GUIDANCE
Limitations with HTMs need addressing
Ashley Morpeth, an Authorising Engineer at Eta Projects, and an experienced and qualified health and safety professional with over 15 years’ experience in the Work at Height and Confined Spaces sector, discusses some of the key reasons why he believes a number of HTM guidance documents are badly in need of updating.
Having recently started a new job, by way of some sort of initiation I was tasked with writing an article for Health Estate Journal. While searching through the archives of the magazine seeking inspiration, I came across an article titled ‘The Missing Health Technical Memoranda’, first published on 3 November 2006. This article centred on the argument that there were significant gaps in the current suite of Health Technical Memoranda (commonly referred to as ‘the HTM’s’), and that more could be done to control the highest-risk activities within health estates. This piqued my interest, because 18 years later the issues raised in the article remain extant, and are in fact the same issues that I (and a lot of others) still face today. I endeavoured to find out why. To understand why there are limitations with the HTMs, and why they only cover specific activities, in a specific way, perhaps we need first to understand the motivation behind writing them in the first instance. In other words, where did they come from?
Designed to ensure that healthcare estates complied It is often thought that the HTMs were originally written to be Safe Systems of Work, as required by the Health and Safety at Work etc Act (HSWA) 1974, and inferred by the Management of Health and Safety at Work Regulations 1999. It would seem, however, that they were not. Instead, they are a series of documents written so that healthcare estates could comply with the requirements of the Care Quality Commission and the Health and Social Care Act. This line of thinking can be demonstrated by the flow chart diagram on page 5 of HTM 00: Policies and Principles of Healthcare Engineering (see Figure 1). You may notice a lack of health and safety legislation being cited. This is an important distinction, because
it could explain the driving force behind writing certain things into the HTMs and not others. While some health and
Figure 1: HTMs and the legislative framework, from HTM 00: Policies and principles of healthcare engineering.
safety has found its way in – for example with a cursory nod to the HSWA 1974 in Paragraph 2.5 of HTM 00 – initially the HTMs were primarily written to prioritise patient safety and welfare (as demonstrated at the bottom of the flow chart). While clearly this is no bad thing,
it has unfortunately come at a cost, and the safety and welfare of the workforce operating and maintaining these systems is often overlooked. An example of this can be seen in HTM 02-01: Medical Gas Pipeline Systems, Part B: Operational Management, where a permit-to-work system is used not
April 2024 Health Estate Journal 57
Used courtesy of the Department of Health and Social Care.
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