Jump to navigation

Licensing of emergency mortuaries

Update for regional resilience teams on licensing of emergency mortuaries

Over the last few months, the Human Tissue Authority (HTA) has been working with the Home Office and others to develop a policy and system for the provision of a licence in the event of a mass fatality incident resulting in the need for an emergency temporary mortuary. We now have a firm policy in place and are developing strong links with the key stakeholders who would be involved in setting up and operating emergency mortuaries.

Legal framework:

The HTA works within a statutory framework, and the following legal requirements need to be met before we can issue a licence:

  • we must have received an application
  • we must be satisfied that the proposed Designated Individual (DI) is a suitable person
  • we must be satisfied that the proposed Licence Holder (LH) is a suitable person / entity
  • we must be satisfied that the premises are suitable
  • the licence and any conditions must be acknowledged in writing by the DI and LH.
     

We have considered a range of options relating to the licensing of emergency mortuaries and have concluded that we should adopt the following two-pronged approach:

Guidance for planning

First, the HTA will proactively provide advice and guidance to post mortem establishments, the Home Office, coroners, pathologists, the Police and emergency planning teams about our policy and the licensing requirement. This will include:

  • application guidance so that emergency planners and Police Mortuary Operations Managers who may be appointed under a mass fatalities plan can assess their arrangements against our standards and will understand how to complete the compliance report for pathology/post mortem services
  • telephone support from the HTA Regulation Directorate
  • e-learning materials.
     

Local authorities and the Police will need to decide, in the context of their Mass Fatalities Plan, which individuals may take on the role of Designated Individual (the person under whose supervision the licensed activity is authorised to be carried on), with a view to them completing our e-learning package for DIs. We do not wish to be prescriptive about this: for example, the DI may be a pathologist, mortuary manager, local authority member with operational responsibility for the mortuary or a senior police officer.

Assistance during the response

Second, in the event of a major incident resulting in mass fatalities, we will provide a reactive licensing and inspection service. In practice, this means that a Head of Regulation and Regulation Manager(s) will join the Mass Fatalities Co-ordination Group to provide direct advice and guidance on the requirements of the Human Tissue Act. The intention is that the relevant licences could be issued within the first few hours of the incident and prior to the facility becoming operational for any necessary autopsy activity but without delaying non invasive identification operations.  A visual inspection by the HTA may be necessary and should be factored into processes detailed in the Mass Fatalities Plan.

What happens next

The HTA has developed a compliance report specifically for emergency temporary mortuaries:

The HTA standards that will allow us to assess the suitability of the Designated Individual, Licence holder, Premises and the practices being carried out under the licence. Emergency planning teams are required to complete and hold the compliance report as part of their local Mass Fatality Plan. We strongly advise that the guidance document is used during this process.

You will be required to submit the completed compliance report for assessment by the HTA when you request a licence for a temporary mortuary.  You will not need to submit the compliance report to the HTA prior to the request for a licence for a temporary mortuary.

The guidance document also includes a process flow diagram setting out the HTA licensing procedure; this can be used to inform your Mass Fatality Plans.

The compliance report should be reassessed at the time of the annual mass fatality plan review to incorporate any changes that may be made.

Following a mass fatality incident

The HTA must be contacted at the first opportunity following a mass fatality incident, your local plans should identify whose responsibility it is to contact the HTA and within what timeframe.

The HTA will arrange to join the mass fatality co-ordination team meeting. During this meeting we will provide guidance on the role of the Designated Individual and Licence Holder. We will also use this opportunity to review the completed compliance report and we may wish to view the facilities.

The HTA will not complete the compliance report on behalf of the licence applicant during this session. We aim to have a licence issued within 72 hours of the incident, but any problems relating to the completion of the compliance report may delay this process

Emergency contact number
In an emergency, please contact:
during normal office hours, The Regulation team on 020 7211 3400;
outside normal office hours, Dr Sandy Mather, Director of Regulation, on 07917 551667 in the first instance, or Caroline Browne, Head of Regulation on 07917 551822

Contact for licensing queries:
Caroline Browne
Head of Regulation
Human Tissue Authority
Finlaison House
15-17 Furnival Street
London, EC4A 1AB
Tel 020 7211 3400 (general) 020 7211 3408 (direct)
Email caroline.browne@hta.gov.uk
Web www.hta.gov.uk