Dear Mrs Corcoran,

Thank you for the opportunity to respond to this Report to Prevent Future Deaths, regarding the tragic death of Mr. Christopher Brazil. I was deeply saddened to read about the circumstances surrounding Christopher’s death and would like to extend my deepest condolences to his family and friends for their loss.

In your letter, you raise concerns around unregulated and unlawful websites offering prescription only medicines and controlled drugs. These matters of concern are largely within the remit of the Medicines and Healthcare products Regulatory Agency (MHRA), given their responsibility for the regulation of medicines and devices in the UK. I understand that they are responding to you separately outlining their approach. Additionally, MHRA have informed my department that they have already taken enforcement action on both websites referenced in your report and are seeking to stop UK users being able to access such sites. One of the websites is subsequently offline, and the other is in the process of being taken offline to protect the public from the illegal sale of medicines.

The government recognises that the internet can sometimes be a gateway to content which can lead to devastating consequences. As the Secretary of State for Science, Innovation and Technology, I am responsible for the Online Safety Act (the ‘Act’) which received Royal Assent in 2023. The Act lays the foundation for strong protections against illegal content for all users, and the government is committed to working with Ofcom, the independent regulator, to ensure it is implemented quickly and effectively. The new laws apply to search services and all companies that allow users to post content online or to interact with each other. This includes a broad range of websites, apps and other services, including social media services, consumer cloud storage sites, video sharing platforms, online forums, dating services, and online instant messaging services.

As the concerns you set out in your letter are around content found via online searches, I will focus on the duties under the Act which are relevant to search services. The Act’s illegal content safety duties require all in-scope search services to operate their service using proportionate systems and processes designed to minimise the risk of all users from encountering search content which is priority illegal content via their service. In practice, this could look like removing results for sites that are known to host illegal content. The relevant priority offences are set out in Schedule 7 and include content facilitating the unlawful supply of controlled drugs, as per the Misuse of Drugs Act 1971. Search services must also take or use, where proportionate, user support measures which might for example, signpost users towards sources of support. These duties will play a key role in protecting all users - children and adults
- from encountering such search content. The illegal harms codes of practice came into force in March. As a result, search services must have measures in place to comply with their duties under the Act and

Ofcom can now enforce against non-compliance. Within the first month of the duties coming into effect, Ofcom launched several enforcement programmes to monitor compliance with the regime. Implementation of the Act represents a huge step forward in online safety.

Whilst Christopher was an adult when he was able purchase medicines from illegal websites, I would like to touch on the Act’s additional provisions for children, as we know that the impact of harmful content and activity online can be particularly damaging for young people. Search services likely to be accessed by children need to take steps to protect them from content which is legal but nonetheless harmful. In-scope services that are likely to be accessed by children will have a duty to take steps to prevent children from encountering the most harmful content that has been designated as ‘primary priority’ content. This includes pornography and content that encourages, promotes, or provides instructions for self-harm, eating disorders, or suicide. Online services must also put in place age- appropriate measures to protect children from ‘priority’ content. This includes content that encourages or depicts serious violence or injury, or dangerous stunts or challenges and content that encourages ingestion, inhalation or exposure to harmful substances. From July, the child online safety regime will be fully in force.

As the independent regulator for the Act, Ofcom have a range of enforcement powers which it can use against non-compliant regulated services, including instructing services to take steps to return to compliance, issuing fines of up to £18 million or 10% of qualifying worldwide revenue. It can also apply to the courts to initiate business disruption measures, which require third party ancillary and access services to withdraw their services from the non-compliant operator (and can result in ‘blocking’).

Whilst the majority of the matters of concern raised in your report are not directly within the remit of my department, I would like to thank you again for drawing this to my attention and I hope that this response is useful in setting out where the Online Safety Act will offer significant new protections against illegal content and harmful material for children online. The government will continue to keep online safety policy under review and identify areas where we can build on the Act, so it is important for me to be made aware of online safety related Reports to Prevent Future Deaths

Dear Mrs Corcoran,

Thank you for the Regulation 28 report of 23 April 2025 sent to the Secretary of State for Health and Social Care about the death of Christopher Brazil. I am replying as the Minister with responsibility for medicines regulation.

Firstly, I would like to say how saddened I was to read of the circumstances of Mr Brazil’s death, and I offer my sincere condolences to their family and loved ones. The circumstances your report describes are very concerning and I am grateful to you for bringing these matters to my attention.

The report raises concerns over the sale of medicines from illegal websites, which look legitimate and are easily found from simple online searches, leading to vulnerable and susceptible people being exposed to counterfeit or unsafe medications. It raises the concern that there are insufficient or no measures to verify patient medical history, age, or identity before selling the medication and drugs, that there is a lack of guidance regarding dosage, and that there are a lack of safeguards to prevent incorrect self-diagnoses or misuse by consumers. It also raises the concern that it is possible for unlawful and unethical online pharmaceutical providers to operate and deliver to the buyer within 24 hours, meaning these illegal websites may be more appealing to some than lawful sources.

The Department is committed to making online prescribing safe. Prescribers, whether working for the NHS or privately, in-person or remotely, are accountable for their prescribing decisions. They are expected to take account of appropriate national guidance. Prescribers should work with their patient and decide on the best course of treatment, with the provision of the most clinically appropriate care for the patient always being the primary consideration.

The General Pharmaceutical Council (GPhC) sets out the precautions to put in place if certain medicines requiring additional safeguards are to be supplied online. Benzodiazepines refers to a group of drugs, most of which are controlled drugs under the Misuse of Use Drugs Act 1971, that are subject to additional safeguards. These include but are not limited to assuring that the person has provided the contact details of their regular prescriber, such as their GP, and their consent to contact them about the prescription; and that the prescriber will proactively share all relevant information about the prescription with other health professionals involved in the care of the person (for example their GP). Further information on this can be found here: Guidance for registered pharmacies providing pharmacy services at a distance, including on the internet. The above guidance was updated (February 2025) in response to concerns relating to unsafe prescribing and supply of medicines online and now includes strengthened safeguards designed to prevent people from receiving medicines that are not clinically appropriate for them and may cause them harm. Specifically, the February 2025 guidance sets out what to include in a risk assessment when prescribing services are involved, this includes considering how the diverse needs of people using pharmacy services are identified, and how staff get users’ valid consent (for example, how staff assess the mental capacity of users). The guidance also sets out strengthened safeguards that should be in place before supplying certain medicines (those requiring additional safeguards, such as benzodiazepines) online. For example, it states that a prescriber should not base prescribing decisions on the information provided in a questionnaire alone. Instead, the prescriber should independently verify the information the person provides and get the information they need to support their prescribing decisions. This could be through timely two-way communication with the person, accessing the person’s clinical records, or contacting the person’s GP, their regular prescriber, or a third-party provider. The guidance also emphasises the need for a robust process to check the identity of individuals before making prescribing decisions. GPhC’s guidance also clarifies the expectation on those providing digital services to ensure their digital platform is structured in such a way that it cannot mislead the public in any way. Service users should not be misled about the identity of the pharmacies involved in providing services, and pharmacies should provide transparent information on digital platforms, including their GPhC registration number. To ascertain further details about procedures followed by the provider that prescribed Mr Brazil’s medication, you could directly approach the GMC and GPhC who may have responsibility for their regulation. In a situation where an online provider acts unlawfully, the General Pharmaceutical Council (GPhC) and other professional regulators, Care Quality Commission (CQC) and the Medicines and Healthcare products Regulatory Agency (MHRA) have the powers to investigate and take action against prescribers, products and suppliers who do not comply with legislation and national guidance. I would like to assure you that regulators have my full support to crack down on any services putting people in danger.

The MHRA, acting on behalf of the Secretary of State for Health, is responsible for the regulation of medicines and medical devices in the UK by ensuring they work and are acceptably safe. This includes applying the legal controls on the retail sale, supply and advertising of medicines which are set out in the Human Medicines Regulations 2012. These regulations also apply to medicines advertised, sold or supplied via the internet. The sale and supply of unregulated medicinal products is a global problem. Online portals play a significant role in transnational medicines crime and many websites proliferate across the internet. Currently, there is no legal mechanism for UK law enforcement to seize control of illicit overseas domains or compel internet registrars to suspend them. Gaining regulatory compliance can be a difficult and sometimes impossible process, especially when domains are registered beyond the reach of UK jurisdiction. Public safety is the number one priority for the MHRA and its Criminal Enforcement Unit works hard to prevent, detect and investigate illegal activity involving medicines and medical devices. Last year, the MHRA and its partners seized millions of doses of illegally traded medicines. These products included prescription-only anti-anxiety medicines, opioids and sleeping pills, and falsified and unlicensed lifestyle products used in the treatment of erectile dysfunction, hair loss and weight loss. It also disrupted thousands of links to websites and social media pages selling medical products to the public illegally. The MHRA also works closely with web-based sales platforms and the internet industry to identify and remove non-compliant medicines and medical devices where possible. Recent collaboration with one well-known online marketplace allowed the use of technology to identify and block more than 1.5 million unregulated medicines and medical devices before they could be advertised to the public. Through a combination of public empowerment, technological innovation, traditional methods of law enforcement and close collaboration with partners, the MHRA is constantly working to develop new and innovative ways to tackle the online trade in illegal medicines. Some of these future criminal countermeasures will include:
• Enhanced collaboration with search engine and UK internet service providers (ISPs) aimed at blocking harmful content through targeted ISP-filtering.
• Collaboration the Office of Communications (Ofcom) to explore fresh preventative opportunities presented by the Online Safety Act, which created new rules for social media companies and search engine providers.
• Boosted collaboration with UK Border Force, allowing the MHRA to grow its operational footprint at the border and increase the seizure rates of illegally trafficked medicines.
• The use of cutting-edge technology to identify, track and seize the proceeds of crime, including cryptocurrency.
• Rollout of an online service that will allow users to check if a website selling pharmaceuticals has been deemed fraudulent by the MHRA.

• Implementation of a web-based reporting scheme allowing users to report suspicious websites, online marketplaces and social media listings to the MHRA.
• Collaboration with UK banking and payment providers to disrupt the payment mechanisms used by websites illegally supplying prescription only medicines.
• The use of Artificial Intelligence to proactively identify illicit internet domains for enforcement action.
• Continued commitment to enhancing collegiate working across internet infrastructure community, including private sector and international law enforcement partners. The MHRA also seeks to identify individuals involved in unlawful activity and, where appropriate, prosecute those who put public health at risk. The MHRA’s Fake Meds campaign https://fakemeds.campaign.gov.uk/ encourages people in the UK who buy medication online to take steps to ensure they only use safe and legitimate sources. It also encourages people to report suspicious medicinal products and adverse side effects via its Yellow Card scheme https://yellowcard.mhra.gov.uk/. The Home Office, including the police and other UK law enforcement agencies, is the lead department for tackling the misuse of controlled drugs in the UK. The efforts of the MHRA and its partners have led to more medicines being seized than ever before, significant custodial sentences for offenders, the forfeiture of criminal profits, and considerable success in disrupting illegal online trading. I hope this response is helpful. Thank you for bringing these concerns to my attention.