PFD report

Stewart Stanley · Prevention of Future Deaths report

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Issued 19 Sep 2023•Exeter and Greater Devon

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
4

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
8

Described in responses

Recipients and published responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

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

Report evidence summary

Concerns raised4

  1. Inconsistent conducting of ACCT observations
    Part of recurring concern: Unreliable ACCT suicide and self-harm prevention processes
  2. Excessive prison officer working hours
    Part of recurring concern: Unreliable fatigue controls for prolonged safety-critical shifts
  3. Different staff interpretations of ACCT observation timing requirements
    Part of recurring concern: Unreliable ACCT suicide and self-harm prevention processes
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.7

  1. Action

    Increase operational staffing, including Band 3–5 officers, at HMP Exeter.

    Stated by HM Prison and Probation ServiceStated completedThe respondent said that this action was complete when they made their response on 22 September 2023.
  2. Action

    Introduce a retention toolkit to help Governors identify drivers of staff attrition.

    Stated by HM Prison and Probation ServiceStated completedThe respondent said that this action was complete when they made their response on 22 September 2023.
  3. Action

    Display ACCT V6 observation posters in wing offices and produce staff guides.

    Stated by HM Prison and Probation ServiceStated completedThe respondent said that this action was complete when they made their response on 22 September 2023.

Source evidence

How this individual concern was interpreted

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

PFD Monitor interpretation

Inconsistent conducting of ACCT observations

Wider context from the report

“(1) The evidence revealed that there was an inconsistent approach taken by staff when conducting and recording observations on prisoners subject to the Prison Service suicide and self-harm prevention procedures (known as ACCT). (2) The evidence also revealed that some Officers had a different interpretation of the requirements of set out in PSI 64/2011 in respect of the timing of observations. (3) The evidence also revealed that precise times of such observations were not routinely being recorded accurately. (4) During the evidence it became apparent that a prison officer worked 23 hours out of 24, he was asked if this was normal and he replied, “yes, to make the regime work.” ”

Is this part of a recurring concern?

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

Open source report

Source evidence

How this individual concern was interpreted

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

PFD Monitor interpretation

Excessive prison officer working hours

Wider context from the report

“(1) The evidence revealed that there was an inconsistent approach taken by staff when conducting and recording observations on prisoners subject to the Prison Service suicide and self-harm prevention procedures (known as ACCT). (2) The evidence also revealed that some Officers had a different interpretation of the requirements of set out in PSI 64/2011 in respect of the timing of observations. (3) The evidence also revealed that precise times of such observations were not routinely being recorded accurately. (4) During the evidence it became apparent that a prison officer worked 23 hours out of 24, he was asked if this was normal and he replied, “yes, to make the regime work.” ”

Is this part of a recurring concern?

Yes — Unreliable fatigue controls for prolonged safety-critical shifts.

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

Different staff interpretations of ACCT observation timing requirements

Wider context from the report

“(1) The evidence revealed that there was an inconsistent approach taken by staff when conducting and recording observations on prisoners subject to the Prison Service suicide and self-harm prevention procedures (known as ACCT). (2) The evidence also revealed that some Officers had a different interpretation of the requirements of set out in PSI 64/2011 in respect of the timing of observations. (3) The evidence also revealed that precise times of such observations were not routinely being recorded accurately. (4) During the evidence it became apparent that a prison officer worked 23 hours out of 24, he was asked if this was normal and he replied, “yes, to make the regime work.” ”

Is this part of a recurring concern?

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

Open source report

Source evidence

How this individual concern was interpreted

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

PFD Monitor interpretation

Failure to accurately record ACCT observation times

Wider context from the report

“(1) The evidence revealed that there was an inconsistent approach taken by staff when conducting and recording observations on prisoners subject to the Prison Service suicide and self-harm prevention procedures (known as ACCT). (2) The evidence also revealed that some Officers had a different interpretation of the requirements of set out in PSI 64/2011 in respect of the timing of observations. (3) The evidence also revealed that precise times of such observations were not routinely being recorded accurately. (4) During the evidence it became apparent that a prison officer worked 23 hours out of 24, he was asked if this was normal and he replied, “yes, to make the regime work.” ”

Is this part of a recurring concern?

Yes — Unreliable ACCT suicide and self-harm prevention processes; Unreliable recording of required observations in care and custody.

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

Increase operational staffing, including Band 3–5 officers, at HMP Exeter.

Verbatim wording from the response

“With regards to your second concern, we remain committed to ensuring prisons are sufficiently resourced to deliver quality outcomes and ensure staff and prisoner safety, as well as improving our regime offering. Staffing has been an ongoing challenge at HMP Exeter, but from June 2020 to June 2023, the total number of operational staff increased by 12% (from 199 to 222), with Band 3-5 officers specifically increasing by 7% (from 165 to 176).”

Source location

Response from HM Prison and Probation Service
Page 1 · response
Published 22 September 2023

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

Introduce a retention toolkit to help Governors identify drivers of staff attrition.

Verbatim wording from the response

“Nationally, we continue to monitor staffing levels across the estate, and when staffing levels affect stability or the regime, there are a number of ways establishments can maximise the use of their own resources and seek support from other establishments to address staffing shortfalls. HMP Exeter have previously received support with additional marketing activity to bolster the recruitment pipeline. Further to this, we have introduced a retention toolkit to help Governors identify the drivers of attrition in their prisons.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 22 September 2023

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

Display ACCT V6 observation posters in wing offices and produce staff guides.

Verbatim wording from the response

“Since February 2023, the Prison Performance Support Programme (PPSP) have provided funding for 12 months for two Band 4 ACCT safety ‘Floorwalkers’ who are responsible for conducting regular upskilling sessions which include the need for accurate completion of observations. Further to this, ACCT V6 observation posters have been displayed in all wing offices and guides have been produced for staff.”

Source location

Response from HM Prison and Probation Service
Page 1 · response
Published 22 September 2023

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

Provide two ACCT safety Floorwalkers to deliver regular staff upskilling on accurate observation completion.

Verbatim wording from the response

“Since February 2023, the Prison Performance Support Programme (PPSP) have provided funding for 12 months for two Band 4 ACCT safety ‘Floorwalkers’ who are responsible for conducting regular upskilling sessions which include the need for accurate completion of observations. Further to this, ACCT V6 observation posters have been displayed in all wing offices and guides have been produced for staff.”

Source location

Response from HM Prison and Probation Service
Page 1 · response
Published 22 September 2023

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 staff profiles and the core day regime to address leadership and staffing concerns.

Verbatim wording from the response

“Following the Urgent Notification received by the prison in November 2022, additional action was taken to address concerns relating to leadership and staffing, this included a review of staff profiles and the core day regime. HMP Exeter remains classed as a ‘standard plus’ site, which reflects its complexity. A business case to uplift managerial grades has been approved to attract and retain experienced managers, and therefore improve stability of the leadership team for the Governor, Deputy Governor and Head of Safety grades.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 22 September 2023

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 an ACCT assurance procedure with supervising-officer allocation, daily observation checks and escalation of discrepancies.

Verbatim wording from the response

“HMP Exeter have reviewed the management of the ACCT process and have introduced an assurance procedure to ensure there is consistency and effective completion of all ACCT documents including observations. All ACCT are now allocated to a supervising officer who is responsible for conducting daily checks to ensure all set observations for the previous 24 hours have been completed. Any discrepancies are highlighted with the safety team for prompt action.”

Source location

Response from HM Prison and Probation Service
Page 1 · response
Published 22 September 2023

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

Examine the overall staffing model for public-sector prisons to improve resource-allocation analysis and prioritisation.

Verbatim wording from the response

“More widely, there is ongoing work within HMPPS to examine the overall staffing model for Public sector prisons. The project aims to improve our analysis of resource allocation across the system and ensure that we have prioritized our staff resources to address key business.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 22 September 2023

Open published response

Other statements in published responses

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

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

  1. 1

    Approve a business case to uplift managerial grades and improve leadership-team stability.

    Stated by HM Prison and Probation ServiceStated completedThe respondent said that this action was complete when they made their response on 22 September 2023.

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

Approve a business case to uplift managerial grades and improve leadership-team stability.

Verbatim wording from the response

“Following the Urgent Notification received by the prison in November 2022, additional action was taken to address concerns relating to leadership and staffing, this included a review of staff profiles and the core day regime. HMP Exeter remains classed as a ‘standard plus’ site, which reflects its complexity. A business case to uplift managerial grades has been approved to attract and retain experienced managers, and therefore improve stability of the leadership team for the Governor, Deputy Governor and Head of Safety grades.”

Source location

Response from HM Prison and Probation Service
Page 2 · response
Published 22 September 2023

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