Dr David Bulpitt

The ICE… is gonna BREAK!

The ICE… is gonna BREAK!

“He who cannot put his thoughts on ice should not enter into the heat of dispute.”
Friedrich Nietzsche, Human, All Too Human

The ultimate temperature test of a Police Pension Authority’s malevolence towards injury awards is how they consider what is a self-created paradox of the ‘band one issue’.

The end game of some Police Pension Authorities is to achieve reduction of all injury pension payments by means of unlawful reviews. But what to do with those who can’t be reduced further? What to do with disabled former officers who are on band one, the lowest band of payment?

Band one presents them with a conundrum. Their thoughts run like this. Reviewing band one pensions might open a box of worms. Should we review them? If we do, then we can’t reduce them, so it would be a waste of time and money, but some of them might well qualify for an increase in payment, which would cost us money. We might also uncover a lot of historical maladministration and face endless complaints, appeals and litigation, which would also cost us money. If we don’t review them, then we leave ourselves open to accusations of disablement discrimination. We can hardly claim we have a duty to review if we then decide not to review band ones.

For so long as these rogue police pension authorities try to justify the contradiction that it’s ‘not all about savings’ whilst holding reviews which so very obviously are for the sole purpose of attempting to save money, they will find it harder to maintain their stance indefinitely and, meanwhile the ice they skate on is getting thinner and thinner.

Staffordshire Police, for example, have a tendency to use dubious practices when an injury award is first decided, such as using their arcane Police Earning Assessment Matrix, to bias the calculation of the degree of disablement heavily so as to only produce disablement levels within band one.

Other police forces such as Merseyside and Nottinghamshire go out of their way to review those in receipt of a band two award and above, so regularly and unlawfully that it just becomes a matter of time until the medical retirement officer civilian or the ‘gun for hire’ SMP succeeds in reducing the award to levels acceptable to the force accountants, but unacceptable and unlawful in respect to legislation.

Merseyside clearly implied in their answer to a freedom of information request that people with injury awards can only ever improve, never deteriorate.  In any case, it seems Merseyside is of the opinion that if the people they medically retire do deteriorate they can’t be bothered to find out.  Action by a public authority cannot be lawful unless there is a positive power that falls within legal restrictions and discharges lawful duties.  Cherry-picking how and when to impose a power isn’t any of these things.

Band 1 will not be reviewed unless requested by the former officer and in that case they would be seen as a priority.


“Seen as a priority” can be interpreted as getting a quick phone call back from Merseyside, from a panicky medical retirement officer, who is intent on convincing the vulnerable that it’s futile to attempt to justify an increase to an award.

Then there are forces like Cambridgeshire, who zealously carried out the unlawful Home Circular 46/2004 whilst deceitfully telling those it affected that it was never about the money, when, in reality, it was always all about the money. Cambridgeshire spent a small fortune of taxpayers’ money in pursuit of illusive savings only to find they were on a fool’s errand. In 2010, Cambridgeshire suspended all reviews. Then in 2012 produced a new policy which limited the number of reviews. Recently there has been a decision to suspend their so-called ‘proactive’ review program. A report to Cambridgeshire Constabulary’s Force Executive Board by the new Director of Human Resources, who runs the recently-formed tripartite Beds/Cambs/Herts HR function, recommends,

‘That in the absence of current national guidance on Injury Award Reviews and the diminishing likelihood of accruing further savings, the current proactive review process be suspended. Recipients will still be able to request reviews where, for example, they believe that there has been a significant change in their degree of disablement, relative to the relevant injury.’

And –

‘The process of carrying out first reviews has generated some savings through the reduction in bandings of allowance for some recipients. However, experience shows that any further reductions in bandings is less likely as a result of second and further reviews.’

Ooops! A bit of a slip there. Do we hear the ominous crack of breaking ice? An admission by Cambs that the driving force behind reviews has always been to achieve savings. No mention of the true intent of the provision of a review process in the Regulations, which is to ensure that disabled former officers continue to receive the amount of injury pension which their disablement qualifies them for, should their degree of disablement alter substantially – for worse, or for better. We suspect, however, that it is less of a slip but rather some sure-footed footwork by a Director who has her heart and her brain fully ethically engaged. She has perhaps recognised the dreadful impact which unlawful or unnecessary reviews bring, to the individuals concerned, and in a different, financial, budget-busting way, to the forces concerned.

The review provision in the Regulations care not what band a person is. The Regulations are blind to the cost implications. Approaching reviews from the point of view of using them to save money is unlawful and immoral. As we have said many a time, injury awards are a form of compensation of work related injuries quantified by the affect the injury has had on a person’s capacity to earn.

Instead of their true purpose, some police pension authorities have corrupted injury awards into the politics of welfare, to what can be termed a ‘race to the bottom’; that is, a drive to cut costs, provision and standards.

There would be a massive improvement in the discourse of injury awards if those who administer the Regulations would calm down enough to think hard about what was being said and to examine its possible truth value.

If the rogue Police Pension Authorities could, for once, examine the ‘heat’ they put into liking or advocating the unpleasant things, plastered all in the emails they distribute between themselves behind closed doors, and start to see the light, there would less opportunity for any independent observer to incessantly impute badness to these people.

Their public face says reviews are nothing to do with the money. Safely sat at their desks their half-truths and lies are forgotten whilst the hot potato of unlawful reviews is put aside to allow them to concentrate on the pressure from above, from the bean-counters and ignorant Chief Constables who see only balance sheets.

The burning – indeed ice melting – question is why would a certain HR manager, one who has been at the centre of the review fiasco in Avon & Somerset since its inception, think its appropriate to ask her force’s Finance Director whether band ones should be reviewed?

There’s nothing in the Regulations to say band ones should be treated any differently from any other band … so, with asinine brashness, Avon & Somerset’s Police Human Resources Manager of Planning, Christine Jones, brings the whole massive iceberg to the surface in her witless puzzlement of why the heck are they even considering to review band ones!

Come on guys, what’s the point? – she asks. It’s not as if we can reduce them any further!


Realising the thin ice that Jones is blundering across has not only cracked but in danger of shattering, Dr Bulpitt, the force’s highly paid Medical Advisor, attempts damage limitation concerning any ‘wild’ assertion from his staff that this is all about reducing people and saving money.

With a rheumy eye to future disclosure under the Freedom of Information Act, Dr Bulpitt, steps in to suggest that he is only doing this mass review program for the benefit of the unfortunate band ones!


So, according to the kindly, caring Dr David Bulpitt, those former officers who are on the highest band, classified in the Regulations as being the victims of ‘very serious disablement’ as a result of performing their duty, are nothing less than ‘selfish’ and ‘fortunate’.

It seems, from this memo, that once Bulpitt thinks the cracking, popping, chirping and pinging from the ice has lessened from Jones’ heavy footfalls, his Tourettes kicks in and normal service resumes. He reverts to his usual nasty, brash, inconsiderate, disability discriminatory self. His memo reveals he thinks his attempts to say as many people should be increased than reduced has stopped the ice from weakening.

His disingenuous claim that reviews are ‘all about the band ones‘ doesn’t, in any way imaginable, mask his claim that those forced to end their career with a severe disability to their earning capacity are ‘fortunate‘ and ‘selfish‘ in their desire to be treated both with dignity and within the law.

Let’s be clear – a doctor, a highly paid medical professional, employed by a police force, has gone on public record that people with a severe degree of disablement which ended their police career are ‘fortunate’ and ‘selfish’.

Why is Dr Bulpitt’s statement about band ones all pretence and covering-his-back bluster? Because in Avon & Somerset between 2005 to 2010 there was not a single increase to any injury award at all. Not only was no single person with a band one increased, there were no increases at all of any banding.

Dr Bulpitt could, of course, send a letter out to every one of the 70 band ones identified by Christine Jones and ask them politely if there has been a deterioration to their medical condition. It is fair to say the probability of him sending such a letter is less than that of Donald Trump converting to Islam and still being elected President.

Dr Bullpitt could also, of course, recommend to his Police Pension Authority, who is the Chief Constable, that he hire another SMP just to review all those on band one. Band one pensioners would be unlikely to object, wouldn’t they? He has chosen not to make that recommendation, for the simple reason that his words are a sham. He has no intention of wanting to see band ones reviewed. He records his fake concern for them only to lay down a get out of goal free card, should he need it. Perhaps this is a sign that he realises the end is now not very far away?

Just like the dungeon scene in Monty Python’s Life of Brian, Dr Bulpitt is effectively saying this to those on any award higher than a band one: You lucky, lucky bastards.  Proper little jailer’s pet, aren’t we? You must have slipped the original SMP a few shekels, eh?

There is no sign from this doctor of any understanding that those on higher awards could have been retired with a higher degree of disability simply because their disablement qualified them for it. He seems to be fixate on some unstated conviction that all bands above band one were the result of some sort of ‘fix’. He pays only lip-service to the fact that there are band ones with an award too low for the disability inflicted upon them. It is abhorrent that a clinician, with such callous condescension, can dismiss all historical awards which were given by his predecessors.

The fact is, Dr Bulpitt, that pensioners themselves were not responsible for deciding what band they were awarded. Those decisions were made by senior people within the organisation, overseen by the then Police Authority. Most, probably all of those disabled officers had no knowledge of the Regulations, and in the midst of the trauma of injury and enforced retirement could hardly have been in any fit state to query the decisions of those in authority. If you think that the ‘wrong’ bandings were decided, then why are you calling pensioners selfish and fortunate? Why are you not calling for your predecessors and for former Police Authorities and former Chief Constables to be investigated and made to account for their decisions?

Bear in mind though that those decisions can not now be overturned. The law is very clear on that point. Decisions are final, subject only to appeal within certain time limits, now long past. Also, can you imagine the disastrous publicity which would ensue should any force attempt to hound disabled people, not for mistakes made by them, but for mistakes made by their former force? What would the Home Office have to say about that, Bulpitt? Given that the Home Office might well have been encouraging Chief Officers to rid themselves of disabled officers at that time? A word of advice, Doc – don’t go looking for any support in that direction. They have long decided they want nothing more to do with existing injury pensions; having sipped from the poisoned chalice once they are not coming back for another quaff. Ask the suddenly retired, aged 54, former Chief Constable of Cambridgeshire what support she got from the Home Office when her particular injury pension scam was revealed in all its sordid glory.

We’ve mentioned that Dr Bulpitt seems to be clumsily mitigating Christine Jones’ attitude to band ones, knowing full well that the emails he types can find their way in the public domain. But isn’t it more than likely that Jones is just saying exactly what she has learnt from the jerky personality of Dr Bulpitt? Hierarchy works like this: when anger and intimidation flow down, initiative stops flowing up.

Christine Jones has summarised the whole attitude in Avon & Somerset: Why review when they can’t be reduced further …

And why is this disclosure important?

Because serving officers are currently in the ‘care’ of Dr Bulpitt and the culture of disrespect towards disabled former officer is not confined to them – it extends to any serving officer unfortunate enough to become injured on duty. Dr Bulpitt’s words are but a visible symptom of a deeply-engrained institutional attitude of disrespect which, if allowed to continue uncorrected will have adverse effect on the efficiency and morale of the force.

The link between harsh words and medical errors was reignited in 2012 when Lucian Leape, Professor of Health Policy at the Harvard School of Public Health, published a two-part series in Academic Medicine. Leape and his co-authors asserted that,

‘A substantial barrier to progress in patient safety is a dysfunctional culture rooted in widespread disrespect.’

The series also reported,

‘Disrespect is a threat to patient safety because it inhibits collegiality and co-operation essential to teamwork, cuts off communication, undermines morale, and inhibits compliance with and implementation of new practices.’

The £159,000 remuneration of A&S’s Force Medical Advisor should dictate that the recipient of the salary is beyond reproach in their maintaining of high standards. Sadly the Bulpitt exception proves the rule. Also sadly, it is doubtful whether the Constabulary will do the right thing and dispense with the services of the dubious Dr Bulpitt. They could get a decent doctor for half the price: that’s a legitimate way to save money.

What is certain is that until the culture changes, the maladministration will continue, and people like Dr Bulpitt and Jones and Kern will continue to skate on thin ice until they and this particular police force sinks under the weight of more and more scandals.

Battle of the ALAMA

Battle of the ALAMA

“I am at liberty to vote as my conscience and judgement dictates to be right, without the yoke of any party on me… Look at my arms, you will find no party hand-cuff on them. ”
David Crockett

In 1835, Mexican President Antonio Lopez de Santa Anna (1794-1876) threw out the nation’s constitution and made himself dictator.  Many Americans in Texas, as well as Tejanos (Mexicans in Texas), hated this blow to their liberty and the growing tensions between Mexico and Texas erupted into violence when Mexican soldiers attempted to disarm the people of Gonzales, igniting the Texan war for independence. Like other states discontented with the central Mexican authorities, the Texas department of the Mexican state of Coahuila y Tejas rebelled in late 1835 and declared itself independent on 2 March 1836.

The Battle of the Alamo (February 23 – March 6, 1836) was a pivotal event in the Texas Revolution. Mexican troops under President General Santa Anna attacked the Alamo Mission near modern-day San Antonio, Texas, United States, killing all of the Texian defenders, one of whom was the famous Davy Crockett.

In an ironic twist of events, Santa Anna had fought for Mexico’s independence from Spain, only to decide to crush the independence desired by the people of Texas.

The Texas revolution finally ended at the battle of San Jacinto on April 21, 1836. It had been an uprising in defence of liberty.

Santa Anna shared a characteristic common to many other dictators. He was as contemptuous of the views, and rights, of the people of Mexico as he was towards the Texians. In 1824 Santa Anna gave his opinion as, ‘A hundred years to come my people will not be fit for liberty. They do not know what it is, unenlightened as they are, and under the influence of a Catholic clergy, a despotism is the proper government for them, but there is no reason why it should not be a wise and virtuous one.

In 2016, a senior representative of an organisation named the ALAMA, which boasts a membership of just 300 occupational health doctors, seems to have experienced a fit of pique. He lobbied the GMC in an attempt to get it to change its rules so as to exclude a certain class of people from the principles of confidentiality and respect for patients’ privacy that all doctors are expected to understand and follow. That class of people was disabled former police officers.

The ALAMA representative wished to prevent them from exercising their right to see a copy of any report written by a SMP before it is sent in to the commissioning authority. He wished to see disabled former police officers also lose their right to withdraw their permission for any such report to be sent in should they find fault with it. (See the guidance on line at http://www.gmc-uk.org/guidance/ethical_guidance/confidentiality_contents.asp)

The lobbyist was Dr Bulpitt, who is Force Medical Advisor for Avon and Somerset Constabulary. He is is the official police representative of ALAMA –  the Association of Local Authority Medical Advisors. He is no Santa Anna, but from him there emanates more than a whiff of the characteristics which distinguish dictators. His approach to the GMC demonstrates that he is contemptuous of the considered democratic view of the eminent GMC, which sets the standards which the more than 281,000 doctors registered with the GMC are required to follow. We are also suspicious that his lobbying was a personal campaign, and does not truly reflect the views of the members of ALAMA.

In ALAMA’s name, Dr Bulpitt has discarded the self evident truth that the GMC guidance follows legislation and complies with legislation. He fails to see that when the law isn’t applied to some, it doesn’t apply to any.

But is it the position of ALAMA, or the views of one man?  We can’t tell if it is the organisation as a whole which is intent on destroying the rights of disabled former police officers, or whether Bulpitt’s lobbying is an example of an individual unilaterally abusing his position within ALAMA to perform some sort of ‘Game of Thrones’ politics of power play.  

Dr David Bulpitt’s position and influence within this small organisation does not just have local consequences within Avon and Somerset. ALAMA represents many of the doctors who work as SMPs across the country. Should Dr Bulpitt’s views sway the GMC to amend its guidance, then that will affect every injury award review and injury award application nationwide.

Unlike Davy Crockett, who solely relied on his conscience and judgement, this particular doctor has the yoke of best practice defined by a regulatory body to adhere to –  best practice that he wants to have the ability to choose when to park aside and who and when to exempt, to suit his own agenda.

ALAMA was founded after a conference on inhalation hazards in Firemen held in Edinburgh in March 1979. In April 1980 a follow-up meeting for local authority doctors in Manchester saw the start of an ALAMA steering committee.

The declared aims of the Association were to hold an annual meeting, to develop some kind of link with the Society of Occupational Medicine, the Faculty of Occupational Medicine and the British Medical Association.

Plainly, its founding aims were not to lobby the GMC to discriminate against certain cohort of people! So, what is the exact lobbying we are talking about?

The GMC are currently reviewing their 2009 Confidentiality guidance – making sure it is “relevant to doctors’ needs and to be compatible with the law throughout the UK.”  The public consultation on the revised draft of the guidance on confidentiality closed on the 19 February 2016.

In January 2016, almost three months after he had professed to the Home Office that he had already contacted the GMC, Dr Bulpitt used ALAMA headed notepaper to belatedly write to that organisation.

(select and use arrows bottom left to navigate pages)

Within his letter he compared the right of certain specified members of the public – who happen to be people retired from the police service – to withdraw consent for medical reports (under the Access to Medical Reports Act) to being synonymous to condoning a repeat of the 2014 Glasgow bus catastrophe that killed six and injured fifteen others.

Just like the Tejanos in 1835, we are understandably appalled at the attack upon our liberty. Such purging of protection under the law for chosen targets leads inevitably to greater and greater abuses and more and more destruction of rights. This process was aptly chronicled by  Martin Niemöller … to misquote this pastor, “First they came … for the people with disabilities. And I did not speak out because I did not have a disability”.

Dr Bulpitt sets his scene by first constructing a diversionary straw-man argument. Ignoring the contentious and unlawful mass review programs instigated by a minority of police pension authorities to reduce their ‘financial exposure’ to the cost of police injury on duty pensions, the doctor starts with smoke and mirrors by saying the OHP (occupational health practitioner, in other words the SMP) is only concerned with the fitness to work, in an attempt to sway the GMC Assistant Director for Standards & Ethics away from his true agenda.

Why let the truth get in the way of a good yarn? That his lobbying has no basis in fitness to work, dealing as it does with the destruction of the rights of people pensioned off from the police service, doesn’t cause Dr Bulpitt to see the irrelevance in his narrative.

Clinical Information obtained and recorded by OHPs, especially during a one off assessment, is exclusively for the purpose of advising employee and employer on fitness for work.  Therefore the consent to request this information is made in that context. Clinical  information is not obtained to provide clinical care and therefore the basis of the consent to  request it is quite different from Drs who provide clinical care.

According to the Introductory Memorandum to The Police (Injury Benefit) Regulations 2006  the Police injury awards do not depend on membership of the Police Pension Scheme, but are in effect compensation for work-related injuries (the degree of disablement in relation to capacity to earn).

Continuing to omit things which irritatingly do not tally with his story, Dr Bulpitt fails to say that a great many SMP’s have in fact become of late a pale shadow of the independent and impartial decision-makers which they are required to be in law.  He leaves out the inconvenient fact that he regularly demands clinical information including full medical records since birth; expunges from his lobbying of the GMC the information that the occupational health unit almost always did provide clinical care to the injured police officer whilst injured and still in service.

Apparently, in Dr Bulpitt’s version of the parliamentary process, it is only civil servants in the Home Office that ‘sets down’ legislation, conveniently forgetting the role of the Houses of Commons and Lords.

The Police Pension Scheme serves as a particular example of where clarity is urgently needed as to whether additional consent is necessary once an individual has requested their employer to enter them into the process for health assessment, and consideration for payment related to ill health. At present GMC guidance appears to sit uncomfortably with the Regulations for the Police Pension Scheme which are set down in Legislation via the Home Office.

Rather peculiarly, the official ALAMA representative’s letter goes from faux concern for Council employed drivers; Police Officers using Firearms; Teachers with responsibility for children, on directly to his real bugbear – the Police Pension Scheme.

Could it be that mention of other local authority aspects were just a diversionary tactic?  Is his real true agenda purely to convince the director of ethics that there is an imagined disconnect between GMC guidance and the Police Injury Benefit Regulations?

At present GMC guidance appears to sit uncomfortably with the  Regulations for the Police Pension Scheme which are set down in Legislation via the Home  Office.

IODPA would like to see evidence of where this proclaimed inconsistency lies. We believe there is no evidence. Dr Bulpitt chooses not to explain himself, and presents as fact something which is wide open to critical challenge. We believe that the current GMC guidance is based on a careful and rational analysis of the Regulations and of relevant court cases which have addressed the issues of confidentiality and consent in respect of reports commissioned by employers and pension scheme managers.

We have witnessed too many instances of reports written by SMPs which contained factual inaccuracies, incorrect application of the Regulations, and which exceeded the limitations of the brief of the SMP to see very readily why Dr Bulpitt wants these reports to be winged direct to the commissioning authority without scrutiny.

He fears that injury on duty pensioners have finally become aware that their rights under the law, and under GMC’s guidance, have consistently and widely been denied. He fears that a high percentage of reports will be subjected to withdrawal of consent and will not land on the desks of HR managers. His ambition to manipulate the Regulations so as to effect reductions of pension payments would be thwarted.

His letter to the GMC exposes very clearly that this doctor has only the wishes of his paymasters in mind, and cares nothing about the health and well being of disabled former police officers, nor cares anything for their right to continue to receive the level of pension their injuries deserve.

Current GMC guidance requires that the patient is offered a copy of the OHP’s report about  them before it is sent. Many Drs consider that the guidance leaves ambiguous whether the  patient is then able to withdraw consent at that point and thus prevent release of the report  to whoever commissioned it.

We would like to request that the GMC consider an additional section in future guidance
advising Drs and patients specifically for situations where health assessments are requested  by third parties from specialist OHPs and which particularly recognises the impartial role of  OHPs making clinical assessments generally and especially in
The context of Health and Safety Legislation.
• When instructed in accordance with the terms of insurance typically in a Pension
• When instructed under Regulations set down under legislation e.g. by Home Office

In their reply the GMC calmly proclaims that Dr Bulpitt’s grotequese bus tragedy analogy is already covered by the guidance and the exception Dr Bulpitt demands is given short-shrift.

Our understanding is that patients are entitled to withdraw consent for a  report to be disclosed to a third party unless there is legal requirement to disclose the information, or disclosure can  be justified in the public interest (for example, because failure to disclose the information could leave others at a  risk of death or serious harm).

So what can the ALAMA learn about the Alamo?

After he defeated the rebels at the Battle of the Alamo, President General Santa Anna unwisely divided his forces, allowing Sam Houston to surprise him at the Battle of San Jacinto.  Santa Anna was captured and forced to negotiate with the Mexican government for recognition of Texas’ independence and sign papers saying he recognised the Republic of Texas. He returned to Mexico in disgrace and retired to his hacienda. The people of Texas fought on for freedom and, eventually, on December 29, 1845, Congress admitted Texas to the U.S. as a constituent state of the Union.

Perhaps members of ALAMA will think it wise to consider how this particular representative is behaving and see fit to distance themselves from his lobbying techniques. The majority of conscientious and hard-working occupational clinicians do not deserve to have their ethics sullied by the machinations of one doctor.

One of Crockett’s sayings, which were published in almanacs between 1835 and 1856, was: ‘Always be sure you are right, then go ahead’

Every time we observe the lengths some twisted minds go to subvert the rights of others, IODPA is reinforced that we are right to keep going ahead.

The Dr Bulpitt Files

The Dr Bulpitt Files

Please Home Office? Change the Law for us


… its crazy us doctors have to treat them as patients

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The Doctor who walks away with patient medical records


Not only does he walk away with them, he names the patients the case files belong to and then Avon & Somerset police release the names…

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I think we have overdone it


An admission that the conveyor belt of reviews is starting to fray.

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Dr Bulpitt realises only A&S, Merseyside and Notts are engaged in a mass review programs


One of the ‘select’ few.  Dr Bulpitt fakes surprise, making reference to Cambridgeshire.  A force he was FMA during a particularly nasty bulk review program.

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Ready to “invite” people in


Everyone will be sent for interrogation…  Disabled former officers were told that they will only have to see a SMP only if their circumstances required…

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Avon & Somerset HR admit to a difference between NAMF publications and what they tell pensioners


An admission that they are using NAMF guidance, but they are not giving the same answers to FOI requests

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Dr Bulpitt discusses entitlement to an injury award based on a fire service court decision


But this is a mass review program isn’t it?  They are not allowed to revisit causation or entitlement!

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Shall we tell NARPO?


… oh, go on then.  Why is this a question? those affected should be told everything by default.

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They know the score


Doctors Johnson and Bulpitt discuss that being forceful and direct is the key as the disabled officers know the ‘score’.  These are vulnerable and disabled former…

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Let’s give the PCC finance officer some medical case files


…  but we might have put a label over the name.  The PCC finance officer has no right to have anything to do with medical files…

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It’s all about the money and how much we can save


A dcotor engaging with a finance officer.  Who’da thunk it!

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Ducks are lining up!


Disabled former police officers are painted as ‘targets’

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Bulpitt says to the SMP “you’re the boss”. Both say don’t believe their GP. They will conceal.


“We are one mind” they say.  General practitioners will conceal, so why not demand full notes from birth as there will be apportionment and causation there….

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Dr Bulpitt discusses permanency with the SMP


Again, there is a wilful failure to understand that revisiting permanency is unlawful

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Not just a SMP, but “Our” SMP


Strangely, Dr Johnson hadn’t actually start to work for Avon & Somerset yet (he started June 24th 2014 apparently)  …  And Dr Bulpitt even has…

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“Who do I send to invoice to, Dr Bulpitt?”, Says Dr Johnson


One question of many is why is the force medical officer talking about invoices and payment.  The friendship with the SMP is a cosy one.

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Local Fed approval? You got it.


Instead of stopping the train, the Fed welfare officer threw coals into the furnace to make it go faster.

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We know what to do. There will be an awful lot of appeals


Although a decade of unlawful guidance has been overturned and hundreds of lives ruined, Dr Bulpitt is still willing to put people through the trauma…

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Let’s invent new Police Injury Benefit Regulations 2014


There was no Regulations published in 2014.  In 2015, Regulations were published to bring in the new police pension scheme but there was no amendments to…

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“Preposterous” Awards

“Preposterous” Awards

“Of all the preposterous assumptions of humanity over humanity, nothing exceeds most of the criticisms made on the habits of the poor by the well-housed, well- warmed, and well-fed.”― Herman Melville

Were Melville commenting today, he might well have had disabled former officers in mind as the ‘poor’ and the Force Medical Adviser of Avon and Somerset Constabulary as their well-warmed and well-fed critic.  In Moby Dick, Melville frequently uses biblical and mythological allusions.  Like the Biblical Ahab, in Melville’s Ahab (and our well-fed critic) there is a desire for something that he isn’t entitled to and that isn’t good for him to have, to try to get it by foul means, and then to get his comeuppance in the form of an ironic reversal of his own evil deed.

Although not all injured-on-duty pensioners are in the dire straits of penury, they are all poor in respect of the way their injury pensions are administered. The habit of the pensioners is to be in constant bemusement over how those who have a duty to administer injury pensions within the law so easily, and so enthusiastically seek to pervert the meaning and intentions of the Regulations.

As we have repeatedly said on these pages, IODPA is not against reviews of degree of disablement. Chief Constables have a wide discretion on whether or not to conduct a regulation 37 review of degree of disablement. They can consider the matter at such intervals as may be appropriate. However, it is not appropriate to initiate a review as a potential cost saving measure.

Reviews can not be used to undo the finality of the last final decision even if a certain force medical officer considers the award to be “preposterous” (see below). We can only wonder just how he managed to come to that opinion. On what evidence did he base his consideration?

No matter what a FMA might think about any individual’s injury pension payment he surely must be aware that only a substantial alteration to the degree of disablement can permit a revision of the level of pension paid. Is the verdict of “preposterous” informed by a generalised assumption of some deficiency in the process of granting an injury award? The FMA must know that the causation and the substance of the award always remains final and can not be revisited at review.

We are writing here about not just any old FMA, but one Dr David Bulpitt MRCGP FFOM, who is the Force Medical Adviser of Avon and Somerset Constabulary. It is a telling reflection of the rather nasty and lawfully inaccurate attitudes prevalent in some quarters, that Dr Bulpitt appears to have an inflated ego of such magnitude that he wants to rewrite history and convert the decisions of his predecessors, into becoming his decisions.

Dr Bulpitt is not shy about voicing his rather skewed opinions on injury awards.  He is not even a run-of-the-mill force medical adviser.  He has a national platform – as the police representative for the Association of Local Authority Medical Advisers (ALAMA).  Listed as a speaker in past ALAMA conferences for Occupational Health physicians who are “set on delivering the highest quality services and the best standards in patient care in the most effective manner”, you’d have thought his words would always exemplify the motto of ALAMA: “communication, education, consistency and quality of clinical practice of doctors providing Occupational Health Services” .  Unfortunately for Dr Bulpitt, his words may well come back to haunt him.

As Will Rogers put it, “After eating an entire bull, a mountain lion felt so good he started roaring. He kept it up until a hunter came along and shot him. The moral: When you’re full of bull, keep your mouth shut.”

In an intemperate email rant to the Police Workforce & Capability Unit at the Home Office, Dr Bulpitt displays his frustration and impuissance.

It seems he might well be vexed over his inheritance of the historical legacy of decisions that he thinks ‘he’ would not have made, conveniently ignoring that such attempts at historical revisionism is forbidden by the Regulations.  An interesting stance, given Dr Bulpitt is not privy to the Zeitgeist and full facts which swayed the decisions of his predecessors.

His ego asks for more.  The finality demanded by the Regulations is an affront to his wishful view of how things should be if he were in charge, and he can’t control his craving to fuel his desire to remove the injury awards of those retired from the force he represents, sacrificing his medical professionalism and independence in the process.

Frustrated by his impotence to alter history, he contacted the Home Office to tell them how hard-done-by he his.


[…] I suspect that you might be aware that we have a group of pensioners that are organising a campaign to resist having their pension reviewed.

So blinded by his own peculiar view of the Regulations, Dr Bulpitt actually thinks that a group of disabled former officers, who in their working lives were intent on seeing that the law was upheld, are now campaigning against reviews, per se.  Dr Bulpitt not only has hold of the wrong end of the stick, he has the wrong stick altogether. We guess he is referring to IODPA. In which case, how has he missed the plainly, and oft-repeated, statement of our mission, which is to challenge all aspects of unlawful reviews and maladministration?

IODPA has never sought to frustrate legitimate, lawful review process, but, in Avon and Somerset, and elsewhere, finding a legitimate review is about as difficult as finding an honest, decent and professionally competent FMA or SMP  (difficult but not impossible – they do exist but the good ones tend to avoid the debacles and imbroglios that always shadow bulk review programs).

Dr Bulpitt’s email continues in a manner that, perhaps unintentionally for him, actually answers his question of why pensioners do not want their injury award reviewed by Dr Bulpitt or anyone connected to Dr Bulpitt.


The issue is largely one of the Constabularies making in my view because they are on preposterous awards, frequently 100% and have hardly ever been reviewed if at all. One appears  to never had anything wrong with them and another had a certificate stating they did not have a permanent condition but got an injury award anyway.

Who are the ‘they’ that Dr Bulpitt refers to? The group ‘resisting having their pensions reviewed’ are all medically retired former police officers unfortunate enough to be retired from Avon & Somerset and other forces across the country where the review process is clearly being managed contrary to the Regulations.

Among everything else wrong in his email, Dr Bulpitt has the nerve to call the deliberate unlawful actioning of recommendatory Home Office guidance that reduction to 0% of the degree of disablement all former police officers once reaching sixty-five years of age as, ‘acting in good faith’.  

Oh!  That’s OK then – it’s fine to carry out a public duty unlawfully as long as it is done in good faith.  It’s perfectly fine to make an almighty cock-up, so long as it was done in good faith. It is acceptable to drive a coach and horses through the Regulations, bringing huge distress to disabled former officers and their families, so long as it is done in good faith.

This may be arguable in a pursuit of proving misfeasance in public office, an intentional tort rooted in bad faith, but the tone of Bulpitt’s email shows his intent is as far a polar opposite to a ‘good faith’ mistake as is possible.  Dr Bulpitt’s unsolicited use of the term ‘good faith’ clearly shows he has the spectre of misfeasance in his mind; just saying it is all in good faith doesn’t make it so.

As sure as eggs are eggs, Dr Bulpitt wants to globally revise the award downwards of all those retired by Avon & Somerset.  If this isn’t bad-faith then what is?

Do you think Dr Bulpitt paused for a minute and thought, as he typed his email, that it’s no wonder that people don’t want to be unlawfully reduced just because he, as the current force medical officer with only the scantiest knowledge of the circumstances, thinks there is nothing wrong with them and they shouldn’t have the award in the first place?

Or perhaps he feels he has sufficient knowledge. If so, he has been trawling through sensitive personal medical data which he has no right to access. The implication from his remarks amounts to a self-admission that Dr Bulpitt freely rummages around in the personal sensitive medical records of former police officers without consent. If that is the case, it is shocking to say the least.  How else can he justify his generalisation that those retired in the past, ‘have nothing wrong with them’?

The bunker mentality seeps through the words of Dr Bulpitt.


Apart from a coordinated campaign of FOI  requests, subject access requests and so on, they have been put in complaints to the GMC about  our SMP. Not too dissimilar from the picture in many forces that I have worked with but this one  is far more venomous and a lot of work has gone into worrying pensioners and frankly trying to smear the OH unit and the SMP by the Pipin group

Hold on there, Doctor. It sounds like you are saying that all complaints, all requests for information, and every attempt by injury on duty pensioners to shine some light into the murky recesses of the shambles that is the administration of their injury pensions, is done to annoy and smear? What utter hogwash! What a frankly outrageous attitude to display by someone who is supposedly trained and skilled in the art of diagnosis. What an example of bias overcoming logic.

Doc, your diagnosis is wrong. YOU, and the other people who have not got a clue about how to properly administer police injury pensions, are the disease. IODPA is the cure. We challenge because we have been attacked. We seek information because none is freely given out. We point out deficiencies because nobody has the wit or the will to remedy them unless backed into a corner.

 It is people such as Dr Bulpitt and Dr Johnson, the SMP used by A&S, who are smearing the Occupational health unit. They are dragging the unit into disrepute by abusing the Regulations.  Uncovering the truth of what is really going on cannot be twisted into smear campaign.  Smear tactics differ from normal discourse or debate in that they do not bear upon the issues or arguments in question.  On this website you will only find disclosure and arguments that always bear upon the focus of unlawful administration of injury awards.

The unguarded admission by Dr Bulpitt is another example in a long line of examples of how far some public officials will go in attempting  to undermine legislation.

Frustrated that Avon & Somerset legal services advise that it is unlawful to reduce an injury pension banding where an IOD pensioner disagrees with the SMP’s report and withdraws consent for it to be disclosed to the police pension authority, Dr Bulpitt states that he is at a ‘crunch point’.

Prevented by the GMC to force the release of a report that a SMP makes on an individual and unable to revise an award without it, his considered reaction is to ask the Home Office to change the law for him to provide immunity for SMPs from oversight by the GMC.


I know that others have written about this but surely it is crazy to have the GMC overseeing the work to the SMP and insisting that the pensioner is our patient and that we must put their  interests first?

Their insistence that we have to offer to share our report with the pensioner/applicant first is very difficult and potentially will prevent the review  of pensions if, as my legal department tells me, we cannot alter the pension without that report  and the pension authority cannot insist on it being released. They (the GMC) are adamant that  we must put the pensioner first and if that means not adjusting a pension to the correct level  then so be it.  My concern is also that this is getting so unpleasant for doctors we are getting very limited in our  selection of SMPs. FMAs are now very rarely employed and tend to turnover very quickly.

We cannot alter the pension without that report”.  Rather a conspicuously revealing and graphic sentence.  He uses the accusation of a conspiracy to save money in a dismissive throwaway comment concerning a pensioner who was unlawfully reduced in – cough! – ‘good faith’ three years ago.


[redacted] is being investigated over a decision [redacted] took 3 years ago when [redacted] had been instructed to review a pensioner who had reached the age of 65 and drop their award (we now know that is incorrect of course but [redacted] acted in good faith at the time). [redacted] contacted the GMC but has been frustrated by the apparent lack of any understanding of the role. The pensioner had his pension restored at appeal but has now gone on a crusade, accusing [redacted ] of “colluding with the pension authority to save money”.

But “we” (not the independent and supposedly impartial SMP) want to alter the “preposterous” award, he says!

You can make your own mind-up whether Dr Bulpitt is seemingly in cahoots with others.  The use of “we” in the above context goes nowhere in quashing any suspicion that the SMP is not totally his own man and the goal is to alter the pension in all circumstances.  You don’t need to be a clairvoyant to predict the direction of the desired alteration.

The Faculty of Occupation Medicine, of which Dr Bulpitt holds the FFOM post-nominal, has a ‘Competency 4‘ that governs the relationship between the occupational health doctor and the patient.

The absence of the usual therapeutic relationship between patient and doctor does not exempt the doctor from his/her professional duties imposed on all members of the profession..

Dr Bulpitt appears adamant that this should not apply to some members of the public and it seems he thinks that the required doctor-patient relationship is absurd.


surely it is crazy to have the GMC overseeing the work to the SMP and insisting that the pensioner is our patient and that we must put their interests first

The role is described as quasi-judicial but I see  little that is “quasi” about it. Surely it is not a doctor-patient relationship as we would understand

They (the GMC) are adamant that we must put the pensioner first and if that means not adjusting a pension to the correct level then so be it.

But it is not just the demands of the GMC, is it?  To be a FMA or a SMP the National Attendance Management Forum demands a prerequisite of membership of the Faculty of Occupational Medicine.  It is Dr Bulpitt’s own specialty designated body that demands the same compliance.

Given the Regulations are paramount and the Home Office refuses to release any central guidance in relation to injury awards, Dr Bulpitt continues forlornly, with a sigh of desperation and acknowledgement that some forces refuse to review contrary to the Regulations.


Can anything be done about this because we are in danger of the whole thing grinding to a halt?
So far as I know the Met are still not carrying out any reviews and have stated publicly that they  will not be doing so.

The Home Office sensibly skirts over the rant and calmly explains to Dr Bulpitt that the Regulations require a medical authority and the GMC therefore have primacy over the behaviour of any medical professional.


Hi David,
Thank you for your email. Whilst I understand your concerns and appreciate your comments it remains that as SMPs do fall within the remit of the GMC. You said that the GMC have been contacted to explain this issue but that the GMC do not seem to be understanding the role. Have any further attempts been made with the GMC to explain the role in further detail?
The Regulations state that the SMPs are being asked for a medical opinion and the fact that they sit under the remit of the GMC is something that cannot just be overridden through amendments to our legislation. It would be interesting to know more about the discussions which have been had with the GMC regarding this issue.
Kind Regards

Dr Bulpitt, and others with similar mindset, appear to have a clear appreciation or understanding of the laws that regulate their conduct in this area, but still they do their utmost to get around them.  When challenged, as we have so often witnessed in instances of other outrageous maladministration by public officials, they consistently fail to acknowledge that they have done anything wrong.


We are lucky here because our GMC liaison officer is very understanding and I took the  precaution of warning him that he would start seeing complaints. Thus far the GMC has not felt  any of the complaints against our SMP warranted investigation.  This has not necessarily been the case elsewhere

It is worrisome that Dr Bulpitt has apparently arranged an ‘understanding’ with the local GMC liaison officer.  Does this mean any complaint of wrongdoing is dismissed by the GMC responsible officer, regardless of the strengths and merits of the complaint?

Dr David Bulpitt’s position as Force Medical Officer has, we believe, become untenable with these shockingly offensive comments. He has demonised the entire population of disabled former officers who have injury awards, and his comments show extremely poor judgment and a surprising lack of sensitivity.

It is important that a doctor in a position of trust who is dealing with injured police officers and medically retired former officers enjoys public confidence and this is at risk with his continuing in the important role of Force Medical Officer.

We are so appalled at this insight into the recesses of the mind of Dr Bulpitt, and are so concerned about the bias and discriminatory attitudes which are revealed that we call for Dr Bulpitt to either resign quietly, or if he will not, for him to be dismissed.

If Avon and Somerset wishes to see a return to normalcy in its relationship with injury on duty pensioners and the emergence of good governance of police injury pensions, then this stumbling block named Bulpitt must go.

This is the full email chain.  Keep in mind if this is what Bulpitt sees as a measured email to the Home Office, what is he saying and doing in the privacy of his own office?


38800 Annex
[hover the cursor over the page to read all 4 pages or to download pdf]

Shocking Revelations from Force Doctor on Injured Officers

Shocking Revelations from Force Doctor on Injured Officers

Breaking News …

The following emails, released by the Home Office (from a Freedom Of Information request), are between Dr David Bulpitt of Avon and Somerset police and the Home Office. They reveal an insight into his thoughts regarding injured officers. 


ho bulpitt


This doctor is from the same force as the PCC (Sue Mountstevens) who wrote a letter three years ago, again to the Home Office, complaining that retired injured on duty police officers serve no benefit to the people of Avon and Somerset.

We are deeply concerned and horrified that a doctor who, according to the GMC good medical practice, should show respect, treat patients and colleagues fairly and without discrimination and act with honesty and integrity, could write something with such disregard about his patients – who happen to be injured police officers.


it is crazy to have the GMC overseeing the work to the SMP and insisting that the pensioner is our patient and that we must put their interests first?

IODPA are alarmed that a person who is a highly qualified doctor and whom is employed by a police force to take care of the physical and mental health of serving and retired police officers should have such a blatant indifference to his patients.

In our belief he has shown no concern for people who have been medically retired; their lives, physical, psychological, emotional, and social state are cruely dismissed.  

By intentionally dehumanising individuals his paramount fealty seems to be to the force finances.  

An opinion piece on this will follow soon.

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