What Is HTM 06-01?
Health Technical Memorandum 06-01 (HTM 06-01) is the Department of Health's guidance document for the design, installation, and operational management of electrical services in NHS and healthcare premises. Unlike a statutory instrument, it doesn't have the force of law in isolation — but failure to follow it is increasingly treated as prima facie evidence of negligence in regulatory investigations and litigation.
The Most Common Compliance Gaps
In our experience auditing NHS estate electrical infrastructure, the same issues appear time and again:
1. Inadequate documentation of HV system modifications Many trusts have accumulated decades of modifications to high-voltage switchgear and distribution systems without maintaining a proper modification history. When something goes wrong, it's almost impossible to trace root cause.
2. Absence of a current infrastructure risk register HTM 06-01 expects trusts to maintain a live risk register for their electrical infrastructure, scored by criticality and likelihood. Few do.
3. Non-compliant witness testing Commissioning records for new or replacement switchgear frequently lack the required witness sign-off by an Authorised Person (HV).
4. Expired periodic inspection records Statutory inspection intervals under BS 7671 are regularly missed, particularly across satellite buildings and outbuildings.
Practical Steps to Close the Gap
- Commission a gap analysis against HTM 06-01 Part A and Part B
- Establish a rolling infrastructure risk register with clear ownership
- Appoint a competent Authorised Person (HV) for all HV work
- Implement a digital compliance management system for statutory inspection tracking
- Undertake periodic training for your in-house engineering team
How B&W INFRA Can Help
We've supported NHS trusts across England with HTM 06-01 compliance — from rapid gap analyses following CQC concerns, through to full infrastructure reinstatement programmes following critical failures.
If you're concerned about your trust's electrical compliance position, get in touch for a confidential initial conversation.