Independent review
Report of the Independent Review of Deaths and Serious Incidents in Police Custody
Government response
The government responded to the review on 30 October 2017.
Summary written by Accountability Index from the government's response. It is not the government's own words.
The Government says it is committed to learning lessons and delivering change in response to the review, setting out progress and new work, and has asked the Ministerial Council on Deaths in Custody to lead on the most complex recommendations.
- On legal aid for inquests, the Lord Chancellor will review the guidance so that the starting presumption is that legal aid should be awarded for the bereaved, subject to the Director of Legal Aid Casework's discretion, with this work to be completed "by the end of this year".
- The Lord Chancellor will "consider" publicly-funded legal advice and representation at inquests, including the means test, as part of the post-implementation reviews of LASPO due to be published next year.
- The Government does not consider that a new and distinct Office for Article 2 Compliance is the most effective means of driving compliance, preferring to make existing agencies' collation and dissemination of learning "more effective".
- The Ministerial Council on Deaths in Custody will consider healthcare in police custody, support for families and the inquest process, with an outline work programme running to July-September 2018.
About this review
Summary written by this siteIndependent review of deaths and serious incidents in police custody. Examined systemic failures including poor use of risk assessment, inadequate healthcare provision, and disproportionate use of restraint on BAME individuals.
Recommendations 110
Recommendation 1
Police practice must recognise that all restraint can cause death. Recognition must be given to the wider dangers posed by restraining someone in a heightened physical and mental state, where the system can become rapidly and fatally overloaded. Position is not always the determining feature. As great a danger can arise from the struggle against restraint as the restraint itself.
Recommendation 2
There should be mandatory and accredited national training for police officers in restraint techniques, including de-escalation and supervision of vital signs during restraint, with appropriate refresher training for officers. There should be national consistency in approaches to the use of force.
Recommendation 3
The grave dangers of prone and other forms of restraint in and of itself must be reiterated within forces in an effective manner and re-emphasised in training and re- training by all forces.
Recommendation 4
‘Excited Delirium’ should never be used as a term that, by itself, can be identified as the cause of death. The use of Excited Delirium as a term in guidance to police officers should also be avoided.
Recommendation 5
National policing policy, practice and training must reflect the now widely evident position that the use of force and restraint against anyone in mental health crisis or suffering from some form of drug or substance induced psychosis poses a life threatening risk.
Recommendation 6
The restraint of anyone suffering a mental health crisis should be identified in national policy and training as a high risk strategy giving rise to a medical emergency. Where all else has failed or life threatening circumstances demand, it should be used for the very shortest time possible and an ambulance should be called for immediate transportation to Accident and Emergency
Recommendation 7
Restraint equipment should be strictly limited and subject to robust monitoring and review. Its use should form part of the mandatory training.
Recommendation 8
A mandatory safety officer approach should be implemented by all police forces similar to that used in the prison setting.
Recommendation 9
CCTV should be introduced in police vans nationally to allow monitoring of restrained detainees, in conjunction with vigilant supervision of welfare and safety during transport. Failure to maintain and ensure its proper functioning should be a disciplinary issue. Unforeseen CCTV failures should not result in a van being taken out of service if a detainee requires urgent transportation.
Recommendation 10
HMIC should include a focus on inspection of observation regimes for intoxicated detainees within its Expectations of Police Custody (updated April 2016). HMIC should monitor police forces’ internal inspection procedures for observation regimes.
Recommendation 11
Custody inspections should continue to focus on the use of liaison and diversion schemes, pre-release risk assessment, and actions taken on release, as part of the inspection regimes of police forces.
Recommendation 12
Police forces should include medical input in the risk assessment process at the point of release, provided by the NHS (assuming medical services within police stations are brought within NHS commissioning).
Recommendation 13
Local Authorities should ensure that they have reasonable systems in place to ensure that all police requests for accommodation, whether secure or non-secure, are accepted. Adequate funding must be made available for local authority overnight secure accommodation of children in police custody.
Recommendation 14
Inspection findings on the continuing use of overnight detention should feed directly into a national framework that links to departments for health and local government.
Recommendation 15
The use of police custody for children detained under section 136 should be brought to an end with all NHS Trusts required to make sufficient provision of health-based places of safety to meet this requirement.
Recommendation 16
Increased funding is required for appropriate adult schemes within a national framework for commissioning. This should include improved training and consistency of Appropriate Adult services.
Recommendation 17
Custody procedures should be developed to lessen the impact of separation of mothers from young children. For example, supervised telephone contact around childcare issues should be prioritised and visits with children and their carers facilitated for longer detentions unless the nature of the alleged crime or the ongoing investigation prevents this. There should be monitoring of the extent to which police bail decisions take account of caring roles and the effects on the likelihood of absconding.
Recommendation 18
The Government should consider whether Independent Custody Visitors schemes should have governance within HM Inspectorate.
Recommendation 19
Privatisation of detention services should be avoided. Where private service providers are used the training of their staff should be to the same standards, preferably carried out jointly with police staff. They should be subject to the same processes of inspection and monitoring as police staff to ensure all-round compliance. Protocols between private service staff and police staff should be fully embedded and employed in practice to avoid fragmentation of services.
Recommendation 20
Healthcare professionals should take primary responsibility for the conduct and safe management of restraint of patients in any healthcare setting. This should be part of NHS and police policy. In the absence of support from other agencies the police may have to intervene with some form of restraint, but its use should be strictly limited and subject to robust monitoring and training.
Recommendation 21
An NHS initiative at the national level should examine whether to prohibit the refusal of access to A&E or to health-based places of safety under section 136 Mental Health Act 1983 (section 136) on the basis of intoxication. It should also consider the redesign of A&E facilities to allow for safe areas, to protect the safety of other routine patients and staff from those suffering from severe intoxication.
Recommendation 22
The Government should give consideration to the viability and cost-effectiveness of drying out centres, and consider piloting a centre or centres in large urban areas where it is most likely to be cost-effective, and linking such centres to existing A&E departments. An alternative would be the fundamental redesign of A&E departments to take into account this challenging situation.
Recommendation 23
Joint local protocols should be established between police forces, ambulance services and hospitals to ensure appropriate medical care for intoxicated people in the appropriate environment.
Recommendation 24
The use of police vehicles for transporting people detained under section 136 should be stopped in all but the most exceptional of situations. These are health emergencies (particularly where force has been used) and an ambulance should be summoned for all section 136 detainees.
Recommendation 25
The use of police stations as section 136 ‘places of safety’ should be completely phased out. Guidance should not advocate the use of police custody on the grounds that a detainee’s behaviour would be ‘difficult to manage’ in a healthcare setting.
Recommendation 26
Successful local mental health policing pilots and initiatives, particularly street triage and liaison and diversion schemes should be funded on a sustainable basis for national roll out so that, as far as possible, those in mental health need are dealt with through medical and community based pathways not through police detention. Such schemes should be subject to regular review.
Recommendation 27
There should be proper resourcing of national healthcare facilities to accommodate and respond to vulnerable people in urgent physical and/or mental health need coming into contact with the police.
Recommendation 28
There should be clear procedures around the operation of section 136 from initial point of contact, including joint protocols between police, local health services and voluntary sector organisations. Health-based ‘places of safety’ should not be permitted to exclude those who are intoxicated or showing signs of agitated/aggressive/disturbed behaviour.
Recommendation 29
An unambiguous and high threshold should be set for police involvement in any health care setting. Clear guidance should identify medical primacy of role in any health based setting involving the police.
Recommendation 30
Independent investigations should always be held for all Article 2 related cases on NHS premises where there has been police involvement, or where someone died after contact with the police.
Recommendation 31
Forensic Medical Examiners and other medical services within police stations should be brought within NHS commissioning, in order to introduce minimum standards of medical care in police custody and so that medical records of the individual are quickly available to the doctor.
Recommendation 32
Local joint protocols should be in place between all forces and their local ambulance service, mental health services and hospitals around ‘crisis planning’, particularly in respect of detainees suffering a mental health crisis and/or disturbed behaviour. Implementation of the protocols should be reviewed regularly and all staff must be familiar and confident in the practices required by the protocols.
Recommendation 33
In order to facilitate their effective participation in the whole process there should be access for the immediate family to free, non-means tested legal advice, assistance and representation from the earliest point following the death and throughout the pre- inquest hearings and Inquest hearing.
Recommendation 34
Written information about sources of specialist support, including information about INQUEST, should be given to every family at the very first contact with an IPCC representative, as well as alternative forms of information taking into account the needs of the individual next of kin.
Recommendation 35
The Coroner and IPCC staff should tell families immediately following the death of their loved one of the right to independent free specialist legal advice, the benefit of securing advice from the earliest possible stage and the right to representation of a pathologist at the post mortem or to request a second post-mortem.
Recommendation 36
This information should be regularly repeated during the progress of the investigation if the family have not sought legal advice at the earlier stage. The Coroner should provide information to families about the post-mortem examination before it takes place – including the time and location of the examination, and their right to have a representative present, and all other associated rights.
Recommendation 37
Urgent consideration should be given to the mandatory video and audio recording of post-mortem examinations in contentious Article 2 deaths, with strict respect given to the control, storage and disclosure of recorded images. Wherever possible, such examinations should not take place until the family’s chosen pathologist is in attendance. The video would serve as a record of the post-mortem but should not be used as a reason not to hold a second post-mortem examination if it is warranted.
Recommendation 38
NHS Trusts should engage with families throughout their own investigations. There should be formal guidelines setting out the nature and expectations of family engagement.
Recommendation 39
Where the NHS Trust is only one of a number of agencies investigating a death involving both police contact and NHS contact with the deceased there should be early, regular and formal communication and coordination with the IPCC and other agencies to minimise confusion, loss of evidence and delays.
Recommendation 40
The Government should consider the feasibility of a scheme to pay reasonable travel and subsistence and compensation for loss of earnings for immediate family to attend the inquest in those inquests relating to deaths in police custody. Such a measure is necessary to ensure that access to the inquest hearing is a practical reality in every case. The Government should look at existing models, for example the support offered through Victim Support, when considering such a scheme.
Recommendation 41
The Government should ensure that families have funded access to appropriate bereavement services offering specialist counselling to families of the deceased. Those providing the services should understand the impact of a traumatic bereavement involving a protracted, intrusive investigation.
Recommendation 42
All state agencies who are engaged with the family, including police, IPCC, CPS and Coroners and their staff should provide both oral and written information about support services, including INQUEST, to families as early as possible when contact is established following the death. Agencies should not assume that this has already been done by others.
Recommendation 43
Families should be provided with a private space for the duration of an inquest and treated with respect and dignity. There should also be designated family space within the courtroom itself.
Recommendation 44
There should be a presumption that families should have access to the body of the deceased as soon as possible, even if this has to be through a screen or CCTV. Where this is not possible, the reasons must be explained clearly to the relatives with all necessary empathy, discretion and awareness of cultural and religious sensitivities. Steps should be taken to allow access as soon as possible once the forensic examination is complete and once it has been determined that a second post mortem is not to follow.
Recommendation 45
Written information about sources of specialist support and legal advice should be passed to every family by the Coroner’s Officer at the very first contact. The Police and IPCC should also be subject to a legal obligation to advise the family of this right immediately on advising the family of the death. This may require translation services if English is not the first language
Recommendation 46
Following a death in police custody the police should immediately advise the Coroner as well as the IPCC of the fact and whereabouts of the death, and preserve the scene of the death from any potential interference.
Recommendation 47
IPCC staff should to be vigilant about language and communication with families and of how their conduct and communication with police officers may be perceived by next of kin. Families should be invited to express concerns about anything said by IPCC staff which may give rise to doubts about independence. This should form part of the IPCC’s learning and development around engagement with families.
Recommendation 48
The roles of the Commissioner and the lead investigator need to be made clear to families in relation to all key aspects of the investigation from the earliest opportunity.
Recommendation 49
In cases where the IPCC and HSE are actively involved, Coroners should hold prompt and regular pre-Inquest hearings requiring the agencies to liaise closely and account for the progress of their work and coordination.
Recommendation 50
Before the IPCC has formerly taken over an investigation the police should make no public comment on the matter. Unless there are exceptional circumstances which require the urgent release of information the police should not issue any information to the media, but should leave this to the IPCC.
Recommendation 51
Any information released to the media should be limited to very basic information about the deceased and the whereabouts of the death, and where possible, agreed in advance with the family, unless there are exceptional circumstances (for example a witness appeal) where time does not allow for this.
Recommendation 52
Consideration should be given to the creation of statutory time limits for the investigation by the agencies unless there are to be criminal charges made and the Coroner suspends the Coroner’s investigation. These time limits should be set by the Coroner following receipt of the report of the early meeting between the agencies. A pre-inquest hearing should be set before the expiry of that time limit or on cause shown in the event of a significant reason why the time limit cannot be met.
Recommendation 53
Police and Crime Commissioners should report annually on deaths and serious incidents in police custody in their jurisdictions.
Recommendation 54
The Home Secretary should provide an annual update to Parliament on the progress of implementation of the recommendations from this review.
Recommendation 55
Urgent consideration should be given to the development of an expert Deaths and Serious Injuries Unit of the IPCC for the investigation of all deaths in police custody in England and Wales. The Unit should be staffed by senior and expert officers from a non-police background.
Recommendation 56
The IPCC should be resourced to provide a 24 hour national on call ‘post incident’ team with sufficient national coverage to ensure immediate response and attendance at a death or life threatening injury in custody within the shortest possible timeframe. Those attending should have experience of all steps necessary to protect a potential crime scene and secure evidence. The IPCC officer should be in constant contact with a senior member of the Deaths and Serious Injuries Unit for advice, guidance and further instruction until members of that Unit have arrived at the scene.
Recommendation 57
IPCC investigators should consider if discriminatory attitudes have played a part in restraint-related deaths in all cases where restraint, ethnicity and mental health play a part (in line with the IPCC discrimination guidelines). A systematic approach should be adopted across the organisation.
Recommendation 58
Ex-police officers should be phased out as lead investigators in the IPCC. To the extent that the IPCC still consider this expertise is required, ex-police staff should act as a consultancy and training source within and, more appropriately, outwith the organisation. The IPCC should also look beyond England and Wales for expert consultants and secondees from other investigative organisations who are also expert in the investigative, forensic skills required to investigate such serious cases, for example, from the Procurator Fiscal Service in Scotland and the Office of the Ombudsmen for Police in Northern Ireland. A wider pool of expert resources can also be considered by looking beyond the immediate jurisdiction of the IPCC.
Recommendation 59
The IPCC should urgently consider whether to adopt a formal time limit for the completion of Article 2 investigations, with the lead investigator obliged to set out in writing why any extension to this limit was required.
Recommendation 60
Police forces should be held accountable at the most senior level for protecting the scene when there is a death or serious incident in custody and preserving evidence until the arrival of the IPCC. Any failure to fulfil this role should be treated as a misconduct issue. Failure to maintain CCTV cameras and audio recording equipment in good working order should carry a disciplinary sanction.
Recommendation 61
Investigations should maintain a strong focus on obtaining independent evidence, including prioritising CCTV coverage, mobile phone video recordings and the existence of independent witnesses during the immediate aftermath of an incident as well as appropriate instruction of experts.
Recommendation 62
Body worn cameras should be rolled-out nationally to all police officers working in the custody environment or in a public facing role.
Recommendation 63
The IPCC draft guidance on post-incident procedures relating to separation of officers and non-conferral should be accepted by the Government.
Recommendation 64
Other than for pressing operational reasons, police officers involved in a death in custody or serious incident, whether as principal officers or witnesses to the incident should not confer or speak to each other following that incident and prior to producing their initial accounts and statements on any matter concerning their individual recollections of the incident, even about seemingly minor details. As with civilian witnesses, all statements should be the honestly held recollection of the individual officer.
Recommendation 65
There should be a duty for police officers to provide a full and candid statement at the earliest opportunity and within the specified timeframe unless they are formal suspects.
Recommendation 66
The IPCC should make clear in its guidance that minor discrepancies in statements given by police officers or any other witnesses to fact, are natural and are not presumed to be the outcome of dishonesty or incompetence.
Recommendation 67
The Government should consider whether there is a need for a formal independent investigatory body for NHS Trusts in England and Wales.
Recommendation 68
Where an individual dies during or following restraint involving both police and health personnel, a joint independent investigation by both the IPCC and the proposed independent investigatory body for the NHS should be closely aligned and coordinated in order to investigate the full circumstances of the death, including the conduct of the health personnel.
Recommendation 69
Article 2 related cases should be dealt with in the same time scales as a civilian homicide case and the appropriate resources deployed by all agencies to achieve the completion of the investigation and decision making process within the robust timescale achieved in those cases.
Recommendation 70
The CPS specialist unit handling prosecution decisions about deaths in police custody should be reviewed to ensure it is properly resourced with experienced prosecutors for consideration of such serious cases.
Recommendation 71
There should be a formal meeting between the CPS, HSE, and IPCC within 14 days of a death or serious incident. This meeting should be chaired by the IPCC to discuss the emerging evidence, the probability and/or possibility of criminal charges and the nature of these charges, and be a precursor to regular cooperation and advice between these bodies for the duration of the investigation. The meeting should set a timetable to be submitted to the Coroner. The liaison should be formalised through a Memorandum of Understanding.
Recommendation 72
A nationally funded National Coroner Service should be urgently considered as a means to address persistent inconsistencies of service and the inability of Coroners to pursue investigations without complete reliance on the IPCC and other agencies.
Recommendation 73
A specialist cadre of ticketed and experienced Coroners should be created to preside over Article 2 inquests, under the auspices of a National Coroner Service.
Recommendation 74
The 2013 Coroners (Investigations) Regulations should be amended to allow for a second post-mortem examination as of right, paid for by the state, in circumstances where no contact has been made with the family before the first post-mortem occurred, except for exceptional circumstances where all reasonable efforts were made to contact the family in advance.
Recommendation 75
The Chief Coroner should consider issuing guidance on what constitutes disclosure of relevant information and, subject to the superintendence of the High Court, how Coroners should approach the issue.
Recommendation 76
The Chief Coroner should issue formal guidance to Coroners to prevent inappropriate or aggressive questioning of next of kin by counsel for interested persons at Inquest hearings. Coroners should be trained to be able to identify and prevent such styles of questioning where necessary.
Recommendation 77
Police must be held to account both at an individual and corporate level, where restraint has been found to have been used in an unnecessary, disproportionate or excessive way.
Recommendation 78
The IPCC should address discrimination issues robustly within misconduct recommendations, including where discrimination is not overt but can be inferred from the evidence in that specific case or similar cases involving the same officer.
Recommendation 79
In Article 2 related deaths the IPCC should consider making a formal written request for the restriction of duties (in misconduct investigations) and the suspension of officers pending the outcome of gross misconduct and/or criminal investigations, although the final decision should remain with the Chief Constable.
Recommendation 80
The IPCC should publish criteria for deciding on whether police action amounts to misconduct or gross misconduct.
Recommendation 81
The IPCC should be responsible for informing all interested persons as soon as a misconduct hearing is arranged. There must be adequate notice for a family to attend, and their rights should be fully explained.
Recommendation 82
The Government should consider whether there is a need for a family’s role at a misconduct hearing to be clarified, standardised and applied with more consistency, and advance disclosure of evidence to family members recognised as interested parties (subject to the harm test).
Recommendation 83
Once clear criteria have been made open and transparent, dismissal should always follow findings of gross misconduct unless there are wholly exceptional circumstances which justify a different sanction. Such exceptional circumstances must be fully explained to the family.
Recommendation 84
Comprehensive and standardised mandatory police training is required across forces for custody sergeants, officers and civilian detention staff on the dangers associated with intoxication. This should include medical input.
Recommendation 85
Training for privatised detention and medical services must be to the same standard as for police staff and include joint training with custody sergeants and other officers working in the custody environment. Joint training is also required for Forensic Medical Examiners and custody sergeants.
Recommendation 86
Police recruitment and training should incorporate the different personal skills and experiences needed to fulfil duties relating to the needs of highly vulnerable groups, including empathy, communication skills and the ability to employ de-escalation techniques. This should be embedded in the police appraisal process with assessment made on the correct use of force and, in particular, where officers have been able to avoid the use of force.
Recommendation 87
National, comprehensive, quality assured mental health training consistent with the above is needed for all officers in front-line or custody roles. This should span all new recruits and regular refresher training. Training should be interactive and should involve mental health users to help break down fears and assumptions.
Recommendation 88
National policing bodies and police forces should implement mandatory training and refresher training on the nature of discrimination, including on race issues, which aims to confront discriminatory assumptions and stereotypes. Policing bodies should consult with bereaved families on how such training can break down barriers and promote change. Training should take the form of a two-way dialogue allowing officers to hear the experiences of people from BAME backgrounds and include participation of bereaved families. Police training should include an understanding of institutional racism, the Macpherson report, the social context of Black deaths in custody and the impact they have had on public confidence.
Recommendation 89
The College of Policing APP on detention and custody and force training should include guidelines for pre-release risk assessment setting out specific practical steps that should be taken to provide support and protection for those at risk of self-harm on release (for example contacting family/carers before release with the detainee’s consent, or referrals to community support groups).
Recommendation 90
Police training and inspection should focus on utilising non-secure accommodation for children other than in exceptional circumstances, where children pose a risk of harm to the public.
Recommendation 91
Mandatory police training on vulnerability must include understanding of, and appropriate policing responses to those with learning disabilities and difficulties, mental ill health, epilepsy or who are on the autistic spectrum as well as other conditions which may compromise the ability to communicate and understand police actions or processes.
Recommendation 92
The use of support card schemes should be developed by all forces and included in police training.
Recommendation 93
Police training should address the particular stressors that affect women detainees and young women in particular. Officers should understand the additional impact of these stressors upon women with mental health difficulties and the importance of access to healthcare.
Recommendation 94
Families should be involved on an ongoing basis with the provision of staff training in the IPCC including training on the impact of a traumatic bereavement
Recommendation 95
Police forces, the IPCC, CPS, Coroners offices and the College of Policing should give consideration to how family experiences can be brought into training and awareness packages. As a result of the tragic experience of the loss of a loved one in police custody many next of kin have become experts on a range of issues following a death in police custody and exposing officers to these families and listening to them is an invaluable training resource for all levels of command.
Recommendation 96
Commitment and responsibility at leadership level is needed across police forces to ensure prioritisation of the issue of mental health and to bring about sustained cultural, organisational and practical changes.
Recommendation 97
There should be consistent national police policy and guidance encompassing current learning and best operational practice, reflecting the need for a drastically improved policing approach to those in mental health need.
Recommendation 98
The IPCC should ensure that race and discrimination issues are considered as an integral part of its work. This should be monitored and fed into internal learning and the IPCC’s ‘watchdog’ role.
Recommendation 99
The Ministerial Council on Deaths in Custody should conduct a review of its structures to consider whether those structures are suitable for purpose.
Recommendation 100
The Government should consider whether there is a need for an independent Office for Article 2 Compliance, accountable to Parliament, and tasked with the collation and dissemination of learning, the implementation and monitoring of that learning, and the consistency of its application at a national level. It should report publicly on the accumulated learning and compliance arising from Inquest outcomes and recommendations. It should provide a role for bereaved families and community groups to voice their concerns and help provide a mandate for its work.
Recommendation 101
An Office for Article 2 Compliance should oversee a coordinated, methodical and routine process around the dissemination of Coroners’ PFD reports and jury findings to all stakeholders, including (but not limited to) police forces, the College of Policing, the IPCC, and healthcare professionals.
Recommendation 102
The national ‘use of force’ data collection must be continually reviewed to ensure it provides the necessary transparency, auditing, active monitoring and opportunities for learning and training absent from the current system. Monitoring of ethnicity and mental health should be part of that system. More meaningful information should be requested from forms recording use of force.
Recommendation 103
There should be robust data collection on near misses and non-fatal serious incidents by the police and IPCC.
Recommendation 104
The IPCC should monitor the correlation between ethnicity and restraint-related deaths, including in healthcare settings where the police were involved. Statistics should be published breaking down restraint related deaths by ethnicity.
Recommendation 105
The national programme for police data collection on the use of force must include ethnicity and mental health (as well as other factors relevant to discrimination) in all force data so as to provide a standardised national picture.
Recommendation 106
National data collection on the use of force should be analysed by the Home Office to draw out patterns and devise national strategies to address discrimination issues. The outcome of data collection and analysis should be made public.
Recommendation 107
The IPCC should monitor ethnicity and deaths in custody against ethnicity and arrests by reference to all arrests, including non-notifiable offences.
Recommendation 108
There should be mandatory ethnic monitoring of Gypsy Roma and Traveller communities in England and Wales by police forces in their ethnic monitoring systems.
Recommendation 109
Collaboration between pathologists, psychiatrists and emergency medicine practitioners is required to clarify and standardise the medical understanding around restraint-related deaths involving mental health crises. This should underpin future police training. An international conference and further urgent research is required to achieve consensus and better understanding.
Recommendation 110
Independent international research should be carried out to look more closely at the safety of Conductive Energy Devices.
All text above is the review's.
No recommendations have this response.