PFD report

Kellie Jean POOLE · Prevention of Future Deaths report

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Issued 4 Oct 2023•Derby and Derbyshire

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
11

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
3

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 raised11

  1. Insufficient training and experience of cold water immersion session leaders
    Part of recurring concern: Inadequate controls for cold-water immersion risks in open water
  2. Lack of specific health and safety guidance for cold water immersion providers
  3. Lack of pre-session health advice or warnings for cold water immersion participants
    Part of recurring concern: Unreliable pre-activity safety information for organised water activities
Responses linked to these concerns

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

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

  1. Position

    Existing legal requirements and guidance from multiple authoritative sources are considered sufficient, so HSE will not publish specific cold water immersion guidance now.

    Stated by Health and Safety ExecutiveExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

Source evidence

How this individual concern was interpreted

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

PFD Monitor interpretation

Insufficient training and experience of cold water immersion session leaders

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

Is this part of a recurring concern?

Yes — Inadequate controls for cold-water immersion risks in open water.

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 specific health and safety guidance for cold water immersion providers

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

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 pre-session health advice or warnings for cold water immersion participants

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

Is this part of a recurring concern?

Yes — Unreliable pre-activity safety information for organised water activities.

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 written risk assessments for cold water immersion sessions

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

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 guidance from the Health and Safety Executive or other appropriate bodies for cold water immersion activities

Wider context from the report

“On my understanding the current limits of oversight of cold water immersion providers in effect means that these activities have not received guidance from the Health and Safety Executive or other appropriate bodies. My investigation indicated that local authority environmental health departments are unclear whether they should and how they might monitor and oversee these providers. ”

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 voluntary self-regulation for cold water immersion providers

Wider context from the report

“There is no established UK member organisation for providers of cold water immersion, other than for ‘wild’ and open water swimming which is a distinct activity, and therefore no form of even voluntary self-regulation. ”

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

Unclear local authority environmental health monitoring and oversight of cold water immersion providers

Wider context from the report

“On my understanding the current limits of oversight of cold water immersion providers in effect means that these activities have not received guidance from the Health and Safety Executive or other appropriate bodies. My investigation indicated that local authority environmental health departments are unclear whether they should and how they might monitor and oversee these providers. ”

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 adequate first aid training and equipment for cold water immersion sessions

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

Is this part of a recurring concern?

Yes — Failure to provide adequate first aid where emergency assistance may be needed; Inadequate staff competence to provide first aid.

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

Risk posed by open-water locations used for cold water immersion sessions

Wider context from the report

“Some sessions take place in water tanks, but sessions are also held in open water such as rivers, lakes, and reservoirs, and therefore at locations that may in themselves pose risk. Session leaders may have undertaken some form of training, but I am not aware that the nature and quality of the training itself is regulated/quality assured. ”

Is this part of a recurring concern?

Yes — Inadequate controls for cold-water immersion risks in open water.

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 regulation or quality assurance of cold water immersion leader training

Wider context from the report

“Some sessions take place in water tanks, but sessions are also held in open water such as rivers, lakes, and reservoirs, and therefore at locations that may in themselves pose risk. Session leaders may have undertaken some form of training, but I am not aware that the nature and quality of the training itself is regulated/quality assured. ”

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 public liability insurance among cold water immersion providers

Wider context from the report

“There seems to be very little oversight of these businesses in their provision of cold water immersion covering matters such as pre-session health advice or warnings, public liability insurance, training and experience of the session leader, first aid training and equipment, or written risk assessments. I am not aware of the issuing of specific health and safety guidance. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

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 legal requirements and guidance from multiple authoritative sources are considered sufficient, so HSE will not publish specific cold water immersion guidance now.

Verbatim wording from the response

“well as targeted guidance for higher-risk industries and activities. HSE does not seek to provide guidance for all industries and activities as it is often the case that others are more knowledgeable or better placed to provide such guidance.”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 6 October 2023

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

Local authorities are predominantly responsible for enforcing work-related health and safety legislation for cold water immersion activities.

Verbatim wording from the response

“HSE will continue to support and liaise with our regulatory partners in local authorities who are predominantly responsible for the enforcement of work related health and safety legislation in this area. To increase awareness among local authority enforcement officers I have asked that this matter is raised at the national Local Authority Health and Safety Practitioner Forum (https://www.hse.gov.uk/lau/national-committees.htm).”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 6 October 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.3

  1. 1

    Continue supporting and liaising with local authority regulatory partners on enforcement.

    Stated by Health and Safety ExecutiveStated in progressThe respondent said that this action was in progress when they made their response on 6 October 2023.
  2. 2

    Keep cold water immersion activity under review.

    Stated by Health and Safety ExecutiveStated in progressThe respondent said that this action was in progress when they made their response on 6 October 2023.
  3. 3

    Raise cold water immersion at the national Local Authority Health and Safety Practitioner Forum to increase enforcement officers’ awareness.

    Stated by Health and Safety ExecutiveStated plannedThe respondent said that this action was planned when they made their response on 6 October 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

Continue supporting and liaising with local authority regulatory partners on enforcement.

Verbatim wording from the response

“HSE will continue to support and liaise with our regulatory partners in local authorities who are predominantly responsible for the enforcement of work related health and safety legislation in this area. To increase awareness among local authority enforcement officers I have asked that this matter is raised at the national Local Authority Health and Safety Practitioner Forum (https://www.hse.gov.uk/lau/national-committees.htm).”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 6 October 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

Keep cold water immersion activity under review.

Verbatim wording from the response

“It is HSE’s view that the regulatory provisions in place requiring cold water immersion providers to manage risks, together with the guidance available from multiple sources on the main risks involved, provide a suitable basis for businesses to provide activities safely and for local authorities to take regulatory action where required. Consequently, HSE will not be publishing specific guidance at this time for cold water immersion activities. However, as this is a newly emerging leisure pursuit we will keep this activity under review.”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 6 October 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

Raise cold water immersion at the national Local Authority Health and Safety Practitioner Forum to increase enforcement officers’ awareness.

Verbatim wording from the response

“HSE will continue to support and liaise with our regulatory partners in local authorities who are predominantly responsible for the enforcement of work related health and safety legislation in this area. To increase awareness among local authority enforcement officers I have asked that this matter is raised at the national Local Authority Health and Safety Practitioner Forum (https://www.hse.gov.uk/lau/national-committees.htm).”

Source location

Response from Health and Safety Executive
Page 2 · response
Published 6 October 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