M&M Compliance Training
In a hospital, someone has to be the named point of control for the water system, the medical gas pipeline, the ventilation serving the operating theatres, and the electrical network. That named individual is the Authorised Person, or AP — and the way the role is filled is more specific than most people realise. You do not simply “become an AP” by attending a course. You demonstrate competence through discipline-specific training, and then your organisation appoints you, in writing, to a defined system on a defined site.
This guide explains what an Authorised Person actually does, how the role sits between the Competent Person below and the Authorising Engineer above, which Health Technical Memorandum (HTM) governs each AP discipline, and the route to getting appointed. If you manage healthcare estates, or you are an engineer looking to move into an AP role, this is the framework your compliance depends on.
The Authorised Person has the key operational responsibility for the specialist service — the focal point for day-to-day management of the system.
The Authorised Person is the operational duty holder for a specific engineering discipline within a healthcare site. Working to the relevant HTM, the AP takes responsibility for the safe day-to-day operation, maintenance control and documentation of their system. In practice that means implementing safe systems of work, issuing and controlling permits-to-work, supervising and authorising the Competent Persons who carry out hands-on tasks, maintaining records and logbooks, and acting as the site’s technical focal point for that discipline.
Critically, the AP’s authority is specific, not general. An AP appointed for low voltage electrical systems is not thereby authorised for water or ventilation. Each discipline has its own AP, its own training, and its own letter of appointment. That precision is the point: it makes accountability unambiguous when something goes wrong.
HTM guidance defines a clear chain of roles, and an AP only makes sense in relation to the roles above and below it. Understanding the whole chain is the fastest way to understand the AP.
Designated Person (DP)
The Designated Person holds the strategic, board-level duty. This is the senior individual with ultimate organisational responsibility for ensuring the engineering risk is managed and that suitable people are appointed. The DP does not run systems day to day; they own the duty.
Authorising Engineer (AE)
The Authorising Engineer is the independent expert. The AE provides independent auditing and advice, assesses the competence of candidates, and recommends who should be appointed as Authorised Person. Because the AE is independent of day-to-day operations, their recommendation gives the appointment its assurance weight.
Authorised Person(AP)
The AP is the operational focal point – appointed in writing by the organisation, on the recommendation of the AE, to manage the discipline on the ground.
Competent Person(CP)
The Competent Person carries out the hands-on work — maintenance, testing and repairs — under the authorisation and supervision of the AP. CPs are themselves appointed in writing following assessment of competence.
The Designated Person owns the duty, the Authorising Engineer independently advises and recommends, the Authorised Person operationally controls the system, and the Competent Person does the hands-on work under the AP.
There is no single “Authorised Person” qualification. The role is always tied to a discipline, and each discipline has its own Health Technical Memorandum. The main healthcare AP disciplines are:
Authorised Person discipline
Governing memorandum
Scope
Medical Gases
HTM 02-01
Medical gas pipeline systems (MGPS)
Ventilation
HTM 03-01
Specialised ventilation, including theatres and isloation
Water
HTM 04-01
Safe water systems and Legionella control
Electrical (low voltage)
HTM 06-02
Installed low voltage electrical systems
Electrical (high voltage)
HTM 06-03
High voltage electrical distribution
Lifts
HTM 08-02
Lift management and lifting equipment
In Scotland the equivalent Scottish Health Technical Memoranda (SHTM) apply — for example SHTM 06-02 for low voltage electrical systems — published by NHS National Services Scotland. The role structure is the same; the reference documents carry the SHTM prefix.
Keep the HTM numbers straight: HTM 04-01 is safe water (not HTM 03-01, which is ventilation), and HTM 02-01 is medical gases. Mislabelling these on appointment letters or training records is a frequent and avoidable audit finding.
AP training is discipline-specific and built around the relevant HTM. A typical course combines the legal and regulatory framework, the detail of the memorandum, risk assessment and documentation, safe systems of work and permit control, and the specific roles and responsibilities the AP must discharge. As an example, the Authorised Person (Water) course for healthcare premises is commonly delivered over five days, reflecting the breadth of HTM 04-01 and the supporting Approved Code of Practice for Legionella.
Most AP courses assume a foundation of relevant engineering experience and, in several disciplines, prior Competent Person knowledge as a prerequisite. You are not starting from zero; AP training builds an experienced engineer up to the operational-control level the role demands. After training, refresher training is expected on a risk-based cycle — commonly about every three years. HTM 06-03, for instance, recommends retraining the high voltage AP every three years, and refresher training for water roles is generally accepted as appropriate every two to three years.
Training proves you are competent. Appointment makes you the Authorised Person. They are two different steps, and you need both.
This is the part that catches organisations out. Completing AP training does not, on its own, make someone an Authorised Person. The appointment is a separate, formal act. Following training, the Authorising Engineer assesses the candidate’s competence and recommends them; the organisation then issues a written letter of appointment that names the individual, the discipline and the site or systems they are authorised for. Until that letter exists, there is no AP — and the organisation has a gap in its safe system of work.
That is why competent estates teams treat AP coverage as a live register, not a one-off task: appointments are person-and-site specific, they lapse if someone leaves, and they need refresher training to stay valid. A clear competence-management system that tracks who is appointed to what, and when their training is due, is what keeps the chain defensible at audit.
The AP framework does not sit in isolation; it is how healthcare organisations discharge statutory duties. The overarching duty comes from the Health and Safety at Work etc. Act 1974, which requires safe systems of work and competent people to operate them. Discipline-specific law sits beneath it — for example the Electricity at Work Regulations 1989 for electrical systems, and the Control of Substances Hazardous to Health Regulations with the Legionella Approved Code of Practice (L8) and HSG274 for water safety. The HTM appointment structure is the recognised way of demonstrating that these duties are being met by named, competent people. These duties are enforced by the Health and Safety Executive across Great Britain.
We help NHS and private healthcare estates teams build and maintain a sound AP framework. We deliver Authorised Person and Competent Person training across the core HTM disciplines; we provide Authorising Engineer services so appointments are independently assessed and recommended correctly; and we help you put a competence-management system in place so every appointment, refresher date and record is tracked rather than chased. The result is a chain of competence that stands up to scrutiny — not a scramble before the next audit.
Talk to us about training across water, ventilation, medical gases and electrical systems - and about the AE support and competence tracking that make appointments straightforward.
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