HTM 05-01: Managing Healthcare Fire Safety updated by NHS England

HTM 05-01 should be read in conjunction with other Health Technical Memoranda in the Firecode suite, specifically Health Technical Memorandum 05-02: Firecode – Guidance in Support of Functional Provisions (Fire Safety in the Design of Healthcare Premises) and Health Technical Memorandum 05-03: Firecode – Fire Safety in the NHS – Operational Provisions.

While HTM 05-02 and HTM 05-03 provide guidance in respect of the fire precautions and protective measures appropriate for healthcare premises, HTM 05-01 focuses squarely on establishing the appropriate fire safety management system to be applied to healthcare organisations.

It recognises the unique operational context of healthcare organisations and the need for a robust system of fire safety management. The guidance and recommendations contained in HTM 05-10 (which was first published back in July 2016) are intended to support compliance with statutory requirements within a structured management framework.

Key changes

One of the most significant changes since the last edition is the inclusion of the Building Safety Act 2022 as a new piece of primary legislation governing fire and building safety. The Building Safety Act expands the statutory framework previously limited to the Building Regulations 2010 and the Regulatory Reform (Fire Safety) Order 2005, adding a third foundational legal pillar.

It imposes specific duties on those involved in the design and construction of higher-risk buildings as well as separate duties on those managing such buildings once they’re in occupation. It may also require healthcare organisations to appoint new statutory roles such as Accountable Persons and Principal Accountable Persons.

Where applicable, HTM 05-01 provides references or guidance on incorporating the requirements of the Building Safety Act into the management of buildings, fire safety and daily operations – particularly so during construction and refurbishment phases – while ensuring the golden thread of safety information is maintained accurately and kept updated at all times.

In this revision of HTM 05-01, the responsibilities previously associated with the Authorising Engineer (Fire) are now separated into two defined roles: the Independent Expert Advisor (Authorising Engineer) and the specialist Fire Engineer.

The Independent Expert Advisor (Authorising Engineer) role focuses on auditing fire safety management systems. Although previous Firecode guidance has assigned the auditing function to the Authorising Engineer – which required Chartered Engineer status – the nature of auditing does not typically require the engineering competencies defined by the Engineering Council for chartership. In practice, these audits are often conducted by experienced fire safety professionals who are not Chartered Engineers, with input from a chartered individual where necessary.

As such, fire safety auditing is not an engineering task and the use of the Authorising Engineer title is therefore not considered appropriate. In contrast, where detailed fire engineering solutions are needed – such as in complex building designs or fire strategy work – a specialist Fire Engineer (often chartered or incorporated depending on the complexity and risk profile of the project) is the appropriate source of technical advice.

The updated HTM 05-01 states: “This new structure matches each role to the right set of skills and competencies, making the approach more practical and proportionate. It helps healthcare organisations bring in the right expertise for both oversight and technical advice, improving how fire safety is managed overall.”

Distinct designations

The revised HTM 05-01 both formalises and clarifies four distinct designations under the Authorised Person (Fire) role (ie the Fire Safety Advisor). These include three specialisms: fire risk assessment, fire training and fire projects, as well as the separate role of Authorised Person (Fire Safety Maintenance).

While these functions were touched on in the 2023 revision of HTM 05-03 Part B, their inclusion in HTM 05-01 “provides a more structured framework” for assigning responsibilities and ensuring appropriate competencies.

In complex healthcare organisations, the role of Senior Fire Safety Advisor may also be designated. This is an experienced Fire Safety Adviser with extensive knowledge of healthcare fire safety who typically co-ordinates a team of Fire Safety Advisors. While holding similar core competencies, the Senior Fire Safety Advisor brings additional expertise and may take on some responsibilities of the Fire Safety Manager. The role exists to provide leadership and oversight within more structured fire safety management arrangements.

Fire safety policy guidance

The Department of Health fire safety policy, previously presented as Chapter 2 in the 2013 edition, is no longer included as a standalone chapter in the main text. Instead, this content has been updated, renamed and also moved to Appendix A. Fire safety policy is overseen by NHS England (or its relevant replacement body/ organisation) rather than the Department of Health.

Additionally, revised fire safety policy guidance is also set out in Chapter 5 of this edition, in turn aligning the guidance with current governance arrangements and strategic responsibilities across the National Health Service.

*Access copies of the updated HTM 05-01: Managing Healthcare Fire Safety online