Human Tissue Authority

The regulator for human tissue and organs

Traceability (T)

The Traceability standards cover the systems and records for the traceability of bodies and tissue and disposal. Out of 59 inspections 66 shortfalls were identified under this standard, 28 of these were under standard T1(c) in relation to the requirement for three identifiers to be used. 

Key findings:

  • establishments did not use three identifiers for release or, for some who attempted to use three identifiers, these were not sufficiently robust, such as two being provided by the funeral director with the third being taken from mortuary internal documentation;
  • release using the Coroner’s documentation or the ‘green form’, neither of which has sufficient identifiers; and,
  • only a name being taken for viewings of the deceased (this was also reflected as an issue in the number of viewings of the wrong body being reported as HTARIs).
The HTA’s good practice advice arising from these observations are as follows:
  1. Funeral directors should bring three points of identification for the body they wish to collect, which should be compared against the identity tags on the body. General Data Protection Regulations requirements restricting the storage and use of personal data do not extend to the deceased.
  2. Establishments should liaise with the Coroner to ensure three points of identification are stated on their release documentation. Age is not considered a robust identifier; date of birth should be supplied where possible.
  3. For viewings, a system should be in place that obtains three identifiers from those requesting a viewing from the outset. Feedback from establishments that have introduced such a system has indicated that people understand the need for this. If there are requests for viewings where people cannot provide three points of identification, other information (such as place of death) may assist the establishment in assuring itself that the correct body is being prepared for viewing. 

Updated guidance for T1c is available on our website

Last updated on: 23 May 2019