The HTA has worked 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.
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
Local authorities and the Police will need to decide, in the context of their Mass Fatalities Plan, which individual will take on the role of Designated Individual (the person under whose supervision the licensed activity is authorised to be carried on). We do not wish to be prescriptive about this: for example, the DI may be the Coroner, the lead Pathologist or the Senior Identification Manager.
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. This will mean that the HTA Head of Regulation for the geographical area will join the Mass Fatalities Coordination Group within 72 hours of the incident, in order that the HTA can provide direct advice and guidance on the requirements of the Human Tissue Act, including advice on how to rectify deficiencies. The intention is that the relevant licenses would be issued on site. A visual inspection by the HTA representative may be necessary and should be factored into processes detailed in the Mass Fatalities Plan.
What Happens Next
Emergency Planning Officers and others with a responsibility for developing the Mass Fatalities Plan should look at the HTA’s current pathology/post mortem compliance report and associated guidance documentation. These provide a good starting point for those who are unfamiliar with the HTA and will enable them to assess whether the emergency facilities meet the standards. The documents can be found on our website.
Note that the same processes will apply to incidents that result in contaminated fatalities.
Contact for queries:
Head of Regulation for the Post Mortem sector
Human Tissue Authority
151 Buckingham Palace Road
London SW1W 9SZ
Tel 020 7269 1900 (general)