23 February 2026

NHS England has published an updated edition of Health Technical Memorandum (HTM) 05-01: Managing Healthcare Fire Safety. The document sets out recommendations and guidance for the effective management of fire safety within healthcare premises.

HTM 05-01 should be read alongside other documents in the Firecode suite, notably:
•    HTM 05-02: Firecode – Guidance in Support of Functional Provisions (Fire Safety in the Design of Healthcare Premises)
•    HTM 05-03: Firecode – Fire Safety in the NHS – Operational Provisions

While HTM 05-02 and HTM 05-03 focus on fire precautions, protective measures and operational provisions, HTM 05-01 concentrates on establishing and maintaining an appropriate fire safety management system for healthcare organisations. It recognises the unique operational environment of healthcare settings and the requirement for a robust, structured approach to fire safety management in support of statutory compliance.

Key Changes
Building Safety Act 2022

One of the most significant developments in this revision is the inclusion of the Building Safety Act 2022 as a primary piece of legislation governing fire and building safety.

The Act expands the statutory framework beyond the Building Regulations 2010 and the Regulatory Reform (Fire Safety) Order 2005, introducing a third core legal pillar. It establishes specific duties for those involved in the design and construction of higher-risk buildings, alongside separate responsibilities for those managing such buildings in occupation.

Healthcare organisations may now be required to appoint new statutory duty holders, including Accountable Persons and Principal Accountable Persons, where applicable.

HTM 05-01 provides guidance on incorporating the requirements of the Building Safety Act into fire safety management systems, including during construction and refurbishment projects. Particular emphasis is placed on maintaining the “golden thread” of accurate, up-to-date safety information throughout a building’s lifecycle.

Changes to Professional Roles

The revision separates the responsibilities previously associated with the Authorising Engineer (Fire) into two distinct roles:
•    Independent Expert Advisor (Authorising Engineer)
•    Specialist Fire Engineer

The Independent Expert Advisor (Authorising Engineer) is responsible for auditing fire safety management systems. The updated guidance recognises that auditing functions do not typically require the engineering competencies associated with Chartered Engineer status. In practice, fire safety audits are often undertaken by experienced fire safety professionals, with chartered engineering input provided where necessary.

Conversely, where detailed fire engineering input is required for example, in complex building design or fire strategy development a specialist Fire Engineer is identified as the appropriate source of technical expertise. Depending on project complexity and risk profile, this role may require chartered or incorporated status.

The revised structure aligns responsibilities with appropriate competencies, supporting a more proportionate and practical approach to fire safety management.

Clarification of Authorised Person (Fire) Designations
The updated HTM 05-01 formalises and clarifies four distinct designations under the Authorised Person (Fire) role (Fire Safety Advisor):
•    Fire Risk Assessment
•    Fire Training
•    Fire Projects
•    Authorised Person (Fire Safety Maintenance)

Although these functions were referenced in the 2023 revision of HTM 05-03 Part B, their inclusion in HTM 05-01 provides a clearer framework for assigning responsibilities and ensuring appropriate competence.

In larger or more complex healthcare organisations, the role of Senior Fire Safety Advisor may also be designated. This individual typically coordinates a team of Fire Safety Advisors and provides leadership and oversight. While retaining core competencies, the Senior Fire Safety Advisor may assume additional responsibilities, including elements of the Fire Safety Manager’s role.

Fire Safety Policy Guidance
The Department of Health fire safety policy, previously presented as Chapter 2 in the 2013 edition, has been updated and relocated to Appendix A. Oversight of fire safety policy now sits with NHS England (or its successor body), rather than the Department of Health.

Revised fire safety policy guidance is also set out in Chapter 5 of the new edition, aligning the document with current governance arrangements.

The updated HTM 05-01 reinforces the importance of structured fire safety management within healthcare settings and reflects significant legislative and governance developments, including the introduction of the Building Safety Act 2022 and clarification of professional roles and responsibilities.

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