What they know …

What they know …

Do you know what is in your occupational health?  Could there be a memo. a letter or some handwritten notes that show that the force did not act within their lawful duty when they made the decision to retire you?

It is foolhardy to attend a review they have instigated upon you without knowing what information they have on you beforehand.  A Subject Access Request (SAR) under the Data Protection Act is a method to get full disclosure of personnel records and occupational health files and should be the first action if ever called to a review of your injury on  duty award

Once submitted with a form of identification (such as a photocopy of a passport)  and a £10 cheque, you should receive within 40 days the required information. Then you will not be entering the process blind.  Indeed there may be something within the file that indicates that any previous decisions were unsound.

A template letter can be found here:

There is nothing stopping you from putting in a SAR once notified they are starting a review process and then another SAR once the review has completed.  The second request should specify all handwritten notes made by SMP during the assessment.

You might also discover that they have destroyed your personnel file under some internal  retention policy.  If so it can be argued how they are going to compare your skill set when they have no record of what skills you gained during your service.

Pension Ombudsman

Pension Ombudsman

When your injury pension has been abused by maladministration you need to know two things.

How to recognise maladministration and who can put things right.

Let’s look at what maladministration is and how we can recognise it. This Google search clarifies how many times the Pensions Ombudsman has had to make determinations against police pension authorities specifically concerning injury awards:

Given the relatively small number in receipt of an injury award, the number of results is mind boggling and it demonstrates the simple fact that police pension authorities are not competent custodians of our injury awards. Remember these are only those that have complained – many, many more are too ill, elderly or restricted by the injuries to pursue a complaint. There are also a number of decisions not returned by the search link, in other words, this result is just the tip of the iceberg.

Maladministration covers the following:

  • Delay
  • Incorrect action or failure to take any action
  • Failure to follow procedures or the law
  • Failure to provide information
  • Inadequate record-keeping
  • Failure to investigate
  • Failure to reply
  • Misleading or inaccurate statements
  • Inadequate liaison
  • Inadequate consultation
  • Broken promises

One thing to be mindful of is that so far as police injury pensions are concerned, it seems to be the case that little will result from any form of challenge or complaint unless the maladministration has resulted in what is termed an unremedied injustice. In other words, unless you have lost out financially, then forget about the Pensions Ombudsman.

Instead make a formal complaint against the individual or individuals concerned. Again, probably not much will result, as Chief Constables have a highly-tuned sense of self preservation and will never willingly admit that they, or anyone else has ever done anything wrong. The point is, to make the complaint and get it on record.

If you have good reason to believe your injury pension is being paid at less a rate than the circumstances would seem to dictate, or that the SMP or HR have done you over by mangling the Regulations, then please do something about it. You don’t necessarily need a solicitor, or extensive knowledge of the case law concerning injury pensions, but you do need to make yourself familiar with something which your police pension authority may well not be open about.

Hands up all those who have heard of an Internal Dispute Resolution Procedure?


Before accepting assurances from HR that if you are dissatisfied with any decision made about your injury pension you can appeal to a Police Medical Appeal Board – a daunting prospect – ask them to tell you all about the force’s IDRP.

Every pension scheme has to have an IDRP system built in to enable members of that scheme to complain about matters concerning the administration of their pension (section 50 of the Pensions Act 1995). Injury awards are no exception.

An IDRP can be a one or two part process. One part may settle the matter, but if not on it goes to part two. Be very aware though that the ‘I’ in IDRP does not stand for Independent. In part one a senior person is asked to consider your submission. If there is no resolution, then someone else is appointed to take a look. That person may be another force employee, or, more often will be someone with no close connection to the force who is deemed to have some relevant expertise. We have no data on how many IDRPs produce an acceptable solution at either stage. The process can take several months.

But if you don’t initiate an IDRP you will find that the Pensions Ombudsman – who is the person who can really do something about maladministration – will not be able to accept your complaint. He likes to see himself as a mediator, a settler of differences, and an arbiter of the law. He wants to see the parties to a dispute make efforts to resolve it before he is asked to get involved.

From anecdotal evidence we believe that more often than not a police pension authority does nothing positive to resolve a dispute or deal with a complaint on the stage one and stage two parts of the dispute. We know that quite often they have no idea what an IDRP is and thus the complainant may be faced with glib meaningless waffle or, after an interminable wait, will have to conclude the file is lost in the bowels of bureaucracy.

Bear with it. There is a time limit. OK, it is only a guideline, but if you have faced unreasonable delay with no conclusion, the PO will look kindly on you and accept your complaint.

It is worth mentioning here that an IDRP, as a route to the PO, is often the only avenue of redress open. There are stricter time limits on when an appeal to a PMAB should be made, and also with taking matters to the Administrative Court for judicial review. One avenue does remain open, without limit of time, and that is a ‘reconsideration’ of a decision, under regulation 32-(2) of the Police (Injury Benefits) Regulations 2006. Of which route, more in another article.

If you are not satisfied with the result of an IDRP, then it can be useful to speak to The Pension Advisory Service. Once you have hit a brick wall with attempts to get matters resolved TPAS should be able give you advice on how to raise the matter to the Pension Ombudsman for a decision.

The Pension Ombudsman has made some very useful, helpful, decisions on injury pension issues in recent years. If you can get your complaint on his desk for investigation, and you have a good case, set out well, then in all probability you will have the pleasure of seeing him tell your PPA to put things right.

Regulation 12

Regulation 12

The word ‘secret’ on the blog featured picture is conveniently obscured by the text.. This works as a good analogy with explaining regulation 12:

If, within 12 months of an injury on duty, you are totally and permanently disabled so that you are unable to earn any money in any employment, you will be entitled to a disablement gratuity under the provisions of the Police (Injury Benefit) Regulations. • The gratuity is the lesser of (a) five times the annual rate of your pensionable pay on the last day of service or (b) four times your total remuneration during the 12 months ending with the last day of service together with your total pension contributions. • The gratuity is reduced by the amount of any other gratuity payable under the Police Pensions Regulations and takes account of damages or compensation recovered in respect of the disability.

Up to 5 times the last pensionable pay.  Quite a substantial monetary figure.

This gratuity is provided under regulation 12 and is rarely known about.  The permanently disability isn’t physical disability, it is the disability of earning capacity and therefore includes the mind as well as the body.  It is the total inability to earn.

The scandal is that it is never given.  People given a 100% band 4 are never told about it by the federation.  Those that do find out about are often told they have passed the 12 months and therefore not eligible.  Those that apply within the 12 months are told that their 100% disablement of earning capacity is not permanent and so aren’t eligible.

Do you see the paradox?  An award of a lump sum gratuity is never given due the hurdles put in place – the police pension authority use a circular argument to deny its application and the federation neglects to inform its members of it and to fight for it on their behalf.  There are hundreds of IOD award recipients retired on 100% band 4 awards that should have had the regulation 12 gratuity but were deliberately misled about their entitlement to it.

The permanence can not argued as that it is a defining criteria of an injury on duty award (under regulation 30) BEFORE the degree of disablement is calculated.  If the degree of disablement is 100% then the IOD recipient has total disability of earning capacity.  Therefore the gratuity should be given automatically  – why should the onus be on a claimant to claim given they are suffering a debilitation that amounts to them being totally disabled from earning due to the injury they received in the execution of their duty.

Given that conjecture is prevented as there is a power to review under regulation 37 the decision of entitlement to the gratuity should be given in the here and now.  There is no remit to speculate about an improvement – if the 100% remains for 12 months post retirement regulation 12 is applicable.  If someone has been a band 4 for years, missed the 12 month window due to maladministration and has never been able to have any earning capacity then regulation 32 may be used to reconsider the entitlement to a regulation 12 gratuity.

Regulation 32

Regulation 32

Everyone in receipt of an Injury on Duty award mostly understands the implications of the discretionary power to review, namely regulation 37.   As described previously on other posts it is frequently an abused power with reviews instigated by the police pension authority, on their whim, so that they can fulfil financial constraint reduction targets.   Rarely does a pensioner with a substantial deterioration in their medical condition request a review themselves – Avon & Somerset has only received 2 self-referred requests for a regulation 37 review in the past 10 years.

The same story is repeated nationally. Too many IODs are living their lives with degenerative conditions brought on by their qualifying injury received in the execution of their duty without wanting to resurrect the pain of dealing with their former force’s bureaucracy.  So they continue on, living on an award banding lower than what they should be entitled to.  The point I’m clumsily trying to make is that if no IOD recipient thinks of requesting a review, it is not surprising to hear that no one knows that there is a power to ask for a reconsideration.

Regulation 32 became more widely known as a direct result of the the unlawfulness of home office circular 46/2004.  Between 2003 and 2009 hundreds of reviews were used to reduce former police officers to the lowest band due to the fact that they had reached the age of 65.  Despite the hardship this caused only a few had the mental strength to appeal and it wasn’t until the first Judicial review in 2009 that the light was shined on the illegality of what had happened.  By then those affected had missed the strict deadlines to lodge appeals.

The case of Haworth explains this clearly.  This was Northumbria again on their mission to ruin lives, guided in their quest by their legal advisor Mr Wirz.  Susan Haworth was retired on an injury on duty award and medical pension in 1995.  In 2005 she was reviewed and had her injury award reduced.  The decision was taken to the police medical appeals board (hearing in 2006) whereupon the board further reduced the award to the lowest band, a band 1.  Both the SMP in 2005 and the board in 2006 revisited causation and unlawfully attempted to claim that Susan had pre-existing conditions and then applied apportionment.  This was not permissible and was outside the task which they had to undertake under regulation 37.  Susan did not take the fight further (she was unaware she could challenge it at the time) until she realised several years later, after Laws V PMAB in 2009, that the decision made against her was unjust.  So in 2010 she sought advice and submitted a request for the 2006 decision to be reconsidered under regulation 32.

Here is an excerpt of the letter from her solicitor requesting the reconsideration:

‘It is against the background of the decisions of the SMP and the PMAB that Mrs Haworth is seeking a reconsideration under Regulation 32(2) of the Police (Injury Benefit) Regulations 2006. The detailed reasons for seeking this review (sic) are set out below, however in essence the decisions of both the SMP and the PMAB were not made in accordance with the relevant regulations , as it is clear that the SMP…..revisited causation as to the original final decision made at the time of Mrs Haworth’s ill heath retirement in May 1995, and the,PMAB ….then proceeded to apply an apportionment, again to a final decision made in May 1995. Both of these decisions are therefore unlawful, and not made accordance with the Injury Benefit Regulations.”

Typically and acting to type, Northumbria refused the reconsideration.  The refusal was taken to judicial review and Haworth won the right to have a her case heard under regulation 32.

The importance of Haworth is not only that it brought to light that a police pension authority needs a robust reason to refuse a request for a reconsideration – more than Northumbria’s claim of “It is important that final decisions, once taken, remain just that” and that Mr Wirz’s submission to the court that ‘re-opening of old-cases will affect the authorities budget’ is irrelevant to the matter at hand .  But also that there is no time limit to restrict the use of regulation 32:

I cannot accept that it is lawfully open to a police authority to refuse a retired officer its consent to refer a final decision back to a medical authority for reconsideration under regulation 32(2) simply on the grounds of delay, even inordinate delay, in other words passage of time since the decision was made, without any consideration of the underlying merits of the matters which the former officer seeks to pursue on such a consideration”.

The power to demand a reconsideration is therefore unfettered by time and is always available as a viable option.

So what advantage does a reconsideration (reg32) have over a review (reg37)?   If a review (or the original decision that the review is based upon) is using the wrong diagnosis, if there is undue apportionment, if causation is incorrect, if a previous final decision was contrary to regulations; a further review can not fix the fault.  That fault will remain now and in future reviews for eternity – the comparator always is the last final decision whether or not that final decision was wrong. A review is blind to the legitimacy of the last decision.   So the only way to wipe the slate clean and have future reviews looking at the correct factors is to have the previous decision(s) quashed and regulation 32 provides a mechanism for this to happen.

Regulation 37

Regulation 37

The ‘positive duty to review’ and the weapon to ‘protect the public purse’

There’s an introduction to regulation 37 here on the ‘The Regs – and what they mean to you’ page.

It’s quite difficult to explain what is meant by earning capacity and how this is the measure of the degree of disablement.  It’s even harder to convince people that the regs do not directly correlate ‘physical disability’ to its meaning of ‘degree of disablement’.

A problem is that reg37 is silent on the detail on how individual forces shall measure the loss of earning capacity.  It has quite simply stated the banding of slight, minor, major and severe is enough instruction, but just like mankind has a tendency to do, something simple has be turned into something complicated.  The complication is the ‘guidance’ that police forces use in an effort to justify their defiled view of what it is to ‘protect’ the  public purse.

The thing is that to be given an IOD award, a high bar has already been passed.  There are 4 levels of attainment to qualify:

(a)whether the person concerned is disabled;

(b)whether the disablement is likely to be permanent,

(c)whether the disablement is the result of an injury received in the execution of duty, and

(d) the degree of the person’s disablement;

If a former officer has an IOD and ALL of the above wasn’t satisfied (retired off, wink, wink, nudge, nudge…) then that says more about the force that did it than the former officer it was done to.

In reality an injured serving officer lives a  hell once injured.  Treated like a malingerer, put on surveillance, reduced to half pay.  The full weight of bureaucracy is put against them and that injured person has to prove everything – permanence, whether the injury was on duty, whether it was in the execution of their duty and all the rest.  An award may be begrudgingly given.  More than likely a civil claim against the force is ongoing as well as the ‘injury in the execution of their duty’ was down to poor management, being single crewed, having defective equipment. Once gone the retired officer has to justify his or her level of loss of earning capacity when they apply for an award so another fight with the HR department starts.

Now retired, the former officer wants to live their life in peace often with a deep resentment of how they were treated.  But every 2 years a letter pops through their postbox calling them to attend a review of their degree of disablement as the police force claims they have to protect the public purse under regulation 37. The insinuation is that the award is something you have to prove for life.  Not much of an award is it?

It’s no wonder that those retired on the lowest tier, a band 1, who’s condition and earning capacity deteriorates rarely if ever ask for a review.  They haven’t the strength.  It can be said that that are more IOD retirees with a banding lower than is strictly appropriate than a banding higher. But that’s the nature of beast – the SMP gives a subjective figure using his qualified medical judgement. If and when circumstances dictate on review here has been substantial change, in other words an substantial improvement or a substantial deterioration, then a revision is permissible, down a band or up a band respectively.  Retrospective attempts at cost-saving redress by HR and Finance teams because they think in hindsight the original banding wasn’t the right one is unlawful as much as it is it impossible.  The award was given at the Zeitgeist of the original decision and if there is notable substantial alteration it is a SMP alone that performs the revision; not for HR departments to interfere and influence the SMP or to attempt to rewrite history.

Case-law deals with the finality of the banding: Laws Appeal 2010

The result is to provide a high level of certainty in the assessment of police injury pensions. It is not open to the SMP/Board to reduce a pension on a Regulation 37(1) review by virtue of a conclusion that the clinical basis of an earlier assessment was wrong. Equally, of course, they may not increase a pension by reference to such a conclusion; and it is right to note that Mr Butler, appearing for the Board, voiced his client’s concern that so confined an approach to earlier clinical findings might in some cases work to the disadvantage of police pensioners

Imagine a person with PTSD and severe mental illness.  A constant review program will lead the person to being sectioned under the mental health act.  Military veterans aren’t treated with this level of disrespect so why are retired former police officers?

Why all the hullabaloo about IOD reviews?

Why all the hullabaloo about IOD reviews?

Injury on Duty Awards used to come out of central government funds but that changed in the early ‘noughties and the awards became payable out of the individual force’s budget.  But the Home Office threw a sop to the forces – now obligated to pay for their decisions they made to retire former officers.  Their redress was new Home Office Guidance – Home Office Circular (HOC) 46/2004

The problem is that although the Regulations are unchanged, many Police Authorities ( probably slightly less than half of the authorities in England and Wales) changed their policy following the issue of the guidance in HOC 46/2004 and introduced reviews triggered when the retired officer reaches the ages of 60 and 65. Although this guidance and policies based on it have been declared unlawful and withdrawn, forces are still attempting to find ways to reduce IOD bands in order to make budget savings. Existing injury pensions which may or may not have been subject to review previously were now reviewed under the new guidance which, in some forces was pursued aggressively.

HOC 46/2004 was unlawful and challenged – not directly at first – there was a blow-back and the new aggressive stance by Police Pension Authorities was used on other former officers, of all ages, in receipt of IOD awards.  Turner V PMAB and Laws V PMAB were case-law decided as a direct result of 46/2004 even though neither of the appellants were 65 years old.  This circular corrupted the administration of ALL IOD awards and the whole thing came down to ways the police pension authority can save money.  Lets not forget who had to challenge the unlawful guidance – incapacitated and disabled former police officers.

Turner and Laws were successful on points of law.  After that the guidance itself contained within HOC 46/2004 was challenged both by  judicial review (Crudace, Simpson etc)  and by the pension ombudsman (Ayers, Sharp etc) and the guidance was declared unlawful in 2013 in the consent order Slater V PMAB and officially withdrawn.

But the Rubicon had been crossed and the police pension authorities had tasted blood.  In the days of austerity how better for a high-flying Chief Finance Officer (CFO) to mark their career by making instant savings into their budget. If they can save ££££ then their CV and LinkedIn would be flowered up and then a new role with  an inflated 6 figure salary plus bonus will be within their grasp.  Like a plague of locusts, using the budget reduction as evidence, the CFOs think they can move onto a new force to decimate and corrupt the administration of IOD awards there as well.

Did the Home Office and police pension authorities accept they were wrong?  No.  The guidance was withdrawn and the Home Office and those forces that pursued 46/2004 maliciously had their fingers burnt.  Out of the ashes the National Attendance Management Forum (NAMF) was born.  A coven of HR and finance managers who meetup at Tally Ho! Conference Centre Birmingham. The cynically minded might view this organisation as an attempt to further undermine the regulations with an attempt to keep  keeping the sphere of influence separate so the Home Office doesn’t get the blame.

There will be further posts all about NAMF.

PEAM and Bad Maths

PEAM and Bad Maths

PEAM (Police Earnings Assessment Matrix)

“The Police Earnings Assessment Matrix (PEAM) was independently developed by Grantwood Consulting to enable the force to arrive at fair, reasonable and defensible assessments of the earnings potential of Police Officers. PEAM’s underlying principle is that there are a number of generic job levels in the police, public sector and the wider job market. The job levels enable:  The size of jobs to be assessed, particularly jobs in different functions or disciplines.  Base salary levels for a number of different market sectors or geographies. The job levels allow police officer positions to be compared with jobs of comparable size or weight in the public sector, private sector or police support staff populations. PEAM therefore combines best practice from both outside and within the police sector. It has also been tested to ensure compliance with equal opportunities requirements.”

Why is this bad maths.  Well its contrary to regulations for a start.  The regulations are quite simple and split the degree of disablement of earning capacity into 4 bands: slight, minor, major and severe:

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%

What the PEAM manages to do is turn a % given by a medically qualified selected practitioner  into another lesser % used by HR for the award.  For example, 75% (major and band 3) once put into the Police Earnings Assessment Matrix can be magically distorted into a minor band 1.  Basically PEAM is a device that is used to reduced an IOD banding into its lowest factor.  This fallacy was spotted in a Senior Counsel review of Injury on Duty Awards commissioned by the Northern Ireland Policing Board where Mr David Schofield QC stated in section 1.35

“I also recommend that, in the course of such a further review of Northern Ireland specific policy guidance in this area, serious consideration should be given to abandoning the currently recommended method of calculating percentage disablement, including detailed reliance on the ASHE survey and comparison with the officer’s notional uninjured police salary, in favour of a much more basic approach, whereby the relevant medical authority would simply make a judgment in the round as to the severity of the impact of the duty injury on the officer’s earning capacity, so as to select the officer’s appropriate band without the need to calculate a specific percentage disablement figure”.


In other words the injured former officer should be placed in band 1,2 3 or 4 based on a judgement ‘in the round’.  The regulations do not allow for inclusion of any manipulation by use of an invented earning matrix therefore this PEAM device has no de jure.

So the use of PEAM (or any convoluted matrix) is unlawful.  PEAM and other methods involving wage comparison resulting in a figure which purports to reflect future loss of earnings. An injury pension is paid as compensation for loss of the capacity to work, and the Regulations are blind as to how much or how little an individual might be earning, or be capable of earning.

The SMP (selected medical practitioner) is not permitted to look to the future when deciding degree of disablement. He must make his decision on the medical evidence at the time he makes that decision. The wording of the Regulations is,

‘Where it is necessary to determine the degree of a person’s disablement it shall be determined by reference to the degree to which his earning capacity has been affected as a result of an injury received without his own default in the execution of his duty as a member of a police force.’

Note, ‘has been’ not ‘will be’.

Note also, ‘capacity’ not ‘earnings’.

The SMP must make a decision in the here and now, and should relevant circumstances alter substantially in future, then the Regulations allow for a police pension authority to review the degree of disablement and revise the amount of pension paid.

Finance Managers gone Rogue part 1

Finance Managers gone Rogue part 1

The delegated Administrator for Police pensions according to Avon & Somerset’s Joint Scheme of Governance is named as the HR Director.  The HR Director resigned suddenly in May 2014.  In mid-May 2014 the Chief Constable was suspended by Commissioner Mountstevens following allegations of ‘inappropriate behaviour towards female officers and staff’.  In this organisational maelstrom, the Finance Director took on the extra duties of the HR Director in a grandly sounding re-badged dual role now called the Director of Resources.

But the authority of delegation ( the Chief Constable is the Police Pensions Authority but he is able to delegate the administration to a named other) wasn’t signed until September 2014 and with a clumsy attempt to back-date it by 3 months.  So who was steering the ship and allowed the reviews to start?  …

Letter from John Long to Julian Kern

It wasn’t on the say so of the PCC’s finance officer was it?  Nah, that’ll be just plain wrong … reviews of IOD awards should surely be solely a medical question under suitable intervals relevant to the individual.  Not because the force is broke, penniless, without means, on the’ bones of yer arse’, etc etc.

HR gone rogue Part 1

HR gone rogue Part 1

Serve as a police officer and you are treated as number, as a ‘human resource’ not as a person.  If you are retired on an IOD award then you become an ex-number that still costs them … and the HR departments will try to collect the pound of flesh as to balance the books of their Director of Resources. Like Portia said to Shylock – you can’t take what you aren’t lawfully allowed to take. Poor metaphor, sorry – can I qualify it by claiming the blood Shylock isn’t allowed to draw is the same as the case-law and police regulations they aren’t allowed to contravene? No? .. I’ll get my coat.

Rhetorical question, but why are IOD awards administered by HR departments ?

When HR has the same director as the Head of Finance then chaos shall reign …  To misquote Jessy J – “It’s all about the money, money, money”


“Pension and retirement costs are significantly overspent due to the large
number of medical retirements; 26 cases to date with a possible further 27
cases identified by the Human Resources department. This overspend will be
funded through Reserves and the number budgeted for within the 13/14
budget remains at 12 cases”.

08/07/2013 Email from HR Director  FOI 1102 email

Edit note: (Why have case-law when you can try to ask the Home Secretary to revoke it !  And they subsequently denied that there is a ‘HR v2’ – the version that needed ‘damping down’)


“The PCC’s attention was also drawn to the Injury on Duty Payment which is a recurring payment for someone who is medically retired but was injured whilst on duty (this includes the commuting journey). This is payable every year until death and currently accounts for £5.6m of the central pay budget (half). The Head of Retained Finance has raised this issue with Winsor following the Winsor Review, which did not pick this issue up, and the Constabulary suggests that consideration should be given to this ceasing at national retirement age. The PCC will write to Winsor to raise this issue again. […]

  1. Finance should consider managing medical retirements through a reserve rather than budgeting for it.
  1. The PCC will write to Winsor regarding the issue of the Injury on Duty Payment being payable until death”.

29/11/2013 HR/OPCC Meeting

“The College of Policing will be hosting an IOD training event on 31 January for SMP’s. A meeting of the National Attendance Forum will look at the agenda for the training day. MS asked if David Bulpitt looked at who is tier 1/2 etc. CW advised that the pension’s team is looking at this”.


“Central pay overspend will be allocated to departments where possible in future reports. Medical retirements was discussed and the potential need to accrue this spend at the end of the financial year dependent on advice from

  1. The PCC sought clarification on the advice given to retiring officers on thelength of time they have to be retired before they can return to a staff role –this is dependent on how different the staff role is to that of the Officer rolethey were in”.


16 letters are sent to youngest band4s (highest disablement) informing them they are subject to a Regulation 37 review.