PFD report

Michael Joseph Hirrell · Prevention of Future Deaths report

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Issued 1 Oct 2013•Leicester City and South Leicestershire

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
6

Raised in this report

Recipients
3

Named on the report

Responses found
3

Of 3 recipients

Stated actions
18

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.

Concerns raised6

  1. Failure of customer services to provide assistance to consumers in difficulty
  2. Failure to recognise vulnerable consumers
    Part of recurring concern: Failure to recognise vulnerability in safeguarding decisions
  3. Failure to provide required customer protection to vulnerable consumers
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.13

  1. Action

    Ask domestic and non-domestic suppliers to report fatalities known to result from disconnection.

    Stated by OfgemStated plannedThe respondent said that this action was planned when they made their response on 30 December 2013.
  2. Action

    Request that npower share its revised disconnection processes with Energy UK for consideration in the Safety Net review.

    Stated by OfgemStated completedThe respondent said that this action was complete when they made their response on 30 December 2013.
  3. Action

    Issue guidance to non-domestic suppliers on good practice for debt management and disconnection, including shared occupancy and vulnerable customers.

    Stated by OfgemStated completedThe respondent said that this action was complete when they made their response on 30 December 2013.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.2

  1. Position

    Suppliers, rather than Energy UK, are responsible for implementing the Safety Net’s protections through their own systems and processes.

    Stated by Energy UKRedirects 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

Failure of customer services to provide assistance to consumers in difficulty

Wider context from the report

“2. Although all 3 personnel present on the morning (Warrant Officer, locksmith and meter engineer) had concerns regarding Mr Hirrell, no one felt empowered to halt the disconnection and, despite efforts by the Warrant Officer, customer services at npower were unable to assist with his predicament. ”

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 recognise vulnerable consumers

Wider context from the report

“1. Mr Hirrell’s presence was recognised by npower representatives before the power supply was disconnected, and he was noted to look unwell, be in receipt of welfare benefits, have no credit on his mobile telephone and to have no gas supply (and therefore no source of heat or light to his home). Notwithstanding this, he was not recognised to be a “vulnerable person”. ”

Is this part of a recurring concern?

Yes — Failure to recognise vulnerability in safeguarding decisions.

Open source report

Source evidence

How this individual concern was interpreted

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

PFD Monitor interpretation

Failure to provide required customer protection to vulnerable consumers

Wider context from the report

“3. Mr Hirrell was not afforded customer protection under the license agreement, or under the Energy UK Safety Net as a vulnerable person, which he clearly and unequivocally was. ”

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

Lack of permanent, industry-wide consumer protection

Wider context from the report

“5. Steps taken by npower since Mr Hirrell’s death was brought to their attention are (while welcome) not permanent, nor industry wide, and therefore future deaths may occur if matters are not resolved to introduce a more robust form of consumer protection. ”

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 empower personnel to halt disconnection

Wider context from the report

“2. Although all 3 personnel present on the morning (Warrant Officer, locksmith and meter engineer) had concerns regarding Mr Hirrell, no one felt empowered to halt the disconnection and, despite efforts by the Warrant Officer, customer services at npower were unable to assist with his predicament. ”

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 report consumer-protection failings and relevant deaths to oversight bodies

Wider context from the report

“4. Ofgem were unaware of this death until advised of the circumstances by this office; no contact has been made directly with Energy UK but npower were unable to offer any reassurances at inquest hearing that the circumstances of this tragic death were reported back either in routine audit feedback, or as a special case, given the failings of the system for consumer protection. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

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

Ask domestic and non-domestic suppliers to report fatalities known to result from disconnection.

Verbatim wording from the response

“In the light of this case, we will ask domestic and non-domestic suppliers to report to Ofgem as soon as it becomes known to them that there has been a fatality as a consequence of a disconnection.”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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

Request that npower share its revised disconnection processes with Energy UK for consideration in the Safety Net review.

Verbatim wording from the response

“Npower review of its practices”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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 guidance to non-domestic suppliers on good practice for debt management and disconnection, including shared occupancy and vulnerable customers.

Verbatim wording from the response

“Open letter: Non-domestic debt and disconnection – suppliers’ approaches and good practice expected”

Source location

Response from OFGEM
Page 5 · response
Published 30 December 2013

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 Energy UK as its review of shared-premises Safety Net provisions progresses.

Verbatim wording from the response

“We met with Energy UK on 14 November to ask that they review the provisions of Safety Net covering the disconnection of domestic customers where they take a supply from a shared non-domestic premise. We have written to Energy UK to highlight our expectation that these provisions must be clear to ensure that suppliers would not proceed with a disconnection of a vulnerable domestic customer in this situation. I have enclosed a copy of this letter. Energy UK has acknowledged the relevant clause in the Safety Net is not fit for the purpose and is also not reflective of suppliers’ current practices.”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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 with suppliers their treatment of domestic customers in shared-occupancy situations.

Verbatim wording from the response

“We intend to discuss with suppliers their approach to treating domestic customers in shared occupancy situations as part of our next regular meetings with them.”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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 a joint follow-up letter with Consumer Futures to non-domestic suppliers on shared occupancy and disconnection expectations.

Verbatim wording from the response

“Joint letter to suppliers with Consumer Futures”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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 and publish the Safety Net to protect vulnerable domestic consumers using non-domestic supplies from uncontrolled disconnection.

Verbatim wording from the response

“Working with suppliers, Energy UK has undertaken a review of the relevant Safety Net section regarding domestic consumers with a non-domestic supply. The matter was discussed in detail at a meeting of Energy UK members on the 11th December 2013. It was agreed that the Safety Net should be amended to clarify that where the supplier determines that a member of a domestic household, which takes its energy through a non-domestic supply, is, for reasons of age, health, disability or severe financial insecurity, unable to safeguard their personal welfare or the personal welfare of other members of the domestic household, the non-domestic supply will not knowingly be disconnected for reasons outside the domestic household’s control.”

Source location

2013-0247-Response
Page 1 · response
Published 30 December 2013

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

Keep the Safety Net’s operation, including its new protections, under constant review through independent audits of suppliers’ systems and processes.

Verbatim wording from the response

“As you are aware, suppliers are responsible for putting the principles of the Safety Net into practice and may do this in different ways, depending on how their businesses are structured. All signatories, however, aim to have implemented the required systems and processes to deliver the new protections for domestic consumers with a non-domestic supply as soon as practicable and will have done so by the end of 2014. Energy UK is also committed to keeping the operation of the Safety Net, including the new provisions, under constant review. This includes audits of suppliers’ systems and processes by an independent auditor.”

Source location

2013-0247-Response
Page 2 · response
Published 30 December 2013

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

Trial stopping complete disconnections of shared commercial and domestic supplies during winter months, extending winter protections to all domestic consumers.

Verbatim wording from the response

“In addition to this, we have introduced a trial period on the cessation of the complete disconnection of shared commercial and domestic supplies during the winter months (i.e. October to March). We began trialling this from 01 October 2013 and, as with any major change of this nature, we intend to review the results and reflect on any learning points, prior to rolling out any permanent change in policy. For the avoidance of doubt, this is in addition to the measures we already have in place to safeguard vulnerable customers throughout the year, by extending the same protections to all domestic consumers during the winter months.”

Source location

Response from NPOWER
Page 4 · response
Published 30 December 2013

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

Add mandatory vulnerability and shared-supply checks, standardize recording through a checklist, and investigate reported risks before disconnection.

Verbatim wording from the response

“Following our review of Mr Hirrell's case, which was carried out at a senior level within the organisation, we agreed a number of further enhancements to our procedures within npower's non-domestic division. These enhancements, which are all now in place, are as follows:”

Source location

Response from NPOWER
Page 3 · response
Published 30 December 2013

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

Empower on-site warrant officers to stop a disconnection whenever they have concerns about consumer welfare or circumstances.

Verbatim wording from the response

“Following our review of Mr Hirrell's case, which was carried out at a senior level within the organisation, we agreed a number of further enhancements to our procedures within npower's non-domestic division. These enhancements, which are all now in place, are as follows:”

Source location

Response from NPOWER
Page 3 · response
Published 30 December 2013

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 procedure allowing debt collection agents to escalate welfare concerns to designated senior managers.

Verbatim wording from the response

“Following our review of Mr Hirrell's case, which was carried out at a senior level within the organisation, we agreed a number of further enhancements to our procedures within npower's non-domestic division. These enhancements, which are all now in place, are as follows:”

Source location

Response from NPOWER
Page 3 · response
Published 30 December 2013

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

Brief internal and external debt-collection agencies on amended shared-supply and vulnerability procedures, with further written guidance and annual repetition.

Verbatim wording from the response

“• In July 2013 we carried out a face to face briefing with all of our debt collection agencies (internal and external), setting out our amended policy and procedures for dealing with shared supplies and vulnerable customers, and clearly explaining the part they have to play in this. Further details were then provided to the agencies in writing, to ensure clarity and consistency, and we intend to repeat this at least annually;”

Source location

Response from NPOWER
Page 4 · response
Published 30 December 2013

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

Suppliers, rather than Energy UK, are responsible for implementing the Safety Net’s protections through their own systems and processes.

Verbatim wording from the response

“As you are aware, suppliers are responsible for putting the principles of the Safety Net into practice and may do this in different ways, depending on how their businesses are structured. All signatories, however, aim to have implemented the required systems and processes to deliver the new protections for domestic consumers with a non-domestic supply as soon as practicable and will have done so by the end of 2014. Energy UK is also committed to keeping the operation of the Safety Net, including the new provisions, under constant review. This includes audits of suppliers’ systems and processes by an independent auditor.”

Source location

2013-0247-Response
Page 2 · response
Published 30 December 2013

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 licence protections, the Energy UK Safety Net, audits and the winter moratorium provide robust protection for vulnerable domestic customers.

Verbatim wording from the response

“The supply licences prohibit the disconnection of any domestic customer in debt unless the supplier has taken all reasonable steps to recover the money owed through fitting a prepayment meter, where it is safe and reasonably practicable to install one.”

Source location

Response from NPOWER
Page 2 · response
Published 30 December 2013

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.5

  1. 1

    Require suppliers to collect relevant shared-premises disconnection information monthly and report it to Ofgem quarterly.

    Stated by OfgemStated plannedThe respondent said that this action was planned when they made their response on 30 December 2013.
  2. 2

    Issue a formal information request to non-domestic suppliers about disconnections affecting vulnerable domestic customers in shared premises.

    Stated by OfgemStated completedThe respondent said that this action was complete when they made their response on 30 December 2013.
  3. 3

    Strengthen debt-collection audit trails by documenting decisions and chronology through adviser checklists, system enhancements, and standard templates.

    Stated by RWE npower Group plcStated completedThe respondent said that this action was complete when they made their response on 30 December 2013.
  4. 4

    Review the winter shared-supply disconnection trial and reflect its learning before deciding whether to make the policy permanent.

    Stated by RWE npower Group plcStated plannedThe respondent said that this action was planned when they made their response on 30 December 2013.
  5. 5

    Brief affected debt-management teams on process changes and organize face-to-face reinforcement training, with annual refresher training.

    Stated by RWE npower Group plcStated in progressThe respondent said that this action was in progress when they made their response on 30 December 2013.

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

  1. 1

    Enforceable licence protections for non-domestic customers are not considered necessary or desirable because business-customer detriment differs from household vulnerability and fuel poverty.

    Stated by OfgemNo action considered necessaryThe respondent said that no further action was needed.

Source evidence

How this respondent action was interpreted

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

PFD Monitor interpretation

Require suppliers to collect relevant shared-premises disconnection information monthly and report it to Ofgem quarterly.

Verbatim wording from the response

“We have requested that this information be collected monthly by suppliers from January 2014 onwards and reported to Ofgem on a quarterly basis. We expect to receive the first data from these suppliers at the end of April 2014.”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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 formal information request to non-domestic suppliers about disconnections affecting vulnerable domestic customers in shared premises.

Verbatim wording from the response

“We have set out above the extensive information we collect on debt and disconnection from domestic energy suppliers. Following a review of that monitoring information, we issued a formal request on 25 October to all non-domestic gas and electricity suppliers. In this we asked suppliers to provide information about the total number of disconnections on non-domestic sites where the gas or electricity supply is shared with a vulnerable domestic customer.”

Source location

Response from OFGEM
Page 3 · response
Published 30 December 2013

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

Strengthen debt-collection audit trails by documenting decisions and chronology through adviser checklists, system enhancements, and standard templates.

Verbatim wording from the response

“• We have strengthened the audit trail on any accounts which proceed to an escalated stage of the debt collection process, so that all decisions and details of how they were reached are clearly documented throughout. We do this via a checklist which all of our advisers have access to, along with (for electricity customers) some enhancements to our system, which provide a clear, chronological sequence of events and those responsible at each stage. For gas customers, due to system constraints, this information is recorded in a standard template; however, all of the same information is captured. As you will recall, on this occasion there was inconsistency between our records and the evidence provided by the warrant officer, and these additional measures are designed to remove such a risk in the future;”

Source location

Response from NPOWER
Page 4 · response
Published 30 December 2013

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 winter shared-supply disconnection trial and reflect its learning before deciding whether to make the policy permanent.

Verbatim wording from the response

“In addition to this, we have introduced a trial period on the cessation of the complete disconnection of shared commercial and domestic supplies during the winter months (i.e. October to March). We began trialling this from 01 October 2013 and, as with any major change of this nature, we intend to review the results and reflect on any learning points, prior to rolling out any permanent change in policy. For the avoidance of doubt, this is in addition to the measures we already have in place to safeguard vulnerable customers throughout the year, by extending the same protections to all domestic consumers during the winter months.”

Source location

Response from NPOWER
Page 4 · response
Published 30 December 2013

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

Brief affected debt-management teams on process changes and organize face-to-face reinforcement training, with annual refresher training.

Verbatim wording from the response

“• All affected teams within npower's debt management area have already received a briefing on the changes to our process, and we are in the process of organising a face to face training session to reinforce these important messages. We have committed to carrying out refresher training in this area at least annually.”

Source location

Response from NPOWER
Page 4 · response
Published 30 December 2013

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

Enforceable licence protections for non-domestic customers are not considered necessary or desirable because business-customer detriment differs from household vulnerability and fuel poverty.

Verbatim wording from the response

“Overall, we do not currently see that enforceable licence protections of this nature are necessary or desirable for non-domestic customers, where the nature of the detriment is different and where equivalent issues of vulnerability and fuel poverty do not exist. However, suppliers should treat non-domestic customers who are in payment difficulties and face disconnection fairly. Through our Retail Market Review¹ we noted that many small businesses have similar levels of knowledge of, and engagement in the energy market to domestic customers, and we also recognise the impact on businesses of rising energy costs in the current economic climate. However, the nature of the potential detriment that can be experienced by business customers is different to households.”

Source location

Response from OFGEM
Page 5 · response
Published 30 December 2013

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

Data last updated 7 September 2026