrations as to how to use the three most common AAI pens, namely Emerade, JEXT and EpiPen, advice as to the different dosages available, instructions and demonstrations as to the different methods of administration for each brand. This was all based on the respective brands’ advice/instruction on their own explanatory posters and the demonstrations were done by Nurse ████████. She has since confirmed that she has also seen a few patients who have attended the Practice to obtain some training on the use of their AAI.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Share learning with the CCG medicines management team to support safer AAI prescribing.

Verbatim wording from the response

“11. The Practice has shared learning with the CCG medicine management team and the message on scriptswitch has been amended as follows:”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Appoint a Practice Anaphylaxis Champion to oversee staff awareness, training, prescribing surveillance, protocol adherence and patient reviews.

Verbatim wording from the response

“9. The Practice has undertaken a rigorous review of all patients that have been prescribed AAI pens so as to ensure that the correct dose and pen is being prescribed. The Practice has nominated one of the Pharmacists to act as the ‘Practice Anaphylaxis Champion.’ This role will include ensuring staff awareness, training and regular surveillance of appropriate prescribing practices and adherence to practice protocols. The Pharmacist will also contact all patients prescribed AAIs to undertake regular reviews of their condition, treatment and training.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Amend the ScriptSwitch message with AAI availability, prescribing, dose-checking, counselling, training and allergy-action-plan requirements.

Verbatim wording from the response

“11. The Practice has shared learning with the CCG medicine management team and the message on scriptswitch has been amended as follows:”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Work with NHS England and other partners, and request resolution of inconsistent anaphylaxis coding between AMPDS and NHS Pathways.

Verbatim wording from the response

“In line with the evidence you heard, at the time of this incident there was an inconsistency in the way in which AMPDS and NHS Pathways categorised anaphylactic shock. Whilst the technicalities of how the respective triage systems operate would be more appropriately commented on by others, it is worth noting that the tools have fundamentally different architecture and methods of operation. They are always likely to produce differing outcomes however we have worked closely with NHS England and other partners to reduce the variation as far as possible.”

Source location

2020-0124-Association-of-Ambulance-Chief-Executives_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

Deploy a software update warning users when a second user opens the same case and address details may be out of date.

Verbatim wording from the response

“This is the first time Advanced has been made aware of the scenario outlined in this case. This involved a second user being asked verbally by the call handler to contact the ambulance service and details from a different screen (that was not the screen in live use) were used. Within two-working days of being made aware of the scenario outlined in this case, Advanced issued a reminder to all call handlers not to manually circumvent the software process and this was followed by a software update being released to prevent this manual override re-occurring ie a message is displayed if a second user opens the same user case, warning them that the address details may be out of date. This was deployed to all customers.”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Save consultation address changes immediately so they are contemporaneously available to other users on other screens.

Verbatim wording from the response

“Subsequently, and as a direct result of this case, we are currently making two changes to the Adastra application which are in development. These changes will ensure that the user will have to actively select, and tick, the address field that is required when there are differences between the locally recorded home address and the PDS registered home address. Also if any changes are made to the address during the course of the consultation they will be saved to the database immediately and will then be available contemporaneously to any other user, on any other screen. We anticipate these changes will be available to all Adastra customers by the end of April 2020.”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Consider whether communication routes or commissioning levers can support uptake and embedding of new allergy guidance and resources.

Verbatim wording from the response

“We are deeply saddened by Shante’s death. We are grateful to have had the opportunity to respond to your concerns relevant to NHSEI. We will continue to work with HEE, the professional Royal Colleges and the other organisations addressed in your report to keep abreast of any new guidance or resources that they produce that would support better management of people with severe allergies. We will consider whether any of our communication routes or commissioning levers can help with their uptake and embedding.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Have commissioning teams liaise with relevant organisations to facilitate uptake of new guidance and resources supporting management of severe allergies.

Verbatim wording from the response

“• I will ensure your report is sent to HEE and the Royal College of General Practitioners. Our commissioning teams will liaise directly with all relevant organisations to facilitate uptake of any new guidance and resource that would support better management of people with severe allergies.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Information about specific adrenaline auto-injector doses is a prescriber’s responsibility, not the call handler’s.

Verbatim wording from the response

“Information about the specific dose required in respect of each AAI has not been included. This is because the appropriate dose is a matter for the prescriber, not the call handler issuing system-generated instructions on how to administer the medication.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 5 · response
Published 13 August 2020

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

Providers are responsible for operating the audit system and managing failed call audits within NHS Digital’s framework.

Verbatim wording from the response

“Clinical providers of services using NHS Pathways (‘providers’) must enter into a Licence Agreement with the Secretary of State for Health and Social Care, including requirements relating to implementation, operation, training and auditing. This licence and the supporting materials are managed by NHS Digital.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 2 · response
Published 13 August 2020

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

Matters of concern 1–14 and 20 do not concern NHS Pathways and fall outside its remit.

Verbatim wording from the response

“HM Coroner raised matters of concern numbered 1 - 20 in the PFD report. Matters of concern 1 – 14 and 20 are not applicable to NHS Pathways. We set out below our response to matters of concern 15 to 19.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 1 · response
Published 13 August 2020

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

The distance learning pack does not direct calls or communicate call-handler advice; NHS Pathways provides real-time support instead.

Verbatim wording from the response

“As NHS Digital described in evidence and subsequent submissions, the distance learning pack is provided as a foundation of background information to all call handlers before they start training. It does not direct the progress of specific calls nor is it relied upon to communicate advice which a call handler should give. It would not be clinically safe or appropriate for non-clinical call handlers to be required to exercise knowledge or judgement, or act prompted by the system, in this way. Call handlers are instead supported by the questions and care advice presented by the NHS Pathways system. The system contains ‘supporting information’ to help call handlers understand the clinical essence of what is being asked or advised. This is presented in ‘real-time’ so that the call handler has the required information in front of them, rather than having to rely on memory.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 4 · response
Published 13 August 2020

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

Ambulance categorisation and alignment of NHS Pathways with MPDS are not NHS Digital’s responsibility or oversight function.

Verbatim wording from the response

“Ambulance response categorisation, and the alignment of different triage systems, is not the responsibility of NHS Digital. This was set out in the following submissions made on behalf of NHS Digital:”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 3 · response
Published 13 August 2020

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

NHS England oversees both systems and must address ambulance categorisation or inconsistencies between MPDS and NHS Pathways.

Verbatim wording from the response

“NHS England is the organisation charged with overseeing both NHS Pathways and MPDS, and has the remit and ability to review potential inconsistencies or change ambulance categorisation. Accordingly, concerns regarding ambulance categorisation or inconsistencies between MPDS and NHS Pathways can only be properly answered by NHS England.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 4 · response
Published 13 August 2020

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

Established NHS Pathways governance systems capture, review and resolve clinical coding issues, including those raised through Prevention of Future Deaths reports.

Verbatim wording from the response

“In relation to NHS Pathways specifically, I am advised that there are established governance systems in place to capture, review and resolve issues relating to clinical coding (including from Prevention of Future Deaths reports); and to ensure latest clinical advice and guidance is reflected in call categorisation. Independent clinical scrutiny of NHS Pathways is provided by a National Clinical Governance Group that includes representatives of medical Royal Colleges.”

Source location

2020-0124-Response-from-Department-of-Health-and-Social-Care_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

NHSEI is responsible for clinical policy and strategy for allergies in the NHS in England, including specialised allergy services.

Verbatim wording from the response

“20,000 (0.1 per cent) require referral to a specialist centre. These specialist services are commissioned at a national level by NHSEI to an agreed delivery specification.”

Source location

2020-0124-Response-from-Department-of-Health-and-Social-Care_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Commissioning and management of general allergy services is a local responsibility rather than a national departmental responsibility.

Verbatim wording from the response

“The commissioning and management of general allergy services is a local matter. For most patients (around 95 per cent) allergic diseases can be managed by primary or other non-specialist allergy services with routine therapy. Approximately five per cent of patients with allergies require treatment in a secondary service, and of those, around”

Source location

2020-0124-Response-from-Department-of-Health-and-Social-Care_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Routine twin-pack supply cannot replace single-pen dispensing or patient education about carrying two auto-injectors.

Verbatim wording from the response

“Emerade, like other adrenaline auto-injectors is authorised for supply as twin-packs as well as single auto-injectors.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Emerade leaflets already advise patients to obtain instruction from a doctor or pharmacist and healthcare professionals to provide thorough training.

Verbatim wording from the response

“However, the wording of the Patient Information Leaflet for Emerade includes the following information, specifically advising patients that training from a doctor or pharmacist is required:”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Changes to medicinal-product labelling require approval from the competent regulatory authority under the Human Medicines Regulations 2012.

Verbatim wording from the response

“With respect to information on the labelling of medicinal products, this is controlled by the Human Medicines Regulations 2012 and the addition of any text must be approved by the competent regulatory authority before it can be implemented. When considering the addition of information not specified in the regulations, it is necessary to take into account whether this can be included on the packaging in legible form without adversely impacting the essential information already required to be present.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Placebo trainer pens are not used because single-use restriction and apparent dosing could create confusion and patient-safety risks.

Verbatim wording from the response

“Bausch distributes trainer pens to allergy clinics and further supplies may be accessed through the Emerade website by all patients for practice purposes. These trainer pens do not include a placebo as this would limit use of the trainer pen to single use and, by administering an apparent “dose”, would present a risk of confusion, with implications for patient safety.”

Source location

2020-0124-Response-from-Bausch-Lomb_Redacted.pdf
Page 4 · response
Published 13 August 2020

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

ECPAG, acting for NHS England, controls ambulance categorisation and can identify inconsistencies between NHS Pathways and MPDS.

Verbatim wording from the response

“The Response Priority for each MPDS determinant descriptor – being the Category of ambulance it requires – is set by ECPAG. This is because final decisions about categorisation are made by ECPAG on behalf of NHS England. It is, therefore, this organisation (if any) who has the power to take the action the learned Coroner is seeking at sub-paragraph 3 above and, where possible, would be capable of identifying any inconsistencies between the categories of ambulance assigned to dispositions within the NHS Digital system on the one hand and PDC on the other, in relation to acute anaphylaxis and otherwise.”

Source location

2020-0124-Response-from-London-Ambulance-Service_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Changes to MPDS and NHS Pathways operation are matters for IAED and NHS Digital respectively.

Verbatim wording from the response

“The LAS, as an MPDS user for its 999 services and an NHS Pathways user for its 111 services, attend the relevant user groups with other ambulance trusts and fully participate in such meetings, where there is the opportunity to share data back and forth, discuss cases of note and share learning in order to make continual improvements through the feedback mechanisms to NHS Digital and the Academy at PDC process. The LAS will discuss the findings of PFD report at such user groups. Ultimately, however, changes to how the triage system operates are a matter for the International Academies of Emergency Dispatch (IAED) where MPDS (owned by PDC) is concerned, or for NHS Digital under their national clinical governance group where NHS Pathways is concerned.”

Source location

2020-0124-Response-from-London-Ambulance-Service_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

ECPAG has limited ability to align NHS Pathways and MPDS because the systems use different methodologies.

Verbatim wording from the response

“From the LAS’s understanding however, there are limitations to ECPAG’s ability to align the two systems – NHS Pathways and MPDS – as they operate differently and have two different methodologies for reaching a triage decision.”

Source location

2020-0124-Response-from-London-Ambulance-Service_Redacted.pdf
Page 2 · response
Published 13 August 2020

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 BNF and BNFc advice sufficiently covers adrenaline auto-injector doses, quantities and training, so NICE will not duplicate that advice.

Verbatim wording from the response

“Having reviewed your concerns, we consider that the British National Formulary (BNF) and the BNF for Children (BNFc) already contain detailed advice on these aspects of care, including the following pieces of MHRA/CHM advice from 2017 and 2019, in the section on Adrenaline/Epinephrine (https://bnf.nice.org.uk/drug/adrenalineepinephrine.html):”

Source location

2020-0124-Response-from-NICE_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

No remaining anaphylaxis categorisation inconsistency exists between NHS 111 and ambulance services because 111 incidents pass directly into ambulance dispatch.

Verbatim wording from the response

“Your report makes the observation that inconsistency may remain in parts of the country where NHS Pathways is in use by the 111 provider and AMPDS is in use by the ambulance trust. I do not believe that is the case and, having consulted with clinical and operational colleagues within AACE, I cannot conceive of a circumstance where an incidence of anaphylaxis would be categorised as Cat 1 by the 111 provider but result in a different categorisation by the ambulance trust. Once categorised by 111 incidents are passed directly to the Computer Aided Dispatch (CAD) system of the ambulance trust bypassing any further call handling or other intervention. The incident would present as a Cat 1 to the ambulance dispatcher who would allocate an ambulance response.”

Source location

2020-0124-Association-of-Ambulance-Chief-Executives_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Comments on the second adrenaline administration should be directed to the NHS Pathways team, which controls the algorithm content.

Verbatim wording from the response

“I would like to make a correction to section 18. The algorithms embedded into the Adastra application are the NHS Pathways 111 algorithms, and Advanced have no editorial control over the content of these algorithms. Thus your comments around the second administration of adrenaline need to be directed to the NHS Pathways team.”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

An independent body, rather than NHS Digital, should conduct the review of clinical triage systems because NHS Digital provides the NHS 111 Pathways system.

Verbatim wording from the response

“Independent review of clinical triage systems”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Additional primary-care allergy training and training requirements are assigned to professional organisations, Health Education England and CCGs.

Verbatim wording from the response

“• The British Society for Allergy & Clinical Immunology (BSACI) provide training for primary care staff across the country (workshops and educational meetings). Additional training of primary care staff / establishing training requirements would be via their professional organisations (e.g. Royal College of GPs), Health Education England and CCGs.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Curriculum content for health professionals’ education and training is outside NHSEI’s direct role.

Verbatim wording from the response

“NHSEI has an assurance role for CCGs and their commissioning of healthcare services. NHSEI does not have any direct role in offsetting the curriculum content for health professionals’ education and training. However, I can set out the following which sets out NHSEI’s work and commitment in this area:”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 1 · response
Published 13 August 2020

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.16

  1. 1

    Enhance NHS Pathways content to require attempts to speak directly with patients, including a new third-party caller question and supporting reminders.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  2. 2

    Continue supporting NHS England through ECPAG on aligning NHS Pathways and other ambulance triage systems.

    Stated by NHS EnglandStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  3. 3

    Identify access to relevant datasets so food-related anaphylaxis cases can be included in analysis.

    Stated by Department of Health and Social CareStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  4. 4

    Share the Prevention of Future Deaths report with the North Central London Joint Formulary Committee and request that it addresses the identified concerns at its next meeting.

    Stated by NHS Enfield Clinical Commissioning GroupStated plannedThe respondent said that this action was planned when they made their response on 13 August 2020.
  5. 5

    Share incident learning and matters of concern with GPs, pharmacists and other prescribers through practice, locality and protected learning meetings.

    Stated by NHS Enfield Clinical Commissioning GroupStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  6. 6

    Discuss the report, incident learning and any further safety measures at scheduled medicines safety, medicines management and formulary committee meetings.

    Stated by NHS Enfield Clinical Commissioning GroupStated plannedThe respondent said that this action was planned when they made their response on 13 August 2020.
  7. 7

    Discuss the Prevention of Future Deaths report findings at relevant ambulance user groups.

    Stated by London Ambulance Service NHS TrustStated plannedThe respondent said that this action was planned when they made their response on 13 August 2020.
  8. 8

    Cascade learning, the AAI policy and patient materials to other practices in the Primary Care Network.

    Stated by the three G.Ps that were interested persons in the above matterStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  9. 9

    Switch patients prescribed Emerade 150mcg to an alternative AAI brand and notify them with alternative prescriptions.

    Stated by the three G.Ps that were interested persons in the above matterStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  10. 10

    Include AAI training-video and website links in patient letters to support self-administration familiarity.

    Stated by the three G.Ps that were interested persons in the above matterStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  11. 11

    Require users to actively select and confirm the required address field when locally recorded and PDS addresses differ.

    Stated by AdvancedStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  12. 12

    Issue a reminder to all call handlers not to manually circumvent the software process.

    Stated by AdvancedStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  13. 13

    Impose contractual requirements for healthcare providers to employ appropriately trained staff and keep staff current through lifelong learning.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 13 August 2020.
  14. 14

    Send the report to Health Education England and the Royal College of General Practitioners.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 13 August 2020.
  15. 15

    Continue working with professional and partner organisations to track new guidance and resources supporting management of severe allergies.

    Stated by NHS EnglandStated in progressThe respondent said that this action was in progress when they made their response on 13 August 2020.
  16. 16

    Review the use of CQUIN incentives in future years and make decisions for 2021/22 contracts.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 13 August 2020.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.2

  1. 1

    Training materials and licence requirements sufficiently address the importance of call handlers speaking directly to patients.

    Stated by NHS EnglandExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.
  2. 2

    Further development of the NHS 111 ambulance request message standard requires NHS Digital to lead.

    Stated by AdvancedRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

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

Enhance NHS Pathways content to require attempts to speak directly with patients, including a new third-party caller question and supporting reminders.

Verbatim wording from the response

“• In version 19.3.0 of NHS Pathways, which was released to 111 and 999 on the 13th January 2020, the following changes were made to the NHS Pathways content to further enhance and support call handlers in attempting to speak to the patient:”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 6 · response
Published 13 August 2020

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

Continue supporting NHS England through ECPAG on aligning NHS Pathways and other ambulance triage systems.

Verbatim wording from the response

“NHS Digital contributes to ECPAG and will continue to support NHS England as far as it is able with the complex challenge of aligning the two very different systems. There is no evidence to suggest that prior to this incident, NHS Digital, through LCW or any other user of NHS Pathways, had been made aware of any issue or concern in respect of the ambulance response category for symptoms that may occur in anaphylaxis. If NHS Digital became aware of such an issue then its response would include raising this with NHS England, NASMED and ECPAG.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 4 · response
Published 13 August 2020

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

Identify access to relevant datasets so food-related anaphylaxis cases can be included in analysis.

Verbatim wording from the response

“Although not directly relevant to the matters of concern in your report, you may wish to note that as part of its food hypersensitivity strategy, the FSA, which is responsible for protecting the health of the public in relation to food, is exploring how it can build a better picture of allergic consumer experience. This includes exploring how to develop a reporting link that a range of stakeholders (e.g., consumers, businesses and potentially medical professionals) can use to facilitate the identification of emerging trends and where necessary, alert local authorities so that they can take appropriate investigative and enforcement action.”

Source location

2020-0124-Response-from-Department-of-Health-and-Social-Care_Redacted.pdf
Page 4 · response
Published 13 August 2020

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

Share the Prevention of Future Deaths report with the North Central London Joint Formulary Committee and request that it addresses the identified concerns at its next meeting.

Verbatim wording from the response

“2. The Prevention of Future Deaths report has been shared with the Chair of the NCL Joint Formulary Committee (JFC) with a request that the committee ensures that they address the matters of concern at the next meeting on 20th April 2020.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 1 · response
Published 13 August 2020

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

Share incident learning and matters of concern with GPs, pharmacists and other prescribers through practice, locality and protected learning meetings.

Verbatim wording from the response

“ix) Ongoing Actions”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 3 · response
Published 13 August 2020

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

Discuss the report, incident learning and any further safety measures at scheduled medicines safety, medicines management and formulary committee meetings.

Verbatim wording from the response

“The Prevention of Future Death notice will be discussed at the next NCL Medication Safety Officer (MSO) Local Network on 4th April 2020 to consider if there is anything further that should be done.”

Source location

2020-0124-Response-from-Enfield-CCG.pdf
Page 1 · response
Published 13 August 2020

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

Discuss the Prevention of Future Deaths report findings at relevant ambulance user groups.

Verbatim wording from the response

“The LAS, as an MPDS user for its 999 services and an NHS Pathways user for its 111 services, attend the relevant user groups with other ambulance trusts and fully participate in such meetings, where there is the opportunity to share data back and forth, discuss cases of note and share learning in order to make continual improvements through the feedback mechanisms to NHS Digital and the Academy at PDC process. The LAS will discuss the findings of PFD report at such user groups. Ultimately, however, changes to how the triage system operates are a matter for the International Academies of Emergency Dispatch (IAED) where MPDS (owned by PDC) is concerned, or for NHS Digital under their national clinical governance group where NHS Pathways is concerned.”

Source location

2020-0124-Response-from-London-Ambulance-Service_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Cascade learning, the AAI policy and patient materials to other practices in the Primary Care Network.

Verbatim wording from the response

“10. The Practice has cascaded the learning from this matter to other practices within the Primary Care Network. The AAI policy together with patient information leaflets and messages on prescriptions have been shared.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Switch patients prescribed Emerade 150mcg to an alternative AAI brand and notify them with alternative prescriptions.

Verbatim wording from the response

“5. The Practice has received a number of alerts from the MHRA explaining defects pertaining to the Emerade AAIs. All relevant information has been disseminated to the patients who have been prescribed Emerade. The Practice recently received a further alert from the MHRA confirming that all Emerade 150mcg AAIs are to be recalled as a result of the potential for the pen to malfunction. The Practice has ensured that all patients who were prescribed Emerade 150mcg have been switched to an alternative brand. Patients were sent letters with an alternative script on 9 March 2020.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Include AAI training-video and website links in patient letters to support self-administration familiarity.

Verbatim wording from the response

“6. It was recognised by the Practice that some patients will not be inclined to attend the Practice in order to obtain advice and training in the use of an AAI pen. To mitigate this, links to training videos and the relevant websites have been included within the letters to patients to encourage them to check that they are familiar with AAI self-administration and advice. Furthermore, all clinical staff at the Practice have been instructed to ensure that any patient who attends (regardless of the purpose of their attendance) and who is being prescribed adrenaline has their AAI prescription as well as their understanding in relation to the use of the pen reviewed. This includes checking whether the patient is receiving appropriate care and support from secondary care.”

Source location

2020-0124-Response-from-Radcliffes-Le-Brasseur_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Require users to actively select and confirm the required address field when locally recorded and PDS addresses differ.

Verbatim wording from the response

“Subsequently, and as a direct result of this case, we are currently making two changes to the Adastra application which are in development. These changes will ensure that the user will have to actively select, and tick, the address field that is required when there are differences between the locally recorded home address and the PDS registered home address. Also if any changes are made to the address during the course of the consultation they will be saved to the database immediately and will then be available contemporaneously to any other user, on any other screen. We anticipate these changes will be available to all Adastra customers by the end of April 2020.”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Issue a reminder to all call handlers not to manually circumvent the software process.

Verbatim wording from the response

“This is the first time Advanced has been made aware of the scenario outlined in this case. This involved a second user being asked verbally by the call handler to contact the ambulance service and details from a different screen (that was not the screen in live use) were used. Within two-working days of being made aware of the scenario outlined in this case, Advanced issued a reminder to all call handlers not to manually circumvent the software process and this was followed by a software update being released to prevent this manual override re-occurring ie a message is displayed if a second user opens the same user case, warning them that the address details may be out of date. This was deployed to all customers.”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Impose contractual requirements for healthcare providers to employ appropriately trained staff and keep staff current through lifelong learning.

Verbatim wording from the response

“NHSEI has an assurance role for CCGs and their commissioning of healthcare services. NHSEI does not have any direct role in offsetting the curriculum content for health professionals’ education and training. However, I can set out the following which sets out NHSEI’s work and commitment in this area:”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 1 · response
Published 13 August 2020

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

Send the report to Health Education England and the Royal College of General Practitioners.

Verbatim wording from the response

“• I will ensure your report is sent to HEE and the Royal College of General Practitioners. Our commissioning teams will liaise directly with all relevant organisations to facilitate uptake of any new guidance and resource that would support better management of people with severe allergies.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Continue working with professional and partner organisations to track new guidance and resources supporting management of severe allergies.

Verbatim wording from the response

“We are deeply saddened by Shante’s death. We are grateful to have had the opportunity to respond to your concerns relevant to NHSEI. We will continue to work with HEE, the professional Royal Colleges and the other organisations addressed in your report to keep abreast of any new guidance or resources that they produce that would support better management of people with severe allergies. We will consider whether any of our communication routes or commissioning levers can help with their uptake and embedding.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 3 · response
Published 13 August 2020

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

Review the use of CQUIN incentives in future years and make decisions for 2021/22 contracts.

Verbatim wording from the response

“• The use of incentives such as CQUIN have been set nationally for 2020/21 contracts. CQUIN as a route to provide incentives will be under review in future years, and decisions will be made in due course for 2021/22.”

Source location

2020-0124-Response-from-NHS-England_Redacted.pdf
Page 2 · response
Published 13 August 2020

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

Training materials and licence requirements sufficiently address the importance of call handlers speaking directly to patients.

Verbatim wording from the response

“• The importance of call handlers speaking to the patient where safe and appropriate is a fundamental principle and core competency for NHS Pathways use. This is emphasised through initial training, call critiques, supervised practice, use of toolkits and completion of written and practical assessments.”

Source location

2020-0124-Response-from-NHS-Digital_Redacted-1.pdf
Page 6 · response
Published 13 August 2020

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

Further development of the NHS 111 ambulance request message standard requires NHS Digital to lead.

Verbatim wording from the response

“Review of the NHS 111 Ambulance Request message”

Source location

2020-0124-Response-from-Advanced_Redacted.pdf
Page 2 · response
Published 13 August 2020

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