yes, i believe that occurs especially when they 'logout' from your website, you don't destroy the session.
so in your code you'd do something like this.
if($logoff_button){
session_destroy();
header("http://www.domain.com/main.php");
}
that way, even if they do go back using the browsers back button and hit refresh they don't have a session and your page should prompt the user a login screen or similar page.
What i did was create a session called 'logged_in' and its checked throughout the 'member' pages and when the user logs off my site, that session is destroyed, so the session doesn't exist. So if the user tries to go back they can't.
In my code i have
if(!$_SESSION['logged_in']){
header("http://www.domain.com/login.php");
}
HTH.