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Restrictive Practices and Physical Interventions Policy
1. Purpose
The purpose of this policy is to ensure that {{org_field_name}} adheres to CQC regulations, the Mental Capacity Act 2005, the Human Rights Act 1998, and other relevant legislation when implementing restrictive practices and physical interventions. This policy aims to:
- Minimise the use of restrictive practices and ensure they are only used as a last resort.
- Protect the dignity, rights, and safety of service users and staff.
- Ensure compliance with CQC’s fundamental standards, particularly regarding safeguarding and safe care.
- Promote positive behaviour support (PBS) and non-restrictive approaches to managing challenging behaviours.
- Provide clear guidance on lawful and ethical decision-making when restrictive practices are deemed necessary.
Introduction and Policy Statement (Restraint / Restrictive Intervention sets out how {{org_field_name}} prevents, reduces, authorises, applies, records, reviews and governs the use of restraint and other restrictive interventions. We recognise that restraint is intrusive and carries physical and psychological risks. Restraint will only ever be used as a last resort, for the shortest time possible, and only where it is lawful, necessary, proportionate and the least restrictive option to prevent harm.
We will always prioritise Positive Behaviour Support (PBS), de-escalation, trauma-informed approaches, reasonable adjustments and capable environments to prevent escalation and reduce the need for restraint, in line with DHSC ‘Positive and Proactive Care’ and NICE guidance.
Our practice is underpinned by human rights principles, including dignity, respect, autonomy, equality and safety. We do not use restraint as punishment, for staff convenience, or to enforce compliance.
2. Scope
This policy applies to:
- All staff members, including permanent, temporary, agency, and volunteer workers.
- All service users who may require restrictive interventions.
- Families, advocates, and external professionals involved in the care of service users.
- Visitors and external stakeholders who may be impacted by the implementation of restrictive practices.
3. Legal and Regulatory Framework
This policy aligns with:
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014:
- Regulation 9 – Person-Centred Care
- Regulation 10 – Dignity and Respect
- Regulation 11 – Need for Consent
- Regulation 12 – Safe Care and Treatment
- Regulation 13 – Safeguarding Service Users from Abuse and Improper Treatment
- Mental Capacity Act 2005 and Deprivation of Liberty Safeguards (DoLS)
- Human Rights Act 1998 (Article 3 – Freedom from degrading treatment, Article 5 – Right to liberty)
- Equality Act 2010 (Protection against discrimination)
- The Restraint Reduction Network Standards
- Positive Behavioural Support (PBS) Framework
Any restraint or restrictive intervention must meet all of the following tests and be documented:
- Prevention first: proactive PBS and de-escalation strategies have been attempted or were not possible due to immediate risk.
- Lawful purpose: used only to prevent foreseeable harm to the person or others, or other lawful safeguarding purpose,
- Necessity: there is an immediate and significant risk and no safer alternative.
- Proportionality: the level of intervention is the minimum required to manage the risk presented.
- Least restrictive option: the option chosen restricts the person’s rights and liberty the least, for the shortest time possible.
- Safety: the technique/equipment is approved and staff are trained and competent; continuous monitoring takes place throughout.
- Human rights: decisions consider the person’s rights, dignity, and equality, including the impact on autistic people and people with a learning disability.
- MCA / consent: consent is obtained where the person has capacity; where the person lacks capacity, MCA best-interests decision-making is followed and recorded.
Where restrictions amount to a deprivation of liberty, we obtain the appropriate authorisation in line with the MCA and DoLS (and LPS when/if commenced).
4. Principles of Restrictive Practices
4.1 Least Restrictive Approach
Restrictive practices must only be used:
- As a last resort, when all other non-restrictive interventions have failed.
- In proportion to the level of risk to the service user or others.
- For the shortest time necessary.
- With full documentation and justification.
4.2 Positive Behaviour Support (PBS)
{{org_field_name}} promotes PBS as a primary strategy for reducing restrictive interventions by:
- Identifying triggers for challenging behaviours.
- Implementing proactive interventions to prevent distress.
- Providing staff training on de-escalation techniques.
- Encouraging service user engagement in behaviour management strategies.
4.3 Consent and Capacity
- Service users must be involved in decisions regarding their care whenever possible.
- The Mental Capacity Act 2005 must be followed when assessing whether a service user can consent to restrictive practices.
- Where a service user lacks capacity, best interest decisions must be made following consultation with families, advocates, and professionals.
Assessment and Decision-Making (Risk / PBS / MCA)
We use individual risk assessments and PBS plans to prevent and reduce restrictive interventions. For each person at risk of distress behaviours, the care plan/PBS plan will include known triggers and early warning signs, proactive strategies, de-escalation preferences, communication and sensory needs, environmental adjustments, and any agreed reactive strategies (including clear boundaries on any restrictive intervention).
Before any planned restriction is introduced we:
- assess risks and benefits and document why less restrictive options are insufficient,
- consider health factors (pain, infection, medication effects, sleep, sensory overlooking, cultural and disability needs and reasonable adjustments,
- complete MCA capacity assessment and best-interests decision where needed, and
- document an explicit reduction plan and review schedule.
In emergencies, staff complete a dynamic risk assessment and apply the minimum lawful intervention necessary, then complete a full review and update plans afterwards.”
4.4 Deprivation of Liberty Safeguards (DoLS)
Where a restrictive practice amounts to a deprivation of liberty, DoLS authorisation must be sought from the local authority. This applies where:
- A service user is not free to leave.
- Continuous supervision and control are exercised.
- There are no less restrictive alternatives available.
4.5 Definitions
Restraint: Any act (or omission) that uses force, or threat of force, or restricts a person’s freedom of movement whether or not the person resists. Restraint can be intentional or unintentional and includes actions to prevent a person from doing what they want to do or moving where they want to go.
Restriction: A wider term that includes any rule, practice or environmental control that limits choice, autonomy, privacy, access, movement or liberty (for example locked doors, restricted access to kitchen, blanket rules). Restrictions may become restraint if they involve force/threat of force or significant limitation of movement.
Roles and Responsibilities
- All staff: use PBS and de-escalation first; only apply restraint if trained/competent and where lawful/necessary; continuously monitor wellbeing; record incidents immediately; report concerns and safeguarding issues.
- Registered Manager (or Service Manager): overall accountability for restrictive practice governance; ensures authorisation processes are followed; reviews each incident within required timescales; ensures learning is embedded; ensures appropriate notifications are made (including CQC notifications) and duty of candour is applied where relevant.
- Safeguarding Lead: oversees safeguarding decision-making multi-agency liaison; oversees thematic reviews where restraint indicates potential abuse/improper treatment risk.
- PBS Lead / Behaviour Specialist (where used): supports functional assessment, PBS plan quality, proactive strategy development, staff coaching, and restraint reduction planning.
- Senior leadership / governance group: receives regular reporting on restraint metrics, trends, audit findings, and actions; ensures resources and improvements are implemented.
5. Types of Restrictive Practices
5.1 Physical Interventions
Using physical contact by one or more staff to restrict a person’s movement to prevent harm (for example guiding, holding, blocking, or escorting where the person cannot freely move away).
Safeguards / key points:
- Used only as a last resort, for the shortest time possible, to prevent immediate and significant harm.
- Must be reasonable, proportionate and least restrictive, and never used as punishment, coercion or for staff convenience.
- Only used by staff who are trained and assessed as competent in approved techniques.
- Continuous monitoring during restraint for signs of distress or medical risk (for example breathing difficulties, pain, reduced consciousness, injury).
- Post-incident: welfare checks, debrief, incident report, and review to identify triggers and strengthen proactive PBS strategies.
5.2 Mechanical Restraint
Using a device, equipment or material to restrict movement (for example specialist belts, straps, splints, mittens, wheelchair tables, bedrails, or other positioning aids), where the primary purpose is to prevent free movement rather than to treat a condition.
Safeguards / key points:
- Mechanical restraint will only be used where it is clinically indicated, authorised, and supported by a documented risk assessment and care/PBS plan.
- Must have a clear rationale, time limits, and a step-down (reduction) plan.
- Must specify: who can apply/remove it, how it is fitted safely, skin integrity checks, comfort, hydration/toileting access, and dignity/privacy arrangements.
- Ongoing monitoring is required to prevent injury, pain, pressure damage, distress or circulation compromise.
- Any mechanical restraint that significantly restricts liberty will trigger review under MCA and consideration of whether DoLS authorisation is required.
5.3 Chemical Restraint
Use of medication primarily to control or restrict behaviour or movement (including PRN used for behaviour control rather than treating a diagnosed condition), particularly where the intention or outcome is sedation or reduced responsiveness.
Safeguards / key points:
- Medication must be clinically prescribed, clearly documented, and administered in line with the MAR chart and medication policy.
- The PBS plan must state: clear indications, maximum dose/frequency, expected effect, side effects, contraindications, monitoring requirements, and escalation guidance.
- We apply STOMP principles: PRN/psychotropic medication is not used as a substitute for PBS, and any use triggers review of underlying causes (for example pain, infection, constipation, sleep, sensory overload, mental distress, trauma triggers, environmental factors).
- PRN use is recorded, reviewed and reduced where safe, with regular prescriber review to assess effectiveness, side effects and reduction/discontinuation plans.
- Covert medication (medication hidden in food/drink) is not used unless there is a lawful, best-interests decision under the MCA, documented multidisciplinary agreement, and clear pharmacy/GP involvement, with regular review.
5.4 Environmental Restrictions
Restricting access to environments, activities, items, or community participation that limits freedom and/or choice (for example locked doors, restricting access to kitchen/sharps, limiting internet/phone use, restricting access to money, removing possessions, restricting visits, or requiring supervision in certain areas).
Safeguards / key points:
- Environmental restrictions must be individualised — blanket restrictions are not permitted unless there is a clearly documented, time-limited safety basis with a plan to reduce and individualise.
- Must be supported by: risk assessment, least-restrictive rationale, and a clear plan for how the person can regain access safely (positive risk-taking approach).
- Must take account of communication needs, sensory needs, cultural needs, trauma history, and reasonable adjustments.
- Must specify: who authorises changes, how the restriction is explained in accessible format, and how it will be reviewed.
- Any restriction that results in continuous supervision and control and/or the person not being free to leave may amount to a deprivation of liberty and will be managed under MCA and DoLS (and LPS when/if commenced).
5.5 Seclusion
Confining a person alone in a room or area they are prevented from leaving (including where a door is locked, held shut, blocked, or staff physically prevent exit), even if for a short period.
Position in our service:
- Seclusion is not used within this supported living service.
- If a situation arises where a person is restricted to an area due to immediate risk, it will be treated as a restrictive intervention, recorded as an incident, and managed under this policy’s legal/ethical tests, authorisation, monitoring, and review requirements.
- Any environmental arrangement that prevents the person from leaving freely will be reviewed urgently under MCA/DoLS considerations and safeguarding, and plans will be updated to prevent recurrence.
For clarity, restraint involves force, threat of force, or restricting freedom of movement, whereas restriction is a broader term covering any practice or rule that limits choice or liberty. Restrictions may become restraint if force/threat of force is used or if movement is significantly limited. Restrictive practices can be planned or unplanned, intentional or unintentional, including omissions or ‘blanket rules’.
Implementing Restraint Safely (Physical wellbeing / time limits / review)
“Where restraint is unavoidable, we will:
- use only approved techniques that staff have been trained and assessed as competent to use, consistent with recognised standards (including RRN principles where applicable).
- ensure the intervention is the minimum necessary and ends as soon as the immediate risk has reduced.
- maintain the person’s dignity, privacy and communication needs throughout (including explaining what is happening in an accessible way).
- continuously monitor airway, breathing, circulation, level of distress, pain and signs of injury throughout the intervention and immediately afterwards, and seek medical assistance with clear time limits: restraint must not continue longer than necessary to manage immediate risk; if the situation cannot be safely resolved, staff will seek additional support/clinical advice/emergency assistance as appropriate.
- ensure that any equipment used (where applicable) is clinically prescribed/authorised, risk assessed, fitted correctly, and monitored as set out in the person’s plan.
- We do not use dangerous pain-compliance techniques, deliberate airway restriction, or any technique that would reasonably increase risk of injury or trauma.
6. Training and Competency
All staff receive mandatory training in:
- PBS and prevention, trauma-informed approaches, communication and reasonable adjustments
- de-escalation and conflict resolution
- lawful and ethical decision-making (MCA, consent/best interests, human rights, safeguarding)
- safe restraint techniques, including physical wellbeing monitoring and post-incident responsibilities
Training is refreshed at least annually (and sooner where required), with competency assessment and observation in practice. Staff receive ongoing supervision and reflective practice, and any staff involved in restraint incidents will have access to debrief and targeted coaching to reduce recurrence. - Where physical restraint training is provided, it will be quality assured in line with the RRN Training Standards.
7. Incident Reporting and Review
7.1 Documentation
- Every restrictive practice must be recorded in an Incident Report.
- Reports must include:
- Triggers and de-escalation attempts.
- The type of intervention used.
- Duration and impact on the service user.
- Service user’s post-incident wellbeing.
- Follow-up actions to reduce recurrence.
7.2 Post-Incident Review
After any restraint, we will complete a structured post-incident process, including:
- Immediate welfare checks for the person and staff (physical injury, emotional distress), and medical review where required.
- Person-centred debrief with the person (and advocate/family if appropriate), using accessible communication, to understand their experience and what would help reduce future risk.
- Staff debrief and reflective practice, including psychological support where needed.
- Incident analysis to identify triggers, environmental factors, communication breakdown, health factors, and whether earlier prevention could have been strengthened.
- Care plan/PBS plan updates including changes to proactive strategies, early-warning responses, and any reduction actions for restrictions.
- Where patterns emerge, we will arrange a multi-disciplinary or specialist review (PBS/psychology/clinical input as appropriate).
7.3 Safeguarding and External Reporting
- Incidents of restraint or restrictive intervention will be notified to the Care Quality Commission (CQC) without delay where they meet the notification thresholds, in accordance with Regulation 18 of the Care Quality Commission (Registration) Regulations 2009 (Notification of other incidents).
- Families and advocates must be informed where appropriate.
- Any concerns regarding misuse or overuse of restrictive practices must be escalated through safeguarding procedures.
Where an incident constitutes a notifiable safety incident, we will comply with Regulation 20 (Duty of Candour) by acting in an open and transparent way with the person affected and/or their representative, including providing an explanation of what is known at the time, offering an apology where appropriate, keeping a written record of all communications and actions taken, and providing written follow-up and updates in line with our Duty of Candour procedure.
8. Governance and Oversight
8.1 Monitoring and Auditing
- Regular audits will be conducted to ensure compliance.
- Trends in restrictive practice use will be analysed to inform training and policy improvements.
8.2 Service User Involvement
- Service users must be consulted on their behaviour management plans.
- Advocacy support must be offered to ensure their voices are heard.
8.3 Governance Reporting and External Notifications
We maintain an internal incident reporting system that captures all restrictive interventions, including type,
Restrictive Practices and Intervention attempts, injuries, and outcomes. We produce regular governance reports (at least monthly/quarterly) for senior leadership that include: frequency and duration of restraint, patterns/triggers, equality impacts, injuries, safeguarding outcomes, themes from debriefs, and progress against restraint reduction actions.
Where required, we notify external bodies, including making statutory notifications to CQC without delay in accordance with Regulation 18 of the Care Quality Commission (Registration) Regulations 2009, and we work with safeguarding partners, commissioners and other agencies as appropriate.
8.4 Equality, Communication and Human Rights
We will consider cultural, linguistic, disability and communication needs in all behaviour support including sensory needs and autism-specific reasonable adjustments. Where a restriction or service rule could affect people differently, we will complete an Equality Impact Assessment and document mitigating actions. We ensure information and debrief processes are accessible (easy read/visual supports/advocacy support where needed), restrictive interventions disproportionately affect any protected group.
9. Related Policies
- Safeguarding Adults from Abuse and Improper Treatment Policy
- Mental Capacity and Deprivation of Liberty Safeguards Policy
- Safe Care and Treatment Policy
- Staff Supervision, Training, and Development Policy
- Incident Reporting and Investigation Policy
10. Policy Review
This policy will be reviewed annually or sooner if changes in legislation, best practice, or operational needs arise. All staff will be informed of updates and provided with training and guidance as necessary.tes and provided with training and guidance as necessary.
Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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