Month: April 2016

Merseyside’s Hatchet Man

Merseyside’s Hatchet Man

Unlimited power is apt to corrupt the minds of those who possess it; and this I know, my lords, that where laws end, tyranny begins.

William Pitt – Case of Wilkes. Speech (January 9, 1770)

A hatchet man is a person employed to carry out controversial or disagreeable tasks, such as the dismissal of a number of people from employment. Merseyside Police employ a hatchet man with the grand title of Medical Retirement Officer (MRO) whose role is more sinister and which adversely affects vulnerable disabled officers and former officers.

His task is to prioritise maximum savings to the force budget, ‘through the robust investigation of injury award applications, appeals and reviews‘.

We quote above from his job description. This is what the man is hired to do.  Not placed there to help injured and distressed people obtain their lawful rights, but to ‘investigate’ them with the objective of reducing the amount of money which would otherwise be paid them by way of recompense for injuries incurred in the line of duty.

There is only one way to read the intention behind the role of MRO. It is a perversion of what the Regulations governing injury on duty pensions were intended to achieve. We fully accept that no public money should be awarded without due diligence. All well and good if ‘robust’ was taken to mean that great care should be taken to comply with the Regulations, but we see that in Merseyside they believe that ‘robust’ means doing whatever they think they can get away with to deny injured officers and former officers their rights.

What Merseyside’s MRO is doing is unlawful. And it is shameful.

We in IODPA are not naïve.  We understand all too well that there has to be some form of administrative procedure regarding Injury Awards which requires management by a functionary of some sort.  That being said, the functionary needs to be neutral with no set agenda other than the lawful application of the statutory duties imposed upon the organisation by the Regulations.

We are, frankly, appalled to see that the job description of the Medical Retirement Officer ignores this principle and imposes an agenda upon the position which prioritises the needs of the organisation over the rights of the recipient. The job description includes sentences such as:

[. . . ] ensure that any changes to pension payments are implemented and financial savings made where appropriate.

There should be no thought given by the Medical Retirement Officer as to the financial consequences on the force of helping to ensure the Regulations are applied lawfully. His role is an abuse of the scope and purpose of the Regulations.

When we see that the Medical Retirement Officer’s main objective is to save money for the Chief Constable it becomes clear that he can not possibly be acting lawfully.

We know, for example, that he takes it upon himself to decide whether any applicant for an injury award application is seen by the selected medical practitioner (SMP) or not.

On behalf of the Police Pension Authority, who is in farcical fact, not an impartial body, but is none other than the Chief Constable wearing a different hat, the MRO blithely breaches the Data Protection Act by forensic examination of the confidential medical records and reports of individuals.

No wonder the Chief Constable of Merseyside finds it hard to arrange for the Regulations to be administered lawfully. He is under pressure to reduce spending, and police injury pensions consume a significant part of his budget. But, that is a pill he just has to swallow. He is under a legal obligation to administer the Regulations properly. He is not entitled to look upon them as an expense which can be trimmed.

I refer the Chief Constable to the case of The Police Federation of England and Wales v. The Secretary for the Home Department (Neutral Citation Number: [2009] EWHC 488 (Admin) Case No: CO/7612/2008). This case concerned the date when new commutation factors for police pensions were brought into law.

Justice Cox stated:

The Home Secretary’s undoubted interest in the expenditure of police authorities does not in my view enable her to alter those rights and liabilities which arise under the Regulations.’


Affordability and public expenditure implications are therefore, in my judgment, irrelevant.’

It is not within the remit of any Chief Constable to direct an employee to save money by means of unlawful manipulation the Regulations. It is an abuse of his authority to specify in a job description that the MRO must approach his task with the objective of making financial savings. The over-riding intention of the Regulations is that people should be paid at the level which is appropriate to the individual circumstances. There is ample mechanism within the Regulations to ensure that this is achieved. Nobody should receive more that their due, and nobody should receive less than their due.

Merseyside has deliberately set out to ensure that the latter situation is the norm.

The MRO decides regulation 37 reviews without the benefit of any input from the SMP. He decides who has experienced a substantial alteration in degree of disablement, and who has not – and does this, not on the basis of medical evidence, but on whether the individual has increased earnings or not. He operates a rule of thumb, whereby if someone has seen an increase of over 10% in their earnings then, ipso facto, they must have had a substantial alteration in degree of disablement.

This is what he instructs former officers who are on an injury pension:

‘. . .  if you commence work or if you are currently working and your gross salary increases by over 10% you are required to inform this department as soon as practicable.’

We have to comment that the MRO has no authority whatever to ‘require’ any private citizen to inform him of a salary increase. Moreover, we feel like shouting at the MRO that a pay increase does not in any way signify that there will have been a substantial alteration in degree of disablement.

What the MRO is doing is creating an iron link between wages and disablement, when, under the Regulations, no such link exists. Disabled former officers are free to earn whatever they can, and their employers are entitled to give them a pay rise if they wish. A pay rise can have no possible link with the level of an individual’s degree of disablement. The MRO is using this as a means of reviewing degree of disablement, as an excuse for holding a review with no good reason, and as justification for reducing the level of pension paid.

Merseyside have corrupted the purpose of the Regulations and turned its provisions on their head for the sole purpose of ensuring that disabled former officers are robbed of their correct level of injury pension payment. The medical basis of assessment of degree of disablement has been abandoned in favour of an actuarial exercise where the cost exposure to the force is the bottom line.

While any question under the Police Injury Benefit Regulations is medical by nature and always requires the opinion of a SMP, in Merseyside the SMP seemingly does not make the decisions. The SMP acts only as a rubber stamp for the pre-made determination of the Medical Retirement Officer.  The Medical Retirement Officer is like an injury award hitman-by-proxy, getting paid to maximise cost savings for the Chief Constable, with no fear of any comeback.

Disabled former officers and serving officers seeking an injury award are kept in the dark. It seems very successfully, for few of them have the knowledge required to realise that they are being ripped off. Many of them are in no fit state to raise a query, and thus accept the decisions conveyed to them with no realisation that the decisions have been unlawfully arrived at. Put simply, they trust their force to do the right thing by them when injured on duty to the extent that they can no longer perform the ordinary duties of a police officer.

Clearly, that trust is sadly misplaced. There are some 880 former officers from Merseyside Police who are paid an injury pension. They need to wake up to the fact that they have, in all probability, been denied their proper pension rights.

Of course, a few individuals do raise queries with the MRO. They question his decisions. Some even manage to take matters to appeal via a Police Medical Appeal Board. Merseyside plays the numbers game. A deliberate calculation has been made, which concludes that those few individuals who do request an appeal to a Police Medical Appeal Board are far outnumbered by the majority who have no idea that they are being denied their rights.

The Medical Retirement Officer makes the decisions but never has to face the consequences. He never has to account for or justify his actions, as he is not the one who would have to be listed as the respondent at a PMAB, or at a judicial review.

The French have a term for such a position: éminence grise (French: “grey eminence”), a powerful advisor or decision-maker who operates secretly or otherwise unofficially.  An apt English phrase is ‘the power behind the throne’, someone who does not have the ultimate official position in a government or organization but who secretly controls it.

The Medical Retirement Officer is not a qualified medical authority – but is deciding what are essentially medical matters. He is making decisions for the Police Pension Authority, and we question whether he has the delegated power to do so. The Chief Constable has already delegated the day-to-day operation of his role as PPA to the head or director of Human Resources. Delegata potestas non potest delegari is Latin for a constitutional and administrative law, translated as, ‘no delegated powers can be further delegated’ and may well apply here.

According to Merseyside, a Medical Retirement Officer as well as having the skills to save the force money should also have:

‘A good knowledge of investigative procedures [. . . ].  Knowledge and understanding of the Regulation of Investigatory Powers Act with regards to surveillance and investigation of officers and pensioners believed to be falsely claiming compensation.’

Not only shall the Medical Retirement Officer have the principle duty to reduce financial costs to the expense of those injured on duty, but he is also let loose with RIPA.

Judicial approval should be the norm, not the exception, for placing members of the public under surveillance and public authorities should be compelled to report how and why they are spying on disabled persons by abusing powers that were introduced to protect us from terrorism and serious crime.

There is no room for RIPA in the administration and lawful application of the Police Injury Benefit Regulations.  Medical evidence is paramount. If the PPA has any cause to think that any individual is working the system, the regulation 37 allows for a formal review of the degree of disablement. The individual can be medically assessed by a duly qualified medical practitioner, selected by the PPA.

The SMP alone should make an assessment, and a decision, and once made that decision is final. Should there be any attempt to exaggerate one’s medical disability a qualified clinician should have little difficulty in spotting it.  If  fraud is suspected then this would be a matter for a serious criminal investigation and prosecution.  It is not open to a Medical Retirement Officer to use RIPA as a means to maximise the financial savings to benefit the force budget.

An injury award is not a benefit that has to be reapplied for – it is an entitlement for life and is final once the high bar of the initial grant has been attained.

Is all the above too hard to believe? Can you bring yourself to realise that a police force, whose job it is to prevent crime, could allow disabled former officers to be put at the mercy of a MRO whose objective is to unlawfully reduce their pensions, and to do whatever it takes to prevent injured serving officers being granted an injury award?

Here is the job description of Merseyside Police’s Medical Retirement Officer  as obtained in a recent Freedom of Information act request.


This job description shows all that is wrong with the way Merseyside, and some other forces, are administering injury awards.  The glib references to following Home Office guidance is a poor attempt of virtue signalling – making a statement that blithely mentions the requirement to ‘follow guidance’ because it thinks it sounds right and it will garner approval, rather than because anyone will actually believe it.  This job description was created in February 2015.  The Home Office partially withdrew their central guidance for injury reviews in March 2012 and then completely in February 2014.  There is no Home Office guidance to follow.

Instead, the Home Office now prefers to keep away from the misdeeds of Chief Constables and their hatchet men. The Home Office now says,

‘We would advise, in the event that such reviews are being conducted or considered, that police authorities should satisfy themselves that they are acting in accordance with the regulations and the relevant case law in the light of the decision in Simpson.’

IODPA suggest that the Chief Constable of Merseyside take a long hard look at what has been done, and continues to be done in his name by the Medical Retirement Officer. If the Chief Constable fails to act then our suspicion, that every breach of the Regulations committed by the MRO is done with his approval and encouragement, will be justified.

There are 880 individuals retired from Merseyside who receive an injury pension. There needs to be conducted and independent and scrupulously fair and impartial appraisal of how each and every one of their injury pensions have been administered.


Award Bands and Length of Service

Award Bands and Length of Service

“Elections belong to the people. It’s their decision. If they decide to turn their back on the fire and burn their behinds, then they will just have to sit on their blisters.”
Abraham Lincoln

Elections of police and crime commissioners in England and Wales are scheduled to take place on 5 May 2016. This will be the second time police and crime commissioner elections have been held.

There was little interest or enthusiasm from the electorate the first time round, but now we have had the opportunity to see how these commissioners performed, perhaps we might feel more inclined to use our votes – if only to get rid of the one’s who have proved themselves to be a liability.

One such is Sue Mountstevens, whose area is Avon and Somerset.

Soon after the 2012 elections, Sue Mountstevens and finance officer John Smith, without any understanding of the Regulations which govern police injury pensions, dreamt up a scheme to reduce the financial commitments of Avon and Somerset by seeking to reduce injury awards.

To emphasise their agenda they started with a selection of some of the disabled former officers who were on the highest band of disability and who were retired young in service. Clearly, Mountstevens figured this was where the most savings could be made. As John Wayne might say, ‘She sure figured wrong.’


[click and use the bottom left arrows to navigate to all the 4 pages, including Damian Green's decorous reply]

Other entries in this blog recount the outcome of the sorry saga that this abortive attempt to rob pensioners turned into. Rather than save money Mountstevens has cost the ratepayers a small fortune in payments to Dr Johnson, who decided that for the sake of his own reputation it was safer not to make any decisions rather than be blamed for the debacle.

So that a mistake of this magnitude won’t be repeated, we would welcome all PCC candidates to read the information posted on this site.

And to help all PCC financial officers we can hereby say with absolute certainty that mass reviews, or any process that has lurking behind it any intent to reduce the injury pensions of disabled former officers which is based more upon budgetary considerations than anything else, is unlawful and will be successfully challenged.

Choosing which pensioners to review solely by the band of pension payment they receive is improper, immoral and unlawful. It is no different to the unlawful and now withdrawn Home Office guidance of reviewing and reducing those who had reached compulsory retirement age.   That was aimed purely at saving money and subsequently cost those forces which had zealously implemented it hundreds of thousands of pounds in legal fees and compensation.  The unlawful guidance had the secondary affect of introducing a raft of case law from strong judicial decisions which defined how the Regulations should be properly administered.

The injury pension of any individual is unique to that person’s individual circumstances of disablement and any review of a pension has to occur only at a suitable interval relevant to that individual’s circumstances.  It may well be suitable never to review.  Lumping bands together in order to mass review is as much an abuse of the Regulations as saying those over 65 have no earning capacity.

Let’s take a moment to see how injury awards are calculated. Potential PCC’s please note.

An injury award is calculated by reference to the person’s degree of disablement, his or her average pensionable pay and the period in years of their pensionable service. Schedule 3 Police Injury Benefit Regulations provides for the following minimum income guarantee based on the band awarded and the length of service.

Degree of disablement Gratuity expressed as % of average pensionable pay Minimum income guarantee expressed as % of average pensionable pay
Less than 5 years’ service 5 or more but less than 15 years’ service 15 or more but less than 25 years’ service. 25 or more years’ service.
(1)       (2) (3) (4) (5) (6)
25% or less (slight disablement)         12.5% 15% 30% 45% 60%
More than 25% but not more than 50% (minor disablement)         25% 40% 50% 60% 70%
More than 50% but not more than 75% (major disablement)        37.5% 65% 70% 75% 80%
More than 75% (very severe disablement)          50% 85% 85% 85% 85%

As can clearly be seen, the percentages within each band increase as the length of service rises.  This means that those retired with more ‘reckonable years’ in service will always have a higher ‘minimum income guarantee’ (the injury pension)  than those retired young in service.

But how does this work with real examples?

Let us examine 4 hypothetical individuals (wages simplified and not lifted directly from police pay-scales):

#1 Retired with 4 years service with a final salary of £25000 ( less than 5 years)

#2 Retired with 7 years service with a final salary of £30000 ( between 5 and less than 15 years)

#3 Retired with 18 years service with a final salary of £35000 ( between 15 and less than 25 )

#4 Retired with 26 years service with a final salary of £40000 (over 25 years)

This diagram shows the proportion of minimum income guaranteed by each band and grouped by years service.  For example, Individual #1, with < 5 years service, has a potential band one figure of £3750 and a band four of £21250.  This is inclusive of both the medical pension and the injury award.


As can be seen, a band one with 26 years service receives a higher minimum income guarantee than a band four with less than 5 years service.  Moreover, the injury award makes up a higher proportion of the minimum income guarantee than the medical pension for those with less service as obviously they have less accrued pension contributions. This seems logical as the older IOD (those retired with more service) has less years of life expectancy to be compensated for the work injuries received.  But this isn’t always the case.  A police constable could be in the their mid-forties and still be a probationer.

This is why just grouping by banding takes the whole award out of context.  The length of service and the final salary have strong correlations to the given band of the award, just as much as the injury itself.

Looking at the above plot you can see the blunder of targeting just the higher bands in any unlawful program of mass reviews.  Any such targeted action is age discrimination against those unfortunate enough to be injured young in service (note – not necessarily age, but service). Likewise, reviewing a band four at 60 years of age for the first time in decades, when they only have the  misfortune (apologies for the bluntness) for their health to deteriorate further and little prospects in any labour market when they have been unable to work in any capacity since leaving the police, is just as perverse.

Refusing to review band one pensions (such as has been the recent practice in Merseyside) is more to the detriment of those retired young service than those who were retired a couple of years shy of their full 30 years service.

Every decision to review has to be based on the individual.  A police pension authority has to apply their mind to consider whether it is appropriate to review that individual, by both first examining whether a suitable interval has elapsed and then considering whether the degree of the pensioners disablement has altered.

We in IODPA think that Mountstevens, her finance officer, and senior people in Avon and Somerset Constabulary reflected the attitudes which are prevalent in some other forces across the country. They think that because injury pensions are paid out of the force budget, then they are ‘fair game’. Such attitudes are wrong. Police injury pensions are protected by law – by the Regulations. They must be administered according to the Regulations and any impact on the force budget, for good or bad, should not enter into any decisions made concerning that administration.  The judicial review of R v. East Sussex County Council ex parte Tandy (page 9 paragraph 3) states

‘To permit a local authority to avoid performing a statutory duty on the grounds that it prefers to spend money in other ways is to downgrade a statutory duty to a discretionary power.’

 In other words, in this judicial review the House of Lords found that, for a public body, the availability of financial resources is an irrelevant consideration when statute indicates a standard to be determined.  For injury awards the standard is defined in statute by the Police Injury Benefit Regulations 2006.

Mountstevens failed to realise that her duties did not extend into allowing her to interfere with the proper administration of injury pensions. We hope that her failure will serve as a warning and as a lesson to any new PCC who takes over her role.

Why Things Hurt

Why Things Hurt

“Of pain you could wish only one thing: that it should stop. Nothing in the world was so bad as physical pain. In the face of pain there are no heroes.”
George Orwell, 1984

This post is about the complexity of pain and the observation that the doctors used by police pension authorities are not able to comprehend how the world of a previously fit and high-achieving police officer collapses once they are injured on duty.  It shows that the consultants, GPs and clinicians of the former officer -who know of and have treated the individual – heavily out-guns the opinion of any given selected medical practitioner.

You haven’t had any contact with the police for years and now they want to reduce their financial commitment by reviewing your injury award .  There has been no change, in fact you’re worse now than ever.  You just want to be left alone to live your life.  Or you are a serving officer struggling on long term sick leave and currently the victim of an UPP.

How can an occupation health doctor make a valid judgement on your health in a 60 minute ‘interrogation’ – don’t fool yourself into thinking it is anything but an inquisition: imagine Tomás de Torquemada assisted by the full incompetence of a HR department.

An injury on duty can involve both body and mind and quite likely both.  A physical injury has psychological consequences. PTSD (Post Traumatic Stress Disorder), is caused when a person experiences an ordeal that causes physical harm or mental harm. The individual was either harmed, someone close to them was harmed, or they experienced events that was imprinted in their brains.  In PTSD, there are two main parts of the brain that are affected and also where all the chemical imbalance in the disorder is located at. The two main parts are the Hippocampus and the amygdala.

The hippocampus is a part of the brain that is located inside one of the folds of the brain so it is not identifiable by the human eye but the way we can find it is that it is located at the temporal lobe which lies right under the temple of the human body. An important function that the hippocampus does is that it makes information into memory and stores it in the brain. So, for example, someone experiences a traumatic event in their life and they can’t forget about it even though they try really hard to. The hippocampus has taken this traumatic event that this person has and stored it in their brain as a memory which explains how PTSD works. This part of the brain can also send connections to the amygdala which then could explain the beginning of strong emotions triggered by specific memories or events. But it is not just for making memories. It also plays a huge roll in the making of creating new brain cells for the brain. The hippocampus may look intimidating but it can be affected very easily. Alzheimer’s Disease, Epilepsy, and little blood flow are just some of the injuries the hippocampus could have.

The other big part of PTSD is the amygdala. Like the hippocampus, it is also part of the limbic system and is also inside the brain just above the hippocampus and the lateral ventricle. This is the epicenter of emotional behavior, emotions, and also motivation. A lot of signals from the other brain parts go to the amygdala because it then makes those signals into emotion. The amygdala can produce components of emotion such as heart rate changes, blood pressure changes, and also respiration changes in the body. While the hippocampus makes memory, the amygdala takes those memories and combine them with emotion which could explain why certain memories produce certain emotions for us such as happiness and fear. This is where the “fight-or-flight” mechanism comes into play. Since so many alarm circuits of the human body are located in the amygdala, there is a lot of triggers that can activate the “fight-or-flight” response.

Sufferers of PTSD are prone to chronic pain and sufferers of the chronic pain of debilitating physical injuries are liable to suffer from PTSD-like chemical imbalances.

The author of this post has a physical injury that has also manifested itself psychologically.  Chronic pain does that.  A life not lived; a career cut short. Over time, to treat the condition, nociceptive prescription pain medication is supplemented with neuropathic medication.  But we are still dragged in front of a SMP and demanded to explain ourselves.  Questioned in a hour window on why we are no longer the high achievers we once were.

This video gives an interesting insight into pain but reveals a terrible dilemma.  We are all individuals,and as IODs, all our circumstances are different.  Herein lies one of the complexities that makes understanding and treating chronic pain so difficult.

Professor Lorimer has the advantage of being on the top of his game.  He has a successful career in clinical Neurosciences. His lecture is factually correct.  Experience doesn’t always match the explanation.

For the individual chronic pain is a reinforcing web of pain signals, personal history, seeking security in what you know (pain) and limited ability to envisage a future.  It is life consuming and this is why the Regulations are there to compensate for work-related injuries.

SMPs are not equipped to understand how the brain creates and perpetuates pain.  They will always fail to make a valid judgement on your health in an allotted 60 minutes.  For this reason if you are ever unfortunate to go in front of a SMP, for whatever reason, go prepared.  Make them understand the complexity of your illness.

Snakes, no Ladders

Snakes, no Ladders

The only way is up down, baby
For you and me now
The only way is up down, baby
For you and me
Read more: Yazz – The Only Way Is Up Lyrics | MetroLyrics

“The Curious Case of Benjamin Button” is a short story written by F. Scott Fitzgerald and first published in Colliers Magazine on May 27, 1922.  The film version stared Brad Pitt but wasn’t as good.

Fitzgerald wrote a comic farce, which the film turned into a forlorn elegy. The film’s approach makes Benjamin the size of a baby at birth. Fitzgerald sardonically but consistently goes the other way: The child is born as an old man, and grows smaller and shorter until he is finally a bottle-fed baby.  He starts as infirm and dilapidated and becomes more healthier and youthful as he ‘ages’.

And? … you say, whether Benjamin started as a baby-sized old man or old man sized newborn is moot as both versions of Benjamin Button’s story is a fantasy – and what’s your point anyway? I hear you ask.  

A tragic story in the style of the great Fitzgerald could be written in the modern day as the telling of the story of the disabled former officer, injured on duty through no fault of his or her own, who as they age, they can only get better. In other words their degree of disablement can never, ever deteriorate by means of a substantial alteration and their degree of disablement never spirals upwards.

Is this still fiction?  No.  It’s happening in Merseyside.

No single person on a band one in Merseyside was reviewed in 2015.  Of the 502 reviewed they were all band two or higher, of these 25 were reduced and 477 unaltered.  But this force has 880 IODs, so what happened to the remainder?  The stark answer is that the 378 that were left alone and not reviewed were all band ones – just like Fitzgerald’s Benjamin Button, Merseyside has taken the view that they can only become healthier as time progresses.

Hang on though.  Is there more devious and nefarious  plotting going on here.  Could it actually be that Merseyside hasn’t reviewed band ones because this opens them up to the possibility of increasing the awards of those they review?  Enough of the grimly mocking  tone.  This is real and is exactly what has happened.


The Merseyside review process has deliberately ignored the tranche of IODs that can only have two responses if ever reviewed – increased, or kept the same.  This is not down to chance – this is overt maladministration in its dirty and unambiguous obloquy .  The blue in the below chart shows the band ones that were not reviewed against those higher bands that were.


As mentioned before on these pages, we have data from most other forces concerning recent reviews and, overall, nearly 7% resulted in an increased injury pension payment – so, of the 502 reviewed, we should have seen approximately 35 people increased in 2015.   Not only are Merseyside deliberately failing to review those band ones whose degree of the pensioner’s disablement can alter only by virtue of his or hers earning capacity deteriorating, of those that they did review not one person was increased.  The probability of no person out of 502 being increased when 35 should be expected to be increased is 0.0000000049 (chi-square test). In context, the probability of winning the National Lottery is  0.0000000222.

In other words there is no fluke here,  no bizarre influence of chance that saw not a single increase in banding – it was deliberate.  As deliberate as ignoring all those who are band one.  Merseyside has acted totally contrary to the purpose of the Regulations and are unlawfully using reviews as a cost saving device.

If mass reviews could ever be fair then there is a prerequisite that it is more likely for someone to be increased as there is for someone to be reduced.  After all, time is by it’s nature degenerative – only Benjamin Button enjoys the opposite. It is a travesty that band ones are likely to remain trapped in the lower realms of percentages, unable to become upwardly mobile because they are deliberately ignored purely as a review of them will increase the forces injury award commitment and, in the absence of any knowledge that they can ask to be reviewed, likely to continue to struggle with an award too low in relation to their lost capacity to earn.

Too many snakes and no ladders.  For every snake, there should be a ladder; for every ladder, a snake.  But not in Merseyside – here there is one snake: the HR department.  And this creature is greased with slime.  Once down, there is no way back up.   This is not the purpose of the Regulations.  Merseyside are blatantly abusing their position as the administrator of the injury award system and should be held to account.