Dear Mr Regan, Re: Regulation 28 Report to Prevent Future Deaths Inquest Into the Death of Leighton Alan Dickens write on behalf of the Chief Constable of South Wales Police in response to the Prevention of Future Deaths Report issued on the 29th September 2023 following the conclusion of the inquest into the death of Leighton Alan Dickens who tragically died on the 14th October
2020. have carefully considered the entirety of the report and wish to reiterate that as an organisation we continue to take seriously the need to meaningfully reflect on the evidence heard during Mr Dickens inquest: We are committed to ensuring the duty of care shown by our officers to the individual concerned is always paramount and welcome any findings and recommendations to ensure the highest standards of service are maintained. This response will be focused on the points raised in section $ of the Preventing Future Deaths Report, and will address each concern in turn as set out below; (1) Followlng the withdrawal of the mental health trlage support provided to the police by mental health nurses, the medically qualified sources of urgent support available to police officers to assist them to safeguard the public are limited to the mental health crisis teams: The previous Mental Health Triage scheme provided a contact for medically qualified advice based in the police control room on which police decision makers and front-line officers would be able to use to assist real-time urgent decisions on mental health related incidents: MHdbudrOytuyciottdi Ordy Eebleam Gyiecte Stotnoe Bvddum yn eiab Dotatlenht CadwDeCymnYnDdlogel clbmmGwermCr bdchtuy Gynengm= aloed south Wate Polre welcomat rcuttn coroenotnce POLICE KeepingSouthWalesSafe hwhm endudt Any contetpondence ncahdin Vlthmab etveedb Wunen andcottetpondht HEDDLU Maten #Ankedio duntnoonan2 T" ( ratl south-wales-police.uk swpolice HeddluDeCymru

However, this advice was available during a core set of hours based on demand profiling which was 09.00 until 01:00 hours: As such it would not have been available to the attending officers in this matter. The scheme did not extend to providing legislative advice on the Mental Health Act or other applicable legislation such as the Mental Capacity Act. On withdrawal of the service, discussions did take place between senior leaders in both Health service and South Wales Police to manage the arrangements for the provision of advice. Since the withdrawal of the service, the South Wales Police 'Mental Health - Section 136' policy has updated The Policy defines the treatment of people by South Wales Police officers under the Mental Health Act 1983. The policy also provides guidance to officers, and staff in the management of mental health concerns, and on the partnership arrangements in responding to mental health related incidents Policy section 1.2 (Mental Health ~ Section 136) defines the specific requirement for police to seek advice from a health professional who are maintained on an agreed list, before detaining a person under 5136 of the Mental Health Act: The policy outlines both the legislative and practical considerations in obtaining advice for use in decision making on s136. Within this section of the policy, it contains the contact details for each crisis team in the respective health board area should urgent advice be required. Following the withdrawal of mental health triage support there remains a dedicated pathway for police officers and staff to obtain urgent (24-hour) medically qualified advice to inform police decision making on the use of 5136. This does satisfy the requirements for advice to be obtained as outlined by the Mental Health Act Codes of Practice 'When deciding that detention may be necessary, the police may also benefit from seeklng advlce before using section 136 powers in cases where they are unsure that the circumstances are sufficlently serlous for using these powers. Local protocols should set out how thls advlce can be provlded and who the police should contact, Includlng outside of normal business hours: (Mental Health Act Codes of Practice 16.23) Mae HedduDeOxwncoetomudobmeshebuoth mn Gyteee 4 8ce3or Bxdary tteb; abaadha CadwDeCymnMnDdiogel dtabymmGyermGynrrntddrttetvy Gyeery8nen#oed pm Wteprrca kont partncnpodbner POLICE KeeplngSouthWalsSafe whhhendEnetth Acoetpondtner neeattedh #nehmabe earutedIn Wehhedcometpondh ! HEDDLU Wiehwanindbacmhitood south-wales police.uk swpolice HeddluDeCymru been

In response to this Regulation 28 report, extensive force communications have been published which reinforces the arrangements for see urgent medically qualified advice prior the use of powers under s136. These included formal communications via Weekly Orders, signposting on intranet and follow up by our Mental Health Iiaison Officers. This communication also highlights additional points of learning as a result of issues arising in this case. South Wales Police employs 3 dedicated Mental Health Liaison Officers (MHLO's) and a Strategic Force Mental Health Advisor, who as part of their responsibilities engage with responding officers, educate on approved practice, identify areas for improvement and escalate concerns both internally and with partners. (2) The crisis teams may not be readily available and deal with their own case load: Whilst | cannot provide specific comment on behalf of the Health Board on the capacity of their Crisls Teams, can provide assurance that the concerns within the regulation 28 notlce have been ralsed dlrectly with Director of Operations, Mental Health Clinical Board_ Formal arrangements for the provision of advice to police by crisis teams are contained within existing protocols between South Wales Police and the respective Health Boards_ As a result of the Regulation 28 Notice, the accessibility of these crisis lines is monitored dally by the force Public Protection Department to identify adverse incidents and accessibility: Information pertaining to the use of 5136 powers is also scrutinised in internal strategic boards and partnership forums, such as the Mental Health Act Monitoring Group: This monitoring is supported by governance and routes of escalation which include the Welsh Chief Officers Group on Mental Health, with Senior Responsible Officers attending from NHS Wales, WAST, Welsh Government and others. The meeting is chaired by the Assistant Chief Constable Jason Davies and provides an opportunity to escalate concerns: The Purpose of the group as agreed in the Terms of Reference include: MooHedduDoCymmumooesamu dubmautabrath mGyiteg . Sadsneg Byxtuyn Mtebgchebuath ! CedwDoCymruYnDdiogel dlbmnomergm Gyeegeald Botebum Gymregm omwa sloed South WtIn Palca welconr catipondenct POLICE KeeplngSouthWalesSafe [n Wlh end Enctth Anyconeteondanca ocohdh Wehh waba anweredh Wth ud cortepondhgh HEDDLU WthWA nolled fo dby nroondhe south-wales policeuk swpolice HeddluDeCymru Jeremy Vaughan: Ptil Cwt1sk45I | onier cpaislabe king Tecetit

to provlde a forum to promote effective multi-agency working for people wlth mental ill-health, crisis, distress and/or 0 learning disability coming into contact with Criminal Justlce agencles' . South Wales Police and Health have an interest in the availability of advice for decision making on the use of 5136 (MHA 1983), to ensure its use is necessary and proportionate to the circumstances and a Mental Health Act Assessment (MHAA); a obligation of the crisis teams to conduct; is necessary: Officers should consult with Health Care Practitioners, prior to detaining someone, however, there remains the contingency if this is not practical, and the information and intelligence, risk and threat assessment known indicate it is necessary; to detain, and remove to a place of safety as defined by Section 135 (6) of the MHA 1983. (3) The alternatlve support available from a mental health tactical adviser, Is not provided by a clinically qualified member of staff and does not have access to the PARIS mental health records system: Mental Health Tactical advisers are not currently deployed within South Wales Police, and it is fully accepted that Mental Health Tactical Advisers will not be clinically qualified members of staff with access to PARIS_ The implementation of the provision would not replace the need to consult with a suitably qualified professional which can include, a Doctor, Nurse, or Approved Mental Health Professional (AMHP); who would have access to PARIS. It remains the intention in the second quarter of 2024 to introduce this scheme which will be based on similar arrangements in other police forces: The notion of the scheme is to offer additional training to officers and staff in roles, such as our Public Service Centre, on relevant mental health legislation and associated force policy. The tactical advisor' $ remit is to offer advice to colleagues on the direction provided by force policy: These will not serve as substitutes for our dedicated Mental Health Liaison Officers as mentioned earlier. Me HacduDeCyumcrounmudubyn solabbtm sn Gree8 a Seotner Brddrm Ueb Jobeathe CadwDeCymruYnDdiogel datbtmOxeegmGrvereenihadgoebum Giermemenbord Bouth Wetes Fplca Wekonet recentg cottenpondeo POLICE KeepingSouthWalasSafo Wath EdEngtth Any colerponttaneehdh WthKbe mued in Whbhendcorerponngh HEDDLU Wtntaildlo duhrspondn PKic7 south-wales-policeuk swpolice HeddluDeCymru key

(4) The intended replacement of the mental health triage support was to have been by the "111 press 2" service: This has not been put in to place and there is no current timescale for it to be Into place. The 'NHS 111 Press 2' service is now operating across Wales. It is available 24 hours a day, 7 days a week for all ages. It is a means for individuals, who have an urgent mental health concern about themselves or about someone else, to seek help and advice_ Since the concerns raised in this inquest; we have worked with NHS Wales to develop a 'NHS 111 Press 2 - Police Contact Protocol' . This provides clarity on how a range of professionals, including the police can access advice relating to urgent mental health concerns This protocol outlines that where a police officer is seeking advice in relation to the use of section 136 (MHA, 1983) they should continue to obtain this advice from the established crisis contact points and not NHS 111 Press 2. However, it has been agreed within the protocol that should an officer come through to NHS 111 Press 2 and it is established that they are seeking section 136 advice that will be signposted to the appropriate crisis line by the call taker. The Implementation of '111 Press 2' has resulted in a more consistent approach for advice, which is available 24 / 7, with the ability to escalate concerns directly with local Crisis Teams: (5) This leaves officers wlth Ilmited sources of qualified mental health advice; with access to relevant clinical records, when responding to the risks posed by those suffering from mental health crisis within the community: When the Mental Health Triage was withdrawn from the South Wales Police force control room this was widely communicated throughout the organisation for the awareness of operational officers. As a police force we want to be confident that procedures are known to officers, and that have had sufficient training: The following is a summary of the mental health training Maattedo Da Cymum dtodsam debm gtabiath mGyveogo Soatnee Bxcboryn eleb gohaboathe CedwDeCymnYnDdiogel atbmuyomangm Gyvatg K riL ghebum Gyveaeyemah#00d South Wles Peteo wakomesrecohng collespondonca POLICE KeoplngSouthWalesSafe In Welth tnd Engtth Ar} contpondr Iecahrdh wchh #Abt enswtnedh Weth and cormpondhgh HEDDLU WadhWanot ked [0 cnietdonotr wos south-wales policeuk swpolice HeddluDeCymru 1u Gens abbceies put they they rdd

provision for officers which exists to prepare them to respond to mental health incidents in the community: New Recruits jointly trained with Gwent Police are provided with initial vulnerability training; with all recruits receiving a 180-minute input dedicated to mental health with defined learning outcomes: South Wales Police officers also receive an additional 60-minute input from the Force Mental Health Advisor around jointly agreed mental health procedures. These include the considerations to be made in responding to vulnerable people and guidance on the use of legislation: This input is also provided to Special Constables, Police Community Support Officers, and newly promoted Sergeants_ In 2024 all police officers attend a newly developed public protection training which will reinforce learning points to consider when responding to vulnerable people in the community: Our Mental Health Liaison Officers, who work daytime hours to facilitate communications with partners, remain based within Operational Police Stations, and are a visible and accessible source of advice: Training for an effective mental health response is vital to ensure that our officers understand the use of s136 (Mental Health Act); and that they are aware of the need to consult with a healthcare professional prior to detaining a person (if practical): The decision to detain remains that of the police officer and not the healthcare professional providing advice. Medically qualified advice for officers can be invaluable to a police officer when faced with a person in crisis and the sharing of information and opinion can be relevant to the formation of the officer'$ final judgement on the need for detention for a person'$ own protection: As such the force will continue to ensure that we work in partnership with NHS Wales and each of the health boards to ensure that processes are effective for officers t0 obtain advice at any time Maattadtu DoCxuyn coatow dubmeotabisath nGyiaaga Stam& Brdmebb el4d0 CedwDeCymruMnDdiogel moynrrmomr*nfrdedtetvm Gynvoeemtmaotd s0th Walot Polco ona stvba oeporte POLICE KeeplngSouthWalesSefe wkh udEngth Atd conetpondenco recektdh Wethmabe meirredh WtthendconetpodL HEDDLU Wanh Mnlkad l0. dlahrepond south-wales policeuk swpolice HeddluDeCymru day key

Whilst progress has been made on several matters discussed above, | appreciate that the response to vulnerable people in our community can always be improved. On behalf of South Wales Police, I provide reassurance that the improvement work continues as a priority to ensure the organisation continues to people safe, and receive the right response from the right agency: hope that this response addresses the concerns that vou set out in your report, and am grateful for you bringing them to my attention.