Human Tissue Authority

The regulator for human tissue and organs

Part 1 - HTA Compliance submissions

Every two years establishments licensed by the HTA in certain sectors are required to submit compliance data. Collection of this information contributes to our oversight of a sector, guides our regulatory approach, informs the scheduling of site visit inspections and supports our system of continuous licensing.

The most recent compliance update survey was undertaken in autumn 2017. In the PM sector, this was less detailed than in previous years because an additional in-depth survey of storage and capacity had taken place at the end of 2016.   

Questions in the 2017 assessment covered six broad areas:

  • Activity
  • Storage
  • Governance
  • Staffing
  • Risk
  • Premises 

All 180 licensed establishments in the PM sector responded to the 2017 questionnaire. This included nine establishments licensed for storage only who do not undertake post-mortem examinations.  

Establishment Activity

Data collected in the latest compliance update assessment was for the year to 30 June 2017. 

Over this period, establishments received 334,314 bodies and performed 92,926 invasive PM examinations. Whilst the HTA does not licence non-invasive post-mortem cross-sectional imaging (PMCSI), 36 establishments reported that they had seen an increased demand for this activity.

49% of establishments stated that there had been an increase in the average length of time bodies were in their care. The most common causes given were: 

  • delay in collection by funeral director;
  • delay in getting information from the Coroner; and,
  • delay in death registration over holiday periods.

(Note - some establishments’ selected more than one reason from the options given. See Figure 1)

Storage and contingency storage

56% of establishments confirmed that they had sufficient refrigerated storage capacity, with a further 37% stating that capacity was sufficient most of the time; however, 7% of establishments reported that capacity was insufficient. 

31% of establishments stated that they did not have sufficient freezer capacity. On inspection, we have also frequently observed a lack of bariatric freezer storage capacity.

14% of establishments reported routinely using temporary storage options as part of their regular storage.

The HTA has provided advice on the website for establishments in relation to capacity and contingency storage here


Nine mortuaries (5%) stated that they did not have a schedule of audits; 25% of establishments stated that they were not up-to-date with their audit schedule, with shortage of staff being the main reason given. HTA Inspection findings, documented later in this report, also identified issues with audits.

51% of establishments stated that removal of tissue from the deceased happens in areas other than the mortuary, most commonly in the Emergency Department (ED), with 26% of these establishments not having a Person Designated (PD) in these areas. 

Advice: The HTA advises having PDs in all areas where licensable activity takes place to help ensure the DI has effective oversight  in those areas

Just over a third of establishments (34%) stated that they were currently storing tissue for police purposes.


As in the previous report, 7% of establishments reported that staffing levels were insufficient for the level of activity undertaken, with 16% of establishments having Anatomical Pathology Technologist (APT) vacancies at the time of submission.  

The HTA recognises the importance of establishments having sufficient staff with relevant technical skills, knowledge and experience to ensure appropriate understanding and application of the requirements of the HT Act.


98% of establishments were aware of the HTA publication 'Regulation of the Post Mortem Sector 2014-16: What we have learned?’ with only three establishments being unaware. This document included a section advising on risk management that had resulted in 74% of establishments updating their risk assessments. 


At the time the data was submitted, 54% of establishments had applied for capital funding in the previous two years, of which 75% were approved, 18% were awaiting a response and 7% were refused. 

Last updated on: 28 May 2019