- M&M Compliance Training
If you work in NHS estates, facilities management, or healthcare engineering, few questions generate more confusion than this one: "What is the difference between an Authorising Engineer and an Authorised Person?"
The two titles sound similar. Both are defined in Department of Health guidance. Both are essential to safe systems of work in healthcare settings. But their roles, responsibilities, and the legal basis for their appointments are entirely different — and confusing them can create serious gaps in your compliance framework.
This article explains both roles clearly, sets out the framework that governs them, and helps NHS Estates Managers understand exactly what they need to have in place.
Both the Authorising Engineer (AE) and the Authorised Person (AP) roles sit within the framework established by Health Technical Memorandum 00 (HTM 00), which provides overarching guidance on safe systems of work for healthcare engineering services. HTM 00 is the “parent” document that all other HTMs reference for the governance of safe working in areas including ventilation, water, electrical systems, pressure systems, and medical gases.
Within HTM 00, the responsibilities of both the AE and the AP are described, along with how they interact with the Responsible Person (RP) — typically a senior member of the trust’s management team who holds overall accountability for compliance.
The Authorising Engineer’s primary function is independence. They sit outside the operational chain of command, providing an objective view of whether the trust’s engineering safety management is working as it should. Think of the AE as an auditor: they are not there to manage day-to-day work, but to assure the Responsible Person that the systems and people in place are competent and fit for purpose.
Key AE duties under HTM 00 include reviewing and auditing the trust’s safe systems of work, assessing whether nominated APs have the necessary knowledge and experience for their roles, making formal written recommendations to the RP regarding AP appointments, and providing an annual written assurance report to senior management.
The Authorising Engineer is not a line manager, a safety officer, or an operational supervisor. Their value lies entirely in their independence — the ability to look at what a trust is doing and tell the Responsible Person, honestly, whether it meets the standard
-M&M Compliance Training Services
Because of this independence requirement, AEs should not be employed by the trust for which they are providing AE services. Increasingly, NHS trusts are engaging specialist firms — like M&M Compliance Training Services — to fulfil the AE function and ensure genuine independence is maintained.
Where the AE provides independent oversight, the Authorised Person provides day-to-day operational accountability. The AP is the person on the ground who understands the specific systems they are responsible for, manages safe working procedures, and takes formal accountability for issuing and receiving permits to work.
Critically, AP appointments are specialism-specific. An individual may hold AP status for low voltage electrical systems but not for medical gas pipeline systems. Each specialism carries its own knowledge requirements, and the appointment must be made separately for each area. APs should be formally assessed against the competency requirements of the relevant HTM before appointment, and that assessment should be carried out (or verified) by the trust’s Authorising Engineer.
The updated HTM 05-01, published in 2025, provides a useful illustration of how these roles are being formalised and separated across different specialisms. The revised guidance splits responsibilities previously held by the Authorising Engineer (Fire) into two distinct roles: the Independent Expert Advisor (the AE equivalent) and the Specialist Fire Engineer. This trend towards clearer separation of advisory and operational roles is likely to continue across other HTMs. Trusts should review their AP and AE appointment structures to ensure they align with the most current guidance.
In practice, several recurring issues arise when trusts do not have a clear AE/AP governance structure in place. Understanding these gaps is the first step to resolving them.
Gap 1: No formal AE appointment in place
Some trusts operate effective permit systems but have never formally engaged an AE. Without an independent AE carrying out periodic audits and producing written assurance reports, the trust has no structured mechanism for identifying gaps in its safe systems of work — and no formal record to demonstrate to a regulator that independent oversight is occurring.
Gap 2: APs appointed without formal competency assessment
AP appointments must be based on a demonstrable assessment of competence, not simply length of service or seniority. The AE should review the proposed AP’s knowledge, experience, and understanding of the relevant HTM before recommending their appointment in writing. Appointing based on familiarity alone creates both a safety risk and a governance liability.
Gap 3: One AP covering multiple specialisms without specialism-specific assessment
It is not uncommon for trusts — particularly those with smaller estates teams — to have a single individual informally covering multiple AP roles. While there is no absolute bar on an individual being appointed as AP across multiple specialisms, each appointment must be assessed and documented separately. A single letter appointing someone as “AP for all M&E systems” does not meet the requirements of HTM 00.
Gap 4: AP training not matched to current HTM requirements
The HTMs are periodically revised. An AP trained to an older version of the guidance may not be current. Refresher training should be considered whenever a relevant HTM is updated, and the AE should flag this during their annual audit.
Failure to have properly appointed and competent APs in place — supported by an independent AE — is a common finding in CQC inspections and NHS estates audits. In the event of a serious incident, the absence of a proper governance structure will be scrutinised intensely. The time to build it is before something goes wrong.
M&M Compliance Training Services provide both AE services and AP training across the full range of healthcare engineering specialisms, including low voltage, high voltage, ventilation, water systems, medical gas pipeline systems, and pressure vessels. Whether a trust needs an independent AE to provide assurance and AP assessments, or requires AP training and appointment support for new or existing team members, M&M can deliver both sides of the framework.
Our credit-rated training courses are recognised across the NHS and aligned to current HTM requirements, ensuring that AP appointments are built on a documented, auditable competency foundation.
KEY TAKEAWAYS
- The Authorising Engineer is an independent advisor who audits safe systems and recommends AP appointments — they do not carry out operational duties.
- The Authorised Person is operationally responsible for specific systems and formally appointed in writing for each specialism they cover.
- Both roles are defined in HTM 00, which applies across all engineering specialisms in healthcare settings.
- AE services should be provided by an independent party — not by someone employed by the trust.
- AP appointments must be based on a formal competency assessment, not just experience or seniority.
- Recent HTM updates (e.g. HTM 05-01 fire safety) are formalising and separating these roles further — trusts should review their current structures.
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