MEDICAL GAS SAFETY
Part B: From engineering compliance to organisational assurance Richard Maycock
If Part A changes the way we design and prove an MGPS, Part B changes the way healthcare organisations govern it throughout operation. The familiar engineering controls remain essential, but the 2026 document places them inside a wider organisational framework. Medical gas safety is not solely an Estates responsibility; it is a patient-safety, medicines-management, operational- resilience, and corporate-governance issue.
Figure 3: MGSG (Medical Gas Safety Group) typical example.
The Medical Gas Safety Group: bringing the whole risk together The Medical Gas Safety Group (MGSG) is central to that shift. Its value is not in creating another meeting. Its value is in bringing together information and authority that can otherwise remain fragmented across Estates, pharmacy, clinical services, capital projects, health and safety, and operational management. Consider a common scenario. Estates may know that an oxygen branch is operating close to its calculated capacity. A clinical team may be planning to introduce high-flow equipment. Capital Projects may be refurbishing an adjacent ward. Pharmacy may be reviewing gas usage and contingency arrangements. Individually, each department sees only part of the picture. The MGSG provides a route for the organisation to recognise that these separate activities may create one combined MGPS risk. This also improves accountability. Significant defects, resilience concerns, overdue actions, competence gaps, incidents, major projects, and changes in clinical demand
should be visible through an appropriate governance route rather than remaining within local engineering correspondence. Board and senior-management assurance depends on having a clear route by which material MGPS risks are escalated, owned, and monitored. The same principle applies to projects. A new installation can be technically compliant at handover yet still create operational problems if the receiving team was not involved in design assumptions, emergency arrangements, isolation philosophy, or documentation requirements. Linking project decisions to MGSG oversight helps connect Part A design with Part B operation before handover rather than after problems emerge.
Pharmacy: medical gases are medicines The increased visibility of pharmacy is one of the most important aspects of the 2026 governance model. Medical gases occupy an unusual position: they are medicinal products delivered through permanent engineering infrastructure and used directly in patient care. That combination means engineering, pharmacy, and clinical governance cannot sensibly operate in isolation. The Chief Pharmacist brings medicines-governance
oversight to decisions that may otherwise appear predominantly technical. Pharmacy and QC involvement is particularly important around gas quality, commissioning and return to service, changes in medicinal gas use, cylinder management, contingency supplies, incidents, and the transition away from piped nitrous oxide where clinically appropriate. This does not mean pharmacy is expected to design pipework or manage engineering permits. Equally, Estates should not be expected to provide pharmaceutical assurance. The strength of the revised structure is that responsibilities remain distinct while the governance interfaces become clearer. Engineering verification can demonstrate that the pipeline performs correctly; QC can provide the required pharmaceutical-quality assurance; clinical representatives can confirm that the service is suitable for patient use. A strong MGSG should therefore be genuinely multidisciplinary, not an Estates meeting to which pharmacy and clinicians are occasionally invited. Pharmacy should be able to challenge proposals, understand outstanding risks, and influence decisions where medicines governance is affected. That is particularly relevant when a technical change alters how a medicinal gas is stored, produced, distributed, or presented to clinical users.
KEY
Each circle denotes members co-opted to the core MGSG for specific task reviews as appropriate
CARA: from a list of defects to active risk management Part B’s Compliance Audit and Risk Assessment (CARA) gives organisations a clearer mechanism for understanding the condition of existing systems and translating deficiencies into managed risk. This is important because much of the NHS estate is old, complex, and continually modified. Complete immediate compliance may not always be technically or financially achievable, but unmanaged non-compliance is not an acceptable alternative. The CARA process creates a logical chain: identify
the deficiency, understand the consequence, assess the risk, prioritise the action, assign ownership, implement
66 Health Estate Journal October 2026
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